OET Initiates Withdrawal Proceedings Under Equipment Authorization Rules
On September 8, 2025, the Federal Communications Commission's Office of Engineering and Technology (OET) released a Notice of Intent to Begin Proceedings to Withdraw Recognition of UL-CCIC Company Limited (UL-CCIC) as an accredited test laboratory. The action, docketed under ET Docket No. 25-270 (DA 25-797), is taken pursuant to section 302(e) of the Communications Act of 1934 and sections 2.951(d)(1) and 2.951(e) of the Commission's rules.
Under rules adopted in the FCC's Equipment Authorization Integrity Report and Order (FCC 25-27), the Commission will withdraw recognition of any measurement facility or test laboratory that is owned by, controlled by, or subject to the direction of a prohibited entity. Prohibited entities include foreign adversaries listed in 15 CFR § 791.4, which includes the People's Republic of China (PRC).
OET has reached a tentative determination that UL-CCIC is subject to the ownership, control, or direction of the PRC, thereby prompting the formal notice of withdrawal proceedings.
- Order designation: DA 25-797, ET Docket No. 25-270
- Statutory and regulatory authority: 47 U.S.C. § 302a(e) and 47 CFR §§ 2.902, 2.951(d)(1), and 2.951(e)
- Adopted and released date: September 8, 2025
Joint Venture Structure and State Supervision Findings
According to the Commission's findings, UL-CCIC is incorporated in the PRC and operates as a joint venture between UL LLC and China Certification & Inspection Group Co., Ltd. (CCIC Group). Under an Amended and Restated Joint Venture Contract dated October 28, 2022 (extending an initial agreement from June 26, 2002), each partner holds a 50 percent equity and voting interest.
The Commission noted that CCIC Group is a state-owned enterprise established with the approval of the PRC State Council and managed under the State-owned Assets Supervision and Administration Commission of the State Council (SASAC). SASAC exercises oversight mandated by the Central Committee of the Chinese Communist Party.
Based on this corporate structure, OET tentatively concluded that the PRC possesses at least negative control and holds the power to determine, direct, or decide important matters affecting the company, placing UL-CCIC within the definition of control under section 2.902 of the Commission's rules.
- Ownership: 50% UL LLC, 50% CCIC Group under an amended contract dated October 28, 2022
- Supervisory body: State-owned Assets Supervision and Administration Commission of the State Council (SASAC)
- Regulatory standard: 47 CFR § 2.902 criteria for entities supervised, directed, controlled, financed, or subsidized by a prohibited entity
Testing Laboratory Background and Scope of Recognition
UL-CCIC is based in Suzhou, China, and holds American Association for Laboratory Accreditation (A2LA) Certificate No. 4829.01, ISO/IEC 17025:2017 accreditation, FCC Designation No. CN1247, and Conformity Assessment Body (CAB) identifier CN0073. First accredited in 2018, the facility was most recently recognized by the FCC on August 4, 2025, with an expiration date of June 30, 2026.
The laboratory's scope of recognition covers testing for electrical and electronic equipment, IT equipment, sound and TV broadcast receivers, household appliances, electric tools, lighting, short-range devices, mobile and portable radio, industrial scientific and medical (ISM) equipment, RLAN devices, and wireless communication devices.
UL-CCIC has contributed test reports to hundreds of equipment certifications, including testing cited in the notice for Beijing Roborock Technology Co., Ltd. under FCC ID 2AN2O-RRE0VSP01.
- Laboratory identity: UL-CCIC Company Limited, Designation No. CN1247, CAB identifier CN0073
- Accreditation certificate: A2LA Certificate No. 4829.01 (ISO/IEC 17025:2017)
- Sample equipment authorization referenced: FCC ID 2AN2O-RRE0VSP01 (granted July 15, 2025)
Response Deadline and Evidentiary Filing Requirements
Pursuant to 47 CFR § 2.951(e), the Commission provides UL-CCIC until October 14, 2025, to submit a written response demonstrating why the FCC should not begin formal proceedings to withdraw its recognition.
Any response filed by UL-CCIC must address whether the company is owned by, controlled by, or subject to the direction of the PRC. The submission must be in English (or include certified English translations) and be supported by official business documentation and sworn declarations signed pursuant to 47 CFR § 1.16 by individuals with personal knowledge.
Filings must reference ET Docket No. 25-270 and Designation No. CN1247, submitted electronically via the FCC's Electronic Comment Filing System (ECFS) and emailed to OET staff member Jamie Coleman. Formal notice was ordered served to Jie Qian at UL-CCIC's address in Suzhou Industrial Park, Suzhou, China.
- Response deadline: October 14, 2025
- Submission channels: FCC Electronic Comment Filing System (Docket No. 25-270) and email to jamie.coleman@fcc.gov
- Service recipient: Jie Qian, UL-CCIC Company Limited, No. 2 Chengwan Road, Suzhou Industrial Park, Suzhou, China 215122