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[Reminder] New requirements for exporting to the US market

Maybe you have a lot of questions about this new requirement for exporting to the US market. So let me list some common problems in the form of Q/A for your reference. Please refer to below.

Q1: The FCC recently adopted FCC 22-84 on Protecting Against National Security Threats to the Communications Supply Chain through the Equipment Authorization Program.  How does that affect the FCC equipment authorization process?

A1: The attachment below, KDB986446 D01 Covered Equipment v01, provides staff-level equipment authorization guidance on how FCC 22-84 affects the equipment authorization process.

FCC 22-84 Attachment List:


KDB98644 Attachment List:


Q2: When was this new requirement enforced?

A2: FCC 22-84 is listed to be published in the Federal Register on February 6, 2023. Accordingly, since there is no waiting period for these Rules to become effective, it is expected that the new Rules will become effective on February 6 as well.


Q3: Which manufacturers are involved in this new regulation?

A3: In addition to the companies on the cover list, related companies (such as investment companies or subsidiaries for the cover list) are also counted.

Covered List Attachment List:


Q4: What is the difference between this new requirement and the previous FCC certification?

A4: This new requirement requires the applicant to provide 2 new certificates:

1.The first attestation exhibit is for the applicant to certify the equipment subject to certification is not on the equipment covered list and the applicant is not on the applicants covered list. This certificate includes 2 declaration letters: 1.1 Attestation Statements Part 2.911(d)(5)(i) Filing, 1.2 Attestation Statements Part 2.911(d)(5)(ii) Filing.

2.The second attestation exhibit is for the designation of a U.S. agent for service of process. Per the KDB and according to section 2.911(d)(7), the applicant must designate a contact located in the United States for purposes of acting as the applicant’s agent for service of process, regardless of whether the applicant is a domestic or foreign entity. An applicant located in the United States may designate itself as the agent for service of process. The new FCC role is similar to the Canadian representative role for ISED Canada equipment certification requirements.

A reminder that the new documentation required by these Rules will be required for all applications immediately.

Q5: Shall the attestation letter be signed with updated date only when section 1.50002 covered list changed?

 A5:The certifications should be dated as of the date the grantee provides the equipment authorization information to the TCB. A separate signed and dated certification is required for each equipment authorization requested.

Q6: If the covered list and the dedicated U.S. agent have not changed, can the signed attestation letter be re-used?

A6 If the U.S. agent information for the grantee has not changed, a previously used agent certification can be re-used.

Q7: If the applicant is not a US company, and there is no US company to cooperate with, can BTL provide agency services?

A7: Yes, BTL has a cooperative American agency that can provide this service.

If you want to know more about FCC certification, please feel free to contact the BTL team at any time, and BTL will share the most professional and comprehensive information with you.


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