FCC Bad Labs Vote: Which Test Labs Are Affected and What It Means

On April 30, 2026, the FCC votes on whether to ban all test labs in China and Hong Kong from certifying electronics for the US market. 126 labs are directly targeted. If your product is being tested in China right now, or you're planning a test campaign for later this year, this affects you.

What's actually being voted on

The April 30 vote is actually two actions bundled together.

The first is an Order extending the existing Bad Labs rule. The FCC adopted its original "Bad Labs" order in May 2025. That round targeted labs owned or controlled by foreign adversary governments, specifically Chinese state-owned entities. It resulted in 15 labs being banned between September 2025 and February 2026: CTTL/CAICT (100% state-owned), UL-CCIC (joint venture with a state entity), the State Radio Monitoring Center Testing Center, and others.

The April 30 Order extends that ban to all labs in foreign adversary countries, regardless of ownership. Privately held, subsidiary of a German company, joint venture, doesn't matter. If it's physically located in China or Hong Kong, it loses FCC recognition. That's 126 labs.

The second action is an FNPRM (Further Notice of Proposed Rulemaking) proposing to ban labs in any country without a Mutual Recognition Agreement with the US. This one adds only 5 more labs: 4 in India and 1 in Switzerland. Small number, because the FCC's MRA network already covers most countries where test labs operate.

One thing to be clear about: this is a proposal, not a done deal. The vote starts the process. After the FNPRM passes (and it will, all five commissioners have signaled support), there's a public comment period, probably 60-90 days. Then the FCC reviews comments and issues a final rule. Implementation follows with a transition period. Months, not days.

But the direction is obvious. The FCC is not going to reverse course. The question is when, not whether.

Which labs are affected

You've probably seen the "75% of electronics testing happens in China" number in the news coverage. That's a testing volume estimate from the FCC, and it's plausible given that most consumer electronics are manufactured in the Pearl River Delta. But it's not the same as 75% of labs. I pulled the numbers from the complete FCC dataset of 591 recognized test labs, and China plus Hong Kong account for 126 of them, or 21.3%. The gap between those two numbers tells you something: Chinese labs handle a disproportionate share of total testing volume because they're co-located with factories and run at higher throughput.

The numbers

27 are Western-brand subsidiaries

Not all unknown local shops. 27 of the 126 affected labs are Chinese subsidiaries of the same Western testing firms you'd use in the US or Europe:

These companies aren't going away. They all operate labs in the US, Europe, Taiwan, and other MRA-protected countries. What changes is that their China locations can no longer perform FCC-recognized testing. They'll route clients to other facilities.

2 TCBs at risk

Only 2 of the 67 TCBs (Telecommunication Certification Bodies) worldwide are in affected countries. Both are Intertek subsidiaries:

• Intertek Testing Services Shenzhen (Guangzhou)
• Intertek Testing Services Hong Kong

TCBs can both test your device and issue the FCC certification directly. Losing two matters, but Intertek has TCBs in the US and UK that can absorb the work.

15 already banned

The first wave already happened. 15 Chinese labs lost their FCC recognition between September 2025 and February 2026 under the original Bad Labs order. All were state-owned or had direct government ties: CTTL/CAICT, UL-CCIC, the State Radio Monitoring Center Testing Center, TUV Rheinland/CCIC Ningbo (a joint venture with a state entity), CCIC-CSA International, CVC Testing Technology, CESI Guangzhou Standards, Shanghai Institute of Measurement and Testing (SIMT), and others.

Those were the easy calls. The April 30 vote extends the ban to the remaining ~111 labs regardless of who owns them.

Half of them are in Shenzhen

Shenzhen alone accounts for 50 of the 119 mainland China labs, 42% of the China total. The wider Pearl River Delta corridor (Shenzhen, Dongguan, Guangzhou, and surrounding Guangdong) holds 77, or 65% of all Chinese FCC-recognized facilities.

That concentration makes sense. The Pearl River Delta is where most consumer electronics get manufactured. Labs followed factories. Now the labs are being cut off from the FCC system while the factories stay put.

The broader FNPRM: 5 more labs

The FNPRM's non-MRA proposal adds just 5 labs:

India has 4, including a TUV Rheinland subsidiary in Karnataka. India isn't party to any FCC mutual recognition agreement despite being a major electronics hub. The fifth is a Eurofins subsidiary in Switzerland, which isn't covered by the EFTA MRA (only EEA EFTA states like Norway and Iceland qualify).

Not a big deal in practice. Both TUV Rheinland and Eurofins can redirect work to their EU or US facilities.

What's NOT affected

Some coverage has implied "all foreign labs" are at risk. That's wrong. The FCC's MRA network protects labs in 60+ countries. Every lab in an MRA country is unaffected:

460 of 591 labs are completely unaffected. Taiwan's 98 labs, Japan's 71, South Korea's 35, the entire EU, UK, Canada, Australia, Israel. If your country has a reciprocal trade agreement with the US for equipment testing, your labs are fine.

Taiwan is worth watching. With 98 labs, it becomes the largest non-US testing market after the ban. Taiwanese labs serve the same Mandarin-speaking manufacturer base, they're a short flight from Shenzhen, and pricing is comparable. For manufacturers who've been testing in the Pearl River Delta, Taipei is the obvious pivot.

What this means for your product

If you're currently testing in China

Your test results may not be accepted after the final rule takes effect. Don't panic — there's a transition period — but don't ignore it either. Talk to your lab now about their plan. If they're a Western subsidiary (Intertek, SGS, TUV, etc.), they're already preparing to route clients to other facilities.

Timeline

Apr 30 vote → 60-90 day comment period → FCC review → final rule → transition period

You probably have 6-12 months before any new ban takes effect. The public comment period alone eats 60-90 days. Then the FCC reviews comments and issues a final rule. Then a transition period.

That said, 6-12 months goes fast when you're also trying to ship a product. If you're planning a certification campaign for Q3 or Q4 2026, pick your lab now while you still have options.

Cost impact

Testing will get more expensive. Remove 21% of global lab capacity and prices go up. Chinese labs have historically been significantly cheaper than US equivalents. Based on published pricing from labs like Sunfire Testing, Predictable Designs, and JJRLAB, a basic FCC SDoC test runs $400-$1,300 in China versus $3,000-$4,000 in the US. That gap is going to narrow as demand piles into the remaining 460 labs.

Expect longer queues too, especially at Taiwan and US labs. If you're a startup watching certification costs closely, budget for this.

The fail-fix-retest problem

The bigger cost isn't the lab fees. It's the iteration cycle. Today, if your product fails testing at a Shenzhen lab, you walk the prototype back to your factory (sometimes in the same industrial park), fix it, and retest the next day. After the ban, that loop means shipping prototypes internationally, waiting in queue again, and adding weeks each time. Many products fail initial testing. The iteration tax is where this really hurts.

What to do now

Start by checking whether your lab is on the list. Search by name on our lab directory, where every China and Hong Kong lab is flagged.

If you are affected, Taiwan and the US are the natural alternatives. Browse by country on the lab directory, or start with US labs. Taiwan-based labs like Sporton International, and US labs like MiCOM Labs, Intertek North America, and UL Northbrook are the kinds of alternatives worth looking at.

If you're with one of the big Western firms (Intertek, SGS, UL, TUV Rheinland, Bureau Veritas), just call your account manager. They have labs on every continent and they're already working out transition plans for clients testing in China.

For new products where you haven't committed to a lab yet: pick one in the US, Taiwan, Japan, South Korea, or the EU. Don't build a certification workflow around a lab that might lose its FCC recognition mid-campaign.

One thing you don't need to worry about: existing grants. If you have FCC grants based on testing done at a now-banned lab, those grants are still valid. The FCC hasn't proposed retroactively invalidating certifications issued before a lab was banned. Only new testing and new certifications are affected.

For background on how FCC test labs work and how to evaluate them, see our Complete Guide to FCC-Accredited Test Labs.

We'll update this post

The vote is April 30. I'll update this post with the outcome and details on the public comment period once we know more.

Last updated: April 28, 2026