💻 Technology
Labs in China Tested 83% of FCC Filings. If the FCC Drops Them, Other Labs Face 5.9x the Work.
The FCC votes October 29 on a draft order to stop recognizing mainland China's test labs from December 1, 2028. Labs in China handled 38,491 of last year's 46,402 equipment applications (U.S. labs, 1,631); by our math, labs elsewhere would need 5.9 times their 2025 FCC workload in 25 months, for under a dollar per American a year at 2025 volumes. Timing is the problem.
Of the 46,402 applications the Federal Communications Commission received in 2025 to sell radio-emitting products in the U.S., 38,491 rested on test reports from labs in China, according to an April staff tally reported by The Epoch Times. Labs in the United States handled 1,631. On October 29, Reuters reports, the commission votes on a draft order that would stop recognizing test labs in economies that do not recognize American ones, starting December 1, 2028, and mainland China is not among the economies that qualify.
If it passes, everyone else gets about 25 months to pick up 83 percent of the work.
What the draft order does
Every phone, router and Bluetooth tracker sold here needs an FCC ID, its own or one on a certified radio module inside it, and getting one means submitting measurements from a recognized lab. As DroneXL describes it, the draft keeps U.S. labs and labs in more than 60 economies with a mutual recognition agreement or reciprocal trade deal with Washington, among them Taiwan, Japan and Vietnam, and ends recognition for labs and for the private reviewers that issue FCC approvals everywhere else. It covers every lab in mainland China and declines an ownership ban, so by our reading a Shenzhen lab is out whoever owns it. China objected through WTO trade-barrier channels and the Consumer Technology Association opposed the proposal, while the Foundation for Defense of Democracies wanted an ownership ban too; commenters who asked for three to five years got about two, the draft saying their claims "generally lack evidentiary support." Grants issued before the cutoff stay valid, and applications filed before it get today's rules.
The FCC says it lacks confidence in testing where the other side will not reciprocate and that moving testing offshore left the program overconcentrated and harder to oversee, The Epoch Times reports, and Chairman Brendan Carr cites a Justice Department warning that an adversary exploiting test labs could infiltrate American networks "on a broad scale." An FCC order in April adds that labs see confidential product details early. Under a 2025 rule, 29 labs the FCC deems adversary-controlled have already lost recognition. The agency has also found 33 incorrect or false test reports from one lab, SLG-CPC, according to DroneXL.
Eighteen years of drift
In 2007, according to DroneXL, U.S. labs handled about 31 percent of applications and Chinese labs about 13 percent. By 2025 they were 3.5 percent and 83 percent; Carr cites 82 percent, counting devices.
| Where the lab is | 2025 applications | Recognized labs | Per lab | If China's work moves |
|---|---|---|---|---|
| China | 38,491 (83%) | 153 / 119 | 252 / 323 | 0 |
| Everywhere else | 7,911 (17%) | 456 / 472 | 17 / 17 | 46,402 (5.9×) |
| Total | 46,402 | 609 / 591 | 76 / 79 | 46,402 |
| Of which, U.S. | 1,631 (3.5%) | 109 / 138 | 15 / 12 | About 9,570 |
Our math: 5.9 times the work in 25 months
Outside China, recognized labs handled 7,911 applications in 2025, about 660 a month, so if the 38,491 tested in China move to them, their FCC workload becomes 46,402 a year, 5.9 times what it was, with just over 25 months to the cutoff. Spread evenly, they must be ready for about 128 more applications a month, every month, until they can take about 3,870 a month. If Hong Kong's seven labs are inside the 38,491, stay eligible as DroneXL's reading allows, and each did an average Chinese lab's volume, the multiple falls to about 4.6 to 4.8.
A recognized lab in China averaged at least 252 applications last year, roughly one per working day, while one elsewhere averaged about 17, one every three weeks. Replacing China's output would take about 153 new labs of the Chinese size, six a month, and fewer if idle labs elsewhere fill up first.
Growth pushes the other way, unevenly. Applications were just over 32,000 in 2021 and an FCC slide projected just under 44,000 for 2022, so depending on the starting year, growth to the deadline puts the multiple between about 6.2 and 7.8.
Money is the smaller problem. Compliance Testing, a U.S. lab, lists $9,000 to $12,000 for a typical Wi-Fi or Bluetooth certification, and its chief executive, Michael Schafer, told the FCC that mainland labs charge 30 to 70 percent less, according to DroneXL, a claim from a rival with a stake in the outcome. A maker paying Chinese rates would pay 1.4 to 3.3 times as much at a U.S. lab, $2,700 to $8,400 more per application, which across 2025's China-tested filings comes to 31 to 95 cents a year for each of about 340 million Americans.
What You Can Do
If you make hardware: check which lab produced the test reports under your existing FCC IDs, since a contract manufacturer may have chosen it for you. If the order passes, later changes to existing products may need a lab in an approved country. For launches after the cutoff, book capacity in Taiwan, Japan or the United States early, get several quotes, and expect prices to rise if capacity tightens.
If you buy hardware: devices you own are unaffected.
If you want a say: the record is in ET Docket 24-136 on the FCC's public filing system, and contacts with commissioners' offices are allowed through the day the Sunshine Agenda comes out, normally a week before the vote, if you file a summary of each in the docket within two business days (one, for contacts on agenda day).
Limitations
The FCC's document server refused our requests, so the draft's contents come from DroneXL and the application counts from The Epoch Times; Reuters confirms the date and Carr's figures. Applications are not devices: one product can generate several filings, and self-certified products file nothing. The two lab counts disagree, as do reports on Hong Kong, and the cost estimate assumes every displaced filing pays one U.S. lab's list price, on one competitor's estimate of the Chinese discount.
The Strongest Case Against This Analysis
The lab tally overstates the problem. A lab outside China handling 17 FCC applications a year is doing mostly other work or sitting partly idle, and nobody publishes chamber-hours, so 5.9 measures FCC workload rather than how many new buildings are needed. Multinational testing chains can shift work between countries, and an anechoic chamber, the foam-lined room where radios get measured, is equipment that can be bought and installed. And on the FCC's reading, 83 percent of American certification passing through one country that does not reciprocate is a chokepoint worth unwinding whatever the congestion.
Most of that holds. At 2025 volumes it makes the multiple a ceiling on new building rather than a floor, but it leaves the timing untouched. Until December 1, 2028, testing in China stays accepted and, on Schafer's numbers, 30 to 70 percent cheaper, and the pending-application rule rewards filing China-tested products right up to the deadline. Two FCC counterweights exist: an April fast lane for trusted-lab devices that need staff sign-off, and a $20,000 fee on other testing, floated but not adopted. If adopted per filing, the fee would swamp the discount; the fast lane's pull is untested. Price alone says wait, and the draft builds a cliff.
The Bottom Line
The testing premium comes to under a dollar a head a year at 2025 volumes. If adopted, the draft gives America a 25-month runway to move most of its device testing out of one country. Watch new lab recognitions outside China and moves by the big testing chains rather than monthly filings, which should stay flat until the cliff; if those signals are not climbing by mid-2027, December 2028 will arrive as a queue, with small hardware makers at the back of it.