EA Security 2.0

The FCC strengthens its Covered List equipment-authorization regime by barring authorization of covered modular transmitters and devices containing them, creating a prospective process to stop importation and marketing of previously authorized covered equipment, and seeking further comment on related controls.

What it does The Second Report and Order clarifies that the existing prohibition on authorizing covered equipment applies to modular transmitters—including single, split, and limited modular transmitters—and to host devices incorporating them, even where a module was previously authorized. It adopts a procedure allowing the FCC to limit an existing authorization to prohibit future importation and marketing without revoking the authorization or disrupting users’ continued operation. It also gives “produced by” a broad, fact-specific meaning, covering substantial responsibility or control over major stages such as design, manufacture, assembly, or development, and clarifies restrictions on modifications. The accompanying Second Further Notice seeks comment on modules and other component parts, critical infrastructure, permissive changes, marketing, and enforcement.

Who it affects Equipment applicants, responsible parties, manufacturers, importers, distributors, retailers, original equipment manufacturers, grantees, and telecommunications certification bodies must account for the expanded authorization restrictions and attestations. Covered List entities and suppliers of affected equipment are especially impacted; current users may continue operating equipment subject to a future limitation.

Why it matters The item closes a potential pathway for covered equipment to enter devices as a component while avoiding the economic and consumer disruption of mandatory replacement. It also responds to the D.C. Circuit’s partial remand concerning the FCC’s prior critical-infrastructure definition.

Key dates and numbers

• Adopted October 28, 2025; released October 29, 2025.
• Comments due 30 days after Federal Register publication; replies due 45 days after publication.
• Proceeding: ET Docket No. 21-232; FCC 25-71.
• The FCC directs OET and PSHSB to begin proceedings concerning equipment currently on the Covered List.