Gear Authorization Rules Require a Cautious Approach: CTIA
CTIA agreed with other commenters that urged the FCC to move with caution in response to a further NPRM approved in October as part of a broader order that further tightens the agency's equipment authorization rules (see 2601060037). Comments were posted this week in docket 21-232.
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The FCC should use its new post-authorization limitation process “judiciously, taking due account of considerations relevant to prohibitions on marketing and importation of previously authorized devices,” CTIA said. The commission also shouldn’t impose “restrictions on certified devices based on their component parts.” In addition, the industry needs “practical guidance on the application of the Commission’s new interpretation of the term ‘produced by,’” as used in the covered list and other regulations, the group said.
MEMA, the Vehicle Suppliers Association, warned of “unintended consequences for vehicle suppliers, vehicle safety, cybersecurity responsiveness, and supply chain resilience” as a result of the proposed rules. MEMA members “operate within tightly constrained development cycles, must comply with overlapping federal safety and cybersecurity regimes, and rely on globally integrated technology ecosystems.”
Garmin International said it will prove “extremely difficult (or, in some cases, impossible) and cost prohibitive” for companies to identify all hardware, firmware and software components or semiconductors in their supply chain “that may have been produced by a Covered Entity or their subsidiaries and affiliates.” For avionics devices, the commission should defer to the expertise of the FAA on equipment authorization “whenever possible,” it said.