The FCC supply chain rules introduce new considerations for manufacturers preparing equipment for the United States market. From component sourcing to online listings, the measures address how companies obtain equipment authorization and market their products.
On September 11, 2026, the Federal Communications Commission published its Final Rule, “Protecting Against National Security Threats to the Communications Supply Chain Through the Equipment Authorization Program.” The publication identifies the rule as 91 FR 57798, ET Docket No. 21-232, FCC 26-50.
The rule takes effect on October 13, 2026, with separate implementation dates for online marketplace requirements in 2027.
FCC Supply Chain Rules: Component Restrictions
The rule prohibits equipment authorization for RF or digital devices that incorporate logic-bearing hardware components produced by entities on the FCC Covered List.
These components include systems-on-chip (SoCs), microcontrollers (MCUs), field-programmable gate arrays (FPGAs), application-specific integrated circuits (ASICs), and RF modules. Accordingly, manufacturers should examine component origins when reviewing products intended for the US market.
Additionally, applicants must provide updated attestation statements when submitting certification applications through Telecommunications Certification Bodies (TCBs). Component sourcing and certification documentation therefore require coordinated attention.
Recertification for Covered List Entities
Covered List entities seeking equipment modifications must undergo full recertification. They cannot use permissive changes or a Supplier’s Declaration of Conformity (SDoC) for those modifications.
This requirement establishes a specific authorization pathway for the entities concerned. Moreover, the rule refines the definition of critical infrastructure applicable to its supply chain restrictions.
Online Marketplace Requirements and Dates
The rule also extends marketing regulations under 47 CFR 2.803 to e-commerce platforms and requires the display of valid FCC IDs at the point of sale.
The supplied implementation schedule distinguishes two dates:
- March 1, 2027: Requirements for platforms taking title to or possession of products.
- June 1, 2027: Third-party marketplace certification requirements.
Consequently, businesses should distinguish the rule’s October 2026 effective date from these later marketplace milestones when planning their compliance activities.
Preparing for the Requirements
Manufacturers targeting the United States should begin reviewing their Bills of Materials (BoMs) to identify integrated circuits or logic-bearing components originating from Covered List entities. In parallel, certification teams should prepare for updated attestations and review the applicable authorization pathway.
Entirety’s Product Certification Service can support companies navigating equipment authorization requirements and preparing their market access activities.
Impact Assessment
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Technical Standards?
No -
Type Approval & Market Access?
Yes -
Imports, Customs, Trade, or Market Surveillance?
Yes -
Spectrum Management?
No
