Overview of Rule Changes in GEN Docket No. 87-212
In a Report and Order adopted on December 15, 1988, and released on January 5, 1989, the Federal Communications Commission amended Part 2 of its rules governing equipment authorization procedures. The Commission initiated the proceeding in GEN Docket No. 87-212 to reduce burdensome paperwork, accommodate modern manufacturing practices, and enhance the efficiency of its compliance sampling program.
The Commission estimated that eliminating repetitive application requirements will save equipment grantees approximately 26,400 hours and roughly $700,000 in filing fees annually. The revised regulations take effect on February 21, 1989.
- FCC Docket: GEN Docket No. 87-212
- FCC Document Number: FCC 88-412
- Adoption Date: December 15, 1988
- Release Date: January 5, 1989
- Effective Date: February 21, 1989
Modifications to the FCC Identifier and Labeling Rules
Under previous rules, the FCC Identifier (FCC ID) was composed of three elements: a grantee code, a manufacturer code, and an equipment product code. Because grantees frequently switch manufacturing sources to manage production costs, requiring separate authorizations for each manufacturer created delays and excessive filings. Under the amended Section 2.926, the manufacturer code has been eliminated. The FCC ID now consists solely of a three-character grantee code followed by a product code of up to 14 characters. The product code may include Arabic numerals, capital letters, and the dash or hyphen character.
The Commission also removed several rigid formatting mandates for equipment labels under Section 2.925. Grantees are no longer required to place their company name or trade name on the FCC label, the label information no longer needs to be circumscribed by a box or outline, and FCC markings may now be combined with other safety or electrical certification labels.
Additionally, the Commission eliminated the requirement to list the country of origin on the FCC label, recognizing that product origin labeling falls under the primary jurisdiction and distinct definitions of the United States Customs Service.
- Manufacturer code removed from the mandatory FCC ID structure
- Equipment product codes may be up to 14 alphanumeric characters and hyphens
- Requirement to circumscribe FCC ID information with a line is eliminated
- Mandatory display of grantee name, trade name, and country of origin removed from FCC labels
- FCC identification labels may be combined with other required equipment markings
Trade Name Filings and Permissive Changes
The Report and Order established a new Section 2.924, allowing grantees to market electrically identical equipment under multiple trade names and model numbers without submitting new applications for authorization. Under the previous framework, adding a marketing trade name necessitated a new filing even when internal circuitry was untouched.
Grantees may now distribute devices under any trade name or model number under the original FCC ID, provided the devices remain electrically identical within the scope of a Class I permissive change. Conforming amendments were also made to Section 2.1043 regarding permissive change descriptions.
- New Section 2.924 permits marketing under multiple trade names under a single grant
- Devices must remain electrically identical within Class I permissive change criteria
- Section 2.1043 updated to align permissive change references with new identification rules
Equipment Sampling Procedures and Administrative Deadlines
To resolve delays in post-market compliance oversight, the Commission added Section 2.946, establishing explicit deadlines for grantees to submit equipment test samples upon request. Grantees must submit requested test samples within 60 days of receiving notice. For matters involving harmful interference or safety of life and property, the Commission may shorten the response period to no less than 14 days. Failure to provide samples within the required timeframe may lead to monetary forfeitures under Section 1.80 or suspension of pending applications.
The FCC declined a proposal that would have permitted agency staff to select test samples directly from grantee production or inventory facilities, noting logistical and administrative burdens raised by industry commenters.
Other administrative revisions include the addition of Section 2.910, specifying official mailing addresses for applications in Washington, D.C., and sample submissions at the FCC Laboratory in Columbia, Maryland. Section 2.934 was amended to require grantees to notify the FCC in writing within 30 days of any change in grantee name or address, and Section 2.954 was updated to prohibit verification labels from mimicking standard FCC ID formats.
- Standard 60-day response window established for FCC equipment sample requests
- Expedited window of 14 to 60 days permitted for safety or interference inquiries
- Section 2.910 codifies Columbia, MD laboratory address for sample submittals
- Section 2.934 sets a 30-day post-change deadline for grantee name and address updates
- Section 2.954 clarifies label distinctness for verified devices