The United States is moving to eliminate a little-known but significant dependence on China within its technology supply chain, following a Federal Communications Commission (FCC) decision to prohibit Chinese laboratories from testing electronic devices for the American market.
The FCC voted unanimously on Oct. 29 to end recognition of testing laboratories in countries that do not provide reciprocal access to American facilities. The restrictions, scheduled to take effect on Dec. 1, 2028, will affect the regulatory approval process for products ranging from smartphones and computers to wireless cameras, routers, and other connected devices.
The decision exposes a striking imbalance. According to FCC data, China accounted for 82.3 percent of equipment authorization testing in 2025, compared with just 3.6 percent conducted in the United States. The figures concern testing associated with FCC equipment authorizations, rather than every type of electronics testing.
Beijing reacted angrily to the announcement, accusing Washington of undermining global supply chains and warning that additional retaliatory measures could follow.
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How China came to dominate American electronics testing
The FCC’s decision highlights how dramatically the American electronics testing industry has changed over the past two decades.
In 2007, approximately 30.7 percent of FCC equipment authorization testing was conducted by laboratories in the United States, while China accounted for just 12.7 percent.
By 2025, China’s share had climbed to 82.3 percent, while the American share had fallen to 3.6 percent.
FCC Chairman Brendan Carr highlighted the disparity in a statement accompanying the commission’s decision, observing that “only 3.6 percent of testing occurs in the United States, while 82.3 percent occurs in China.”
The figures illustrate how a regulatory function once substantially performed by American laboratories has become concentrated in a country Washington increasingly considers a strategic competitor.
The shift closely followed the movement of global electronics manufacturing to China, where companies could manufacture, test, and prepare products for export within the same industrial regions.
In an Oct. 28 interview with Lawfare, Andy Hendrickson, chief of the FCC’s Office of Engineering and Technology, acknowledged that manufacturing economics contributed to the transformation.
Companies naturally prefer to “test close to where they build products,” Hendrickson explained.
However, he also pointed to American regulatory policies that allowed overseas laboratories to conduct testing for the U.S. market even when their home countries did not extend comparable privileges to American facilities.
The resulting arrangement enabled Chinese testing companies to serve American manufacturers while U.S. laboratories faced restrictions when seeking similar access to China’s market.
According to the FCC, the concentration of testing work also creates a supply-chain vulnerability, leaving American manufacturers heavily dependent on facilities operating under a different country’s legal and regulatory systems.
The new rules seek to reverse that arrangement by requiring testing, certification, and accreditation activities to take place in the United States or jurisdictions with reciprocal agreements.
National security concerns drive Washington’s crackdown
Beyond the economic imbalance, American regulators have raised concerns about the security and reliability of the laboratories responsible for evaluating electronic equipment.
Before certain wireless devices can receive authorization for sale in the United States, manufacturers must submit technical information demonstrating compliance with FCC requirements.
Testing laboratories examine radiofrequency emissions, interference characteristics, and other technical specifications. Their findings are subsequently reviewed as part of the equipment authorization process.
The facilities can therefore gain access to sensitive product designs and technical information before devices become commercially available.
“These labs are a critical gateway into American communications infrastructure,” Carr said following the October decision, according to Reuters.
He warned that compromised laboratories could potentially approve insecure equipment, interfere with communications networks, or facilitate intellectual property theft.
The FCC has also uncovered documented irregularities involving Chinese testing facilities.
In June, the agency initiated proceedings against Dongguan-based SLG-CPC Test Laboratory after discovering that 33 equipment authorization filings apparently relied on duplicated testing reports, including reports submitted for different products.
The laboratory acknowledged submitting falsified reports, according to the FCC, which subsequently withdrew its recognition in October.
“Falsifying test data plainly undermines trust in the FCC’s equipment authorization process,” Carr said in the agency’s June 9 enforcement announcement.
Other enforcement actions have targeted laboratories accused of submitting inaccurate or falsified results. The FCC has also removed recognition from facilities with prohibited foreign ties.
In another case discussed during the October Lawfare interview, FCC official Alice Jou described an investigation into Derycom, a telecommunications certification body registered at an address in Minnesota.
According to Jou, investigators discovered that most of its personnel were actually based in China and that the company had misrepresented where its certification work was performed.
The company had processed nearly 12,000 applications in approximately 18 months before its accreditation was suspended.
The incidents provide documented grounds for concerns about regulatory oversight and testing integrity. However, falsified testing reports do not, by themselves, establish that Chinese laboratories have engaged in espionage.
The FCC’s broader position is that testing organizations operating outside jurisdictions with enforceable reciprocal agreements create risks that cannot always be adequately addressed through individual enforcement actions.
Beijing threatens retaliation as manufacturers face higher costs
China’s Ministry of Commerce condemned the FCC decision on Oct. 30, accusing Washington of interfering with ordinary commercial activity and threatening the stability of international supply chains.
In an official statement, the ministry argued that Chinese laboratories provide cost-effective services supporting electronics manufacturing and international trade.
Beijing maintained that relocating testing operations would increase business expenses, delay product development, and ultimately harm American companies and consumers.
The ministry also claimed that China had repeatedly proposed negotiations over a bilateral mutual-recognition agreement but received a negative response from Washington.
It urged the United States to “immediately revoke the relevant measures” and warned that additional countermeasures could follow if the restrictions remained in place.
Chinese Foreign Ministry spokesperson Guo Jiakun reinforced Beijing’s objections during an Oct. 30 press briefing.
“The U.S. is overstretching the concept of national security and abusing state power to go after Chinese businesses,” Guo said, according to the ministry’s official English-language transcript.
Guo argued that Washington’s approach would damage economic cooperation between American and Chinese companies and said Beijing would defend its interests.
For American manufacturers, however, the implications extend beyond the diplomatic dispute.
An FCC regulatory analysis estimated approximately $79.3 million in additional annual testing costs under assumptions about manufacturers relocating work to American laboratories and facilities in countries with reciprocal arrangements.
The estimate is based on modeled testing costs rather than confirmed future expenditures. Actual costs will depend on laboratory capacity, pricing, and the locations manufacturers ultimately select.
Industry concerns also include potential delays in product development, particularly if testing facilities in approved countries experience a sudden increase in demand.
Nevertheless, the restrictions do not require all electronics testing to return to the United States.
American authorities recognize reciprocal testing arrangements with numerous countries and territories, including Japan, South Korea, Taiwan, Hong Kong, and Canada.
This means manufacturers could relocate testing operations elsewhere in Asia rather than bring them back to America.
Hendrickson acknowledged that distinction during his Lawfare interview.
“The goal is not to move every single test lab to America,” he said, explaining that Washington also wants a more geographically diversified network of approved testing facilities.
According to an analysis published by law firm Covington & Burling, the FCC’s approximately two-year transition period is intended to allow manufacturers to identify alternative facilities without disrupting existing equipment approvals.
Authorizations already granted, along with applications received before the December 2028 deadline, are not expected to be affected by the new location restrictions.
The dispute nevertheless illustrates a broader challenge confronting Washington as it seeks to reduce reliance on Chinese technology and industrial services.
Although U.S. restrictions have traditionally focused on advanced semiconductors, telecommunications infrastructure, and sensitive electronic components, the latest FCC action extends that effort into the testing and certification systems supporting the global electronics industry.
Whether the policy ultimately revives American testing capacity or simply redirects business toward other international facilities remains uncertain.
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