Notice of Intent to Withdraw Laboratory Recognition
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 its recognition of Telecommunication Technology Labs, CAICT (TTL) as an accredited test laboratory. The action was initiated under sections 2.951(d)(1) and 2.951(e) of the Commission's rules, following regulations established in the Equipment Authorization Integrity Report and Order (FCC 25-27, ET Docket No. 24-136).
Under Section 302 of the Communications Act of 1934, as amended, the FCC sets technical standards and authorization rules for radio frequency (RF) equipment to prevent harmful interference. Under the updated regulatory framework, test laboratories recognized by the FCC to test equipment for compliance must satisfy rigorous integrity standards and cannot remain recognized if owned by, controlled by, or subject to the direction of a prohibited entity.
Tentative Findings and Regulatory Basis
Under 47 CFR Section 2.902, prohibited entities include foreign adversaries identified by the Secretary of Commerce pursuant to 15 CFR Section 791.4, which includes the People's Republic of China (PRC). Section 2.951(d)(1) mandates the withdrawal of recognition for test facilities owned by, controlled by, or subject to the direction of such entities.
In the Notice (DA 25-794, ET Docket No. 25-267), OET made a tentative determination that TTL (Designation No. CN1349) is subject to the control and direction of the PRC through its institutional hierarchy:
OET noted that since its initial accreditation in 2007, TTL has performed compliance testing contributing to thousands of equipment authorizations, including grants held by Huawei Technology Co., Ltd. and ZTE Corporation, both of which are listed on the FCC's Covered List.
- TTL operates as a business department within the China Academy of Information and Communications Technology (CAICT).
- CAICT is a scientific research institute directly under the Ministry of Industry and Information Technology (MIIT) of China.
- MIIT is an administrative department under the State Council of the PRC responsible for China's industrial branches and information industry.
Response Deadline and Procedural Requirements
The Commission has provided TTL until October 14, 2025, to submit a written response showing why the FCC should not proceed with withdrawing its recognition as an accredited measurement facility.
The response must be submitted in English, filed electronically in ET Docket No. 25-267 via the FCC's Electronic Comment Filing System (ECFS), and emailed to OET staff. All filings must include supporting official business documents (with certified English translations where applicable) and sworn declarations signed in compliance with 47 CFR Section 1.16.