Introduction to the FCC’s “Bad Labs” — Ban China Test Labs Initiative
The FCC’s ban on “Bad Labs”—foreign adversary test labs and certification bodies with ties to the Chinese Communist Party—represents the most significant electronics testing security action in U.S. history, affecting the $28 billion market where 75% of American device certification has been outsourced to China.
This comprehensive timeline serves as the ultimate, living resource documenting the movement to restore U.S. sovereignty over electronics testing, continuously updated as new enforcement actions, FCC rulings, and developments regarding FCC Rule 25-27 and foreign adversary lab restrictions unfold.
The One-Way Trade Betrayal
For decades, China executed a calculated strategy to capture America’s electronics testing industry through a fundamentally unfair trade arrangement. Under the U.S.-China Mutual Recognition Agreement, China refuses to accept any testing performed by American laboratories for products entering their market, while the United States accepts Chinese testing for products entering ours. This asymmetric arrangement transferred 75% of U.S. electronics testing business to China—costing American test labs over $1.5 billion annually in lost revenue.
Every device tested by these foreign adversary labs represents a potential national security vulnerability—from smartphones and computers to medical devices and telecommunications infrastructure. The testing process itself exposes proprietary American technology, design specifications, and security protocols directly to entities controlled by the Chinese Communist Party.
Industry Expert Perspective – Michael Schafer – CEO Compliance Testing, LLC:
“We didn’t just outsource testing—we surrendered control of our entire electronics supply chain security to a foreign adversary. China told us decades ago: ‘We won’t accept your testing, but you must accept ours.’ And inexplicably, we agreed.
This one-sided arrangement costs American test labs over a billion dollars every year while simultaneously creating massive national security vulnerabilities. Chinese labs aren’t just testing our devices—they’re collecting intelligence on every piece of American technology that passes through their facilities.
The testing they perform is questionable at best. We’ve documented instances of falsified reports, circumvented regulations, and equipment that somehow passes Chinese labs but fails when retested in American facilities. These aren’t just business practices—these are national security threats.
Every day we allow this system to continue, we’re financing surveillance capabilities that can be turned against American citizens and businesses. The FCC’s action isn’t just about protecting American labs—it’s about protecting America itself. Our U.S. labs stand ready to rapidly scale capacity to handle this critical testing workload with trustworthy, verifiable results that put American security first.”
The Path Forward
As Peter Navarro warned in his 2011 book Death by China: “Every dollar spent on Chinese goods finances a threat to our own soil.” This timeline chronicles how that warning became reality, and how industry experts and federal regulators are fighting to reclaim America’s testing sovereignty and rebuild the domestic testing infrastructure that should never have been surrendered.
What Are “Bad Labs”? Definition & Explanation
“Bad Labs” is the FCC’s official term for electronics testing laboratories and telecommunications certification bodies (TCBs) that pose national security risks to the United States through ownership, control, or direction by foreign adversaries—particularly the Chinese government and Chinese Communist Party (CCP).
Official FCC Definition
According to FCC Rule 25-27, Bad Labs are equipment test laboratories, telecommunications certification bodies (TCBs), or laboratory accreditation bodies that:
- Are owned, controlled, or directed by entities on the FCC’s Covered List
- Have equity or voting interests exceeding 5% by foreign adversary entities
- Are connected to Chinese state-owned enterprises
- Are involved in China’s Military-Civil Fusion apparatus
- Work with or support the People’s Liberation Army
- Operate as Chinese state actors or under CCP influence
Why “Bad Labs” Threaten National Security
Bad Labs have unrestricted access to electronic device specifications, circuit designs, software code, and operational parameters during the FCC certification process. This access allows foreign adversaries to:
- Gather intelligence on American technology and innovation
- Identify vulnerabilities for exploitation
- Steal intellectual property and trade secrets
- Potentially insert surveillance capabilities or backdoors
- Compromise device security before products reach consumers
The Scale of the Problem
Approximately 75% of electronics testing for U.S.-bound devices occurs in Chinese-controlled laboratories. These Bad Labs have tested thousands of smartphones, computers, IoT devices, medical equipment, and telecommunications infrastructure components—all containing sensitive technical data.
Bad Labs control an estimated $28 billion annual market in electronics certification services for U.S.-bound products, representing lost American revenue, jobs, and technological sovereignty outsourced to foreign adversaries.
The HC3 Headquarters building in Hangzhou, China is one of the test labs who’s renewal application from the FCC has been denied.
FCC Chairman Brendan Carr’s Warning:
“While the FCC now includes national security checks in our equipment authorization process, we have not had rules on the books that require the test labs conducting those reviews to be trustworthy actors. Bad labs participate in the approval and testing process—a loophole the FCC must close.”
Chronological Timeline: FCC’s “Bad Labs” — Ban China Test Labs Initiative
We will continue to update this page to contain the latest information about the FCC’s actions to secure the U.S. electronics infrastructure and to protect our national security.
2025.10.15: TELECOM CARRIER – FCC Orders HKT to Show Cause
Document: FCC DA 25-928 Order to Show Cause (.pdf)
The FCC issued an Order to Show Cause directing HKT (International) Limited and four wholly-owned subsidiaries to explain why the Commission should not revoke their domestic and international telecommunications authority under Section 214 of the Communications Act.
Companies Facing Revocation:
- HKT (International) Limited (British Virgin Islands)
- PCCW Global, Inc. (Delaware)
- PCCW Global Limited (Hong Kong)
- Gateway Global Communications Inc. (Delaware)
- PCCW Global (UK) Limited (United Kingdom)
Why This Matters:
HKT is 18.41% owned by China Unicom, a Chinese state-owned enterprise whose U.S. subsidiary (China Unicom Americas) already had Section 214 authority revoked in January 2022. The FCC found China Unicom Americas was “vulnerable to exploitation, influence, and control by the PRC government” and that China’s 2017 National Intelligence Law requires all PRC entities “to cooperate, assist, and support Chinese intelligence efforts wherever they are in the world.”
Section 214 authority grants permission to operate telecommunications networks domestically and provide international services. Revocation means these companies can no longer operate voice, data, or internet services in or from the United States.
The Pattern of Carrier Revocations:
The FCC has systematically revoked operating authority from Chinese government-controlled carriers using identical national security reasoning:
- China Telecom (Americas) – revoked 2021
- China Unicom (Americas) – revoked 2022
- Pacific Networks & ComNet – revoked 2022
- China Mobile International (USA) – application denied 2019
Hong Kong = China:
The FCC explicitly treats Hong Kong as part of the People’s Republic of China, consistent with President Trump’s Executive Order 13936 which suspended Hong Kong’s preferential treatment due to PRC government control.
30-Day Response Deadline: HKT and subsidiaries must respond by November 14, 2025.
Industry Expert Perspective – Michael Schafer – CEO Compliance Testing, LLC:
“This proves the Bad Labs ban isn’t isolated—it’s part of a comprehensive strategy to remove Chinese government control from every layer of U.S. telecom infrastructure. The FCC is using the exact same playbook against telecom carriers that we advocated for testing labs: PRC ownership plus intelligence laws equals unmitigable national security risk. If multibillion-dollar Hong Kong carriers can’t survive FCC scrutiny, Chinese test labs with Communist Party ties don’t stand a chance. The same laws forcing carriers to spy for the CCP also apply to testing laboratories accessing American technology specifications.”
2025.10.14: EQUIPMENT BAN – FCC Issues National Security Advisory on Covered List
Document: FCC National Security Advisory No. 2025-01 (DA 25-927)
The FCC issued its first formal National Security Advisory warning that communications equipment and services on the Covered List pose “unacceptable risks to national security” and can allow the Chinese Communist Party to surveil Americans and disrupt U.S. communications networks.
Key Warning:
The Advisory explicitly states that use, importation, marketing, sale, or interconnection with covered equipment may threaten American national security. The FCC strongly recommends all organizations review the Covered List before purchasing communications equipment.
Current Covered List Entities:
- Telecommunications: Huawei, ZTE, China Mobile, China Telecom, China Unicom
- Video Surveillance: Hikvision, Dahua Technology, Hytera Communications
- Cybersecurity Software: Kaspersky Lab products
Subsidiaries Disclosure:
The Advisory reveals the massive scale of covered entities, including 129 Dahua subsidiaries operating across 50+ countries—demonstrating how deeply Chinese surveillance companies have penetrated global markets.
Industry Expert Perspective – Michael Schafer – CEO Compliance Testing, LLC:
“This National Security Advisory is critical because it creates official federal documentation of the threat. Organizations can no longer claim ignorance about Chinese equipment risks. The disclosure of 129 Dahua subsidiaries alone shows how these companies use complex corporate structures to hide their true scope—exactly the shell game we warned about with testing labs. If Dahua can operate 129 entities worldwide, imagine how easily they can manipulate ownership thresholds to keep their labs operating. This validates our push for complete geographic bans rather than chasing ownership percentages.”
How to Report Violations:
File complaints at www.fcc.gov/complaints or call 1-888-CALL-FCC.
2025.10.14: EQUIPMENT BAN – FCC Issues National Security Advisory on Covered List
Document: FCC National Security Advisory No. 2025-01 (DA 25-927) (.pdf)
The FCC issued its first formal National Security Advisory warning that communications equipment and services on the Covered List pose “unacceptable risks to national security” and can allow the Chinese Communist Party to surveil Americans and disrupt U.S. communications networks.
Key Warning:
The Advisory explicitly states that use, importation, marketing, sale, or interconnection with covered equipment may threaten American national security. The FCC strongly recommends all organizations review the Covered List before purchasing communications equipment.
Current Covered List Entities:
Telecommunications Equipment:
- Huawei Technologies Company (3 subsidiaries reported)
- ZTE Corporation (1 subsidiary reported)
Video Surveillance:
- Hangzhou Hikvision Digital Technology Company (9 subsidiaries reported)
- Dahua Technology Company (3 subsidiaries initially reported; 129 total subsidiaries disclosed September 2025)
- Hytera Communications Corporation (4 subsidiaries reported)
Cybersecurity/Software:
- Kaspersky Lab, Inc. and all predecessors, successors, parents, subsidiaries, or affiliates
Telecommunications Carriers (Section 214 Services):
- China Mobile International USA Inc.
- China Telecom (Americas) Corp.
- Pacific Networks Corp. and subsidiary ComNet (USA) LLC
- China Unicom (Americas) Operations Limited
The Dahua Disclosure Bombshell:
The Advisory reveals that Dahua Technology disclosed 129 subsidiaries and affiliates operating across 50+ countries—demonstrating how deeply Chinese surveillance companies have penetrated global markets through complex corporate structures designed to obscure true ownership and control.
Partial List of Dahua’s 129 Global Entities:
- Dahua Technology USA Inc. (United States)
- Dahua Technology Canada Inc. (Canada)
- Dahua Technology UK Limited (United Kingdom)
- Dahua Technology Australia PTY LTD (Australia)
- Dahua Technology India Private Limited (India)
- Dahua Technology Germany GmbH (Germany)
- Dahua Technology France SAS (France)
- Dahua Technology Italy S.R.L. (Italy)
- Dahua Technology Japan LLC (Japan)
- Plus 120 additional entities across Asia, Europe, Africa, Middle East, and Latin America
(Full list of all 129 Dahua subsidiaries available in Advisory Appendix B)
How This Relates to Ban China Labs:
While the Covered List targets equipment manufacturers and telecom carriers, the same national security reasoning applies to testing laboratories. If Chinese companies can’t be trusted to manufacture equipment or operate networks, they cannot be trusted to test and certify American technology.
Industry Expert Perspective – Michael Schafer – CEO Compliance Testing, LLC:
“This National Security Advisory creates official federal documentation of the threat that validates everything we’ve been saying about Chinese testing labs. The Dahua disclosure alone—129 subsidiaries across 50+ countries—proves how easily Chinese companies manipulate ownership structures to hide their true scope and control.
If Dahua can operate 129 entities worldwide while maintaining CCP connections, imagine how easily Chinese testing labs can restructure ownership to stay below the FCC’s 5% threshold in Rule 25-27. This is exactly why we’ve advocated for complete geographic bans rather than chasing ownership percentages through corporate shell games.
The Advisory explicitly warns that organizations ‘currently using, or considering the purchase of’ covered equipment risk national security threats. That same logic applies to testing: organizations currently using, or considering the use of, Chinese testing laboratories risk exposing American technology specifications, circuit designs, and proprietary information to foreign adversary intelligence gathering.
The FCC already banned these manufacturers’ equipment and these carriers’ services. The next logical step—which we’ve been demanding for over a decade—is banning their testing laboratories for the same reasons. You can’t secure the electronics supply chain if you allow the adversary to inspect every device before it reaches American consumers.”
How to Report Violations:
File complaints at www.fcc.gov/complaints or call 1-888-CALL-FCC.
2025.10.08: FCC’s Actions to Ban Bad Labs
The movement to ban foreign adversary testing labs has achieved significant momentum but faces continued industry resistance. While the FCC’s enforcement actions represent historic progress, comprehensive geographic bans remain unrealized.
Current Situation:
- 15 Chinese labs now facing FCC enforcement action or denial
- 75% of U.S. electronics testing still occurs through foreign facilities
- Presidential Executive Order awaiting White House response
- Manufacturers actively seeking U.S.-based testing alternatives
- Estimated $28 billion testing market beginning to redistribute
Industry Expert Perspective – Michael Schafer – CEO Compliance Testing, LLC:
“We’ve made historic progress, but the job isn’t finished. The FCC’s enforcement actions validate everything we’ve been saying for over a decade, but we need comprehensive geographic bans to truly secure America’s electronics supply chain. The ownership threshold approach will be circumvented—we’ve already seen how Chinese labs are restructuring to avoid detection.”
What’s Needed:
- Presidential executive order implementing complete geographic bans
- Immediate revocation of remaining Chinese lab recognitions
- Government support for U.S. lab capacity expansion
Actions for TCBs and Testing Labs:
- Ensure full compliance with FCC Rule 25-27 ownership disclosure requirements
- Review all partnerships with foreign entities for potential conflicts
- Prepare transition plans away from Chinese testing capacity
- Consider expanding domestic testing capabilities to meet increased demand
- Encourage the FCC to make grants available for expansion of U.S. based testing capacity
2025.10.07: EQUIPMENT BAN – FCC Closes Device and Component Loopholes
Document: FCC Press Release
FCC Chairman Brendan Carr announced the Commission will vote on new rules closing two critical loopholes in protections against foreign adversary equipment, complementing the Bad Labs ban with direct device restrictions.
The Two Loopholes Being Closed:
- Previously-Authorized Devices: Extends prohibitions to older models of Covered List equipment (Huawei, Hikvision) that can currently still be imported and sold in the U.S.
- Component Parts: Bans Covered List component parts embedded within otherwise lawful devices
How This Relates to Bad Labs:
While Rule 25-27 targets the testing laboratories that certify devices, this October 7 action targets the devices and components themselves. Together, they create comprehensive protection: Bad Labs can’t certify products, and Covered List equipment can’t enter the U.S. market.
Chairman Carr’s Statement:
“For years, we have known that devices produced by Huawei, Hikvision, and other Covered List entities threaten America’s national security. But up to now, FCC regulations have not prevented Covered List providers from continuing to sell previously authorized device models. This month, the FCC will vote on closing these loopholes and providing the agency with new tools to safeguard our networks from insecure spy gear.”
Strategic Significance:
This action demonstrates the FCC’s multi-pronged approach to national security: attacking the threat at both the certification stage (Bad Labs) and the device stage (Covered List equipment). The Commission is systematically closing every avenue foreign adversaries use to compromise U.S. communications infrastructure.
Listen to FCC Chairman Brendan Carr briefly describe the China Lab testing problem. (on X)
2025.09.26: TESTING LAB – FCC Denies 4 Additional Chinese Labs
Document: Official FCC Press Release (.pdf)
The FCC continued its enforcement campaign by targeting four more Chinese-controlled testing facilities, bringing the total to 15 labs facing action.
The Four Additional Targeted Labs:
- CCIC-CSA International Certification Co., Ltd. (application denied)
- Industrial Internet Innovation Center (Shanghai) (renewal denied)
- State Radio Monitoring Center (renewal denied)
- Reliability Laboratory – New H3C Technologies Co. Ltd. (renewal denied)
FCC Statement:
“This week’s denials follow the Commission’s action earlier this month targeting 11 other ‘bad labs.’ Altogether, the FCC has now begun proceedings to withdraw recognition or denied applications from 15 China-controlled ‘bad labs’.”
Industry Expert Response – Michael Schafer – CEO Compliance Testing, LLC:
“The FCC is finally taking this seriously, but 15 labs is just scratching the surface. We know there are dozens more Chinese facilities with ties to the CCP that should be banned immediately. Every day we delay is another day these labs can gather intelligence on American technology and compromise our national security.”
2025.09.08: TESTING LAB – FCC Takes Enforcement Action Against Eleven China Labs
Documents: Official FCC Enforcement Notice (.pdf)
The Federal Communications Commission issued Notices of Intent to withdraw recognition from seven major Chinese testing laboratories, marking the first concrete enforcement under Rule 25-27.
Withdrawal Proceedings Initiated (7 Labs):
1. Chongqing Academy of Information and Communications (CAIC/CN1239)
2. CQC Internet of Vehicles Technical Service Co. Ltd. (CQC-IVTS/CN1329)
3. CVC Testing (CVC Guangzhou/CN1282)
4. CVC Testing Shanghai (CVC Shenzhen/CN1363)
5. TTL CAICT (CN1349)
6. TUV Rheinland-CCIC Ningbo Co. Ltd. (CN1237)
7. UL-CCIC (UL-CCI/CN1247)
Recognition Expired – Never Sought Renewal (2 Labs):
8. CESI (Guangzhou) Standards
9. China Academy of Information and Communications Technology (CAICT)
Renewal Applications Denied (2 Labs):
10. Shanghai Institute of Measurement and Testing Technology (SIMT)
11. CCIC Southern Testing Co., Ltd.
Why These Labs Were Targeted:
The FCC identified these facilities as having “deep ties to the Chinese Communist Party” through:
- Connections to Chinese state-owned enterprises
- Involvement in Military-Civil Fusion apparatus
- Apparent work with People’s Liberation Army
- Operating as Chinese state actors
The October 14, 2025 Deadline:
These labs have until October 14, 2025 to respond to the FCC’s enforcement action or lose their ability to test products for the U.S. market.
Market Impact Categories:
- Consumer electronics and smart home devices
- Telecommunications infrastructure and 5G equipment
- Medical devices requiring IEC 60601-1-2 EMC compliance
- Industrial and laboratory equipment
- Automotive electronics and connected vehicle systems
Industry Expert Response – Michael Schafer – CEO Compliance Testing, LLC:
“This enforcement action vindicates what we’ve been saying for over a decade—Chinese testing labs pose legitimate national security threats. But seven labs is just the beginning. The FCC has identified dozens more facilities that should face similar action.”
“The October 14 deadline creates immediate pressure, but manufacturers should have seen this coming. Any company still relying primarily on Chinese testing hasn’t been paying attention to national security trends.”
Market Response:
Within days of the FCC announcement, Taiwanese testing lab Sporton began aggressive email campaigns to U.S. manufacturers, explicitly marketing their services as alternatives to the banned Chinese facilities.
Actions for TCBs:
Review current testing partnerships with the seven named labs • Develop transition plans for products currently in certification pipeline • Identify alternative testing facilities for affected product categories • Prepare for potential supply chain disruptions
2025.09.04: FCC Issues Small Entity Compliance Guide
Document: FCC Small Entity Compliance Guide DA 25-803
The FCC published official guidance to help small businesses, non-profits, and small government entities comply with the new foreign adversary ownership rules.
Key Requirements:
- Within 30 days:TCBs, test labs, and accreditation bodies must certify they’re not owned by prohibited entities
- Within 90 days: Report all equity or voting interests of 5% or greater
- Ongoing: Provide notifications within 30 days of any ownership changes
Document Purpose:
This guide provides the compliance checklist for maintaining FCC recognition under the new foreign adversary rules. All TCBs and testing laboratories must follow these requirements to continue operating.
Actions for TCBs:
- Complete 30-day certification immediately
- Prepare 90-day ownership documentation
- Establish internal processes for ongoing ownership monitoring
- Ensure compliance systems are in place before deadlines
2025.08.20: China Formally Objects Through WTO
Document: PRC Official Comments to FCC
The People’s Republic of China submitted formal objections to the FCC’s foreign adversary rules through the World Trade Organization, claiming violations of trade agreements.
China’s Key Arguments:
- Claims FCC rules violate international trade agreements
- Notes that “about 75% of FCC certification testing performed in China” would be relocated
- Argues rules create unfair trade barriers
- Requests reconsideration of geographic restrictions
Strategic Significance:
China’s admission that 75% of testing occurs in Chinese labs validates industry estimates of the market capture. The WTO objection demonstrates China recognizes the financial impact of losing this $28 billion annual market.
Death by China Excerpt Regarding China Innovation:
Peter Navarro warned about this exact scenario: “China doesn’t innovate—it infiltrates and imitates.” China’s reaction to losing testing lab control proves how strategically important this market capture was to their intelligence gathering operations.
2025.08.07: FCC Rule 25-27 Published in Federal Register
Document: Federal Register Vol. 90, No. 149
The Federal Communications Commission officially published Rule 25-27 with corrections, establishing the compliance framework for all testing laboratories and certification bodies.
Key Provisions:
- 47 CFR Part 2 amendments requiring foreign adversary ownership disclosure
- Certification requirements for TCBs, test labs, and accreditation bodies
- 5% ownership threshold for reporting equity or voting interests
- Framework for reviewing and potentially revoking recognition
Effective Dates:
- September 8, 2025 (general provisions)
- Delayed indefinitely (certain transition period provisions)
Technical Corrections:
The document corrected inadvertent inclusion of compliance dates for provisions delayed indefinitely and clarified language in TCB recognition procedures.
2025.07.15: Industry Battle Lines Drawn – FCC Rule 25-27
30 Day Comment Period Closes
Documents:
FCC 41 Comments Submitted
FCC Comment Analysis
42 organizations and individuals submitted official comments on FCC Rule 25-27, revealing deep industry divisions on how to address foreign adversary testing threats.
The Shocking Statistics:
- Only 4 commenters (9.5%) supported strong geographic-based restrictions
- 34 commenters (81%) actively opposed comprehensive bans
- Industry demonstrated resistance to meaningful reform despite documented national security risks
Michael Schafer’s Official FCC Comments:
On Ownership Thresholds:
“The 5% threshold is impossible theory easily manipulated. Simply start by banning the FA [Foreign Adversary] countries Labs and Certification bodies. If the FCC creates a bunch of rules then will make it take years to properly vet bad actors.”
On Enforcement:
“Where there are any concerns in Phase 1, revoke their FCC Approval as fast as possible. Go back in six month increments, and notify all recent devices tested and certified are revoked due to concerns on the reliability of the China Testing.”
On Geographic Bans:
“Lab locations and simply start by banning the FA countries Labs and Certification Bodies. This is what China did to the U.S. about ten years ago.”
Strong Industry Allies Supporting Reform:
CETECOM Inc.: • Strongly advocated onshoring testing to U.S. laboratories • Noted China’s reciprocal restrictions prevent U.S. labs from testing for Chinese market • Warned of unfair competition from subsidized foreign labs (30-70% lower prices)
RF Safety Laboratory, LLC: • Supported extending prohibitions to entities located in foreign adversary countries • Warned 75% of US testing occurs in China ($28-400 billion lost revenue) • Explicitly supported geographic restrictions combined with ownership controls
The Opposition’s Argument:
The majority of commenters argued that:
- Ownership verification creates regulatory burden on “legitimate” labs
- Geographic restrictions would disrupt supply chains
- Complex ownership structures require nuanced approach
- Industry should self-regulate rather than face mandates
Schafer’s Response to Opposition:
“The industry’s argument proves my point exactly—if ownership is so easily obscured through corporate shell games, why rely on ownership thresholds at all? Geographic bans cut through the complexity: if the lab is in China, it’s banned. Period.”
2025.05.22: FCC RULE 25-27 – Commission Bans Bad Labs – Takes Historic Action
Documents: FCC Rule 25-27 Full Text (114 pages) | FCC Press Release
The Federal Communications Commission adopted new rules to block and remove Chinese government and other untrustworthy actors from controlling America’s wireless equipment authorization process.
What the Rule Does:
- Requires equipment test labs and telecommunications certification bodies (TCBs) to disclose foreign adversary ownership above 5% threshold
- Relies on official security determinations including Defense Department’s List of Chinese Military Companies
- Establishes framework for reviewing and potentially revoking recognition from compromised entities
- Shifts eligibility criteria from purely technical competence to include trustworthiness assessment
FCC’s Shocking Discoveries:
The Commission reviewed currently recognized labs and found numerous facilities with “deep ties to the Chinese Communist Party (CCP),” including:
- Entities connected to Chinese state-owned enterprises
- Labs involved in China’s Military-Civil Fusion apparatus
- Facilities working with the People’s Liberation Army
- Chinese state actors operating as testing facilities
Industry Expert Perspective – Michael Schafer – CEO Compliance Testing, LLC:
“The 5% ownership threshold creates massive loopholes. Chinese labs can easily create shell corporations, silent partnerships, and ownership structures that stay below detection while maintaining operational control. We’ve seen this pattern in other industries—it’s the classic Chinese shell game.”
“The FCC’s approach will take years to properly vet bad actors through lengthy investigation processes. Meanwhile, Chinese labs continue testing thousands of American devices annually, gathering intelligence and potentially compromising device security.”
“Why waste time writing complex rules when the answer is simple: BAN ALL TESTING AND CERTIFICATION LABS OPERATING IN CHINA. China banned our labs a decade ago—we should implement immediate geographic restrictions rather than chasing ownership percentages.”
Death by China Context:
As Navarro documented: “Chinese espionage is like death by a thousand cuts.” Each device tested in Chinese labs represents another intelligence leak that cumulatively damages U.S. technological leadership.
2025.05.01: Initial News Coverage Breaks for FCC Bad Labs Rule
Articles:
- CNET: FCC Wants to Ban Some Chinese Labs From Testing US-Bound Electronics
- Reuters: FCC to Vote to Bar Chinese Labs from Testing US Electronics
- CTOL Digital Solutions: FCC’s Impending Ban Reshapes Global Electronics Supply Chain
Key Media Coverage Points:
CNET (May 1, 2025): FCC Chair Brendan Carr announced the May 22 vote, stating: “While the FCC now includes national security checks in our equipment authorization process, we have not had rules on the books that require the test labs conducting those reviews to be trustworthy actors.”
Reuters (April 30, 2025): Reported the FCC will vote May 22 to finalize rules barring Chinese labs deemed national security risks from testing electronic devices for U.S. market.
CTOL Digital Solutions: Characterized the vote as “the most consequential regulatory vote of 2025,” noting potential for upheaval in global technology supply chains.
Industry Impact Projections:
- 5-30% price increases from alternative testing facilities
- Potential bottlenecks during Q4 2025 holiday season
- Major manufacturers (Nintendo, SpaceX, Apple) shifting to Japan, Taiwan, UK labs
- Smaller manufacturers facing acute capacity problems
Death by China Warning Realized:
The media coverage validated Navarro’s prediction: “We have witnessed the greatest transfer of wealth in human history—from America to China.” The testing industry represented another $28 billion front in this economic warfare.
Michael Schafer is interviewed by Ray Michaels from Total News Nation regarding the FCC Rule 25-27 that is designed to limit foreign adversary labs ability to test and certify electronic devices that are sold in the U.S.
2025.01.30: Michael Schafer Delivers Crisis Briefing Letter to President Trump
Document: Full Schafer Letter to President Trump
After more than a decade of advocacy, Michael Schafer sent a comprehensive briefing package to President Donald J. Trump outlining the electronics testing infrastructure crisis and proposing immediate solutions.
Key Facts Presented:
- Chinese laboratories control 75% of America’s electronics certification process
- China maintains complete ban on American labs while dominating U.S. market
- $28 billion annual vulnerability in critical testing infrastructure
- 5,000-8,000 American jobs lost to Chinese subsidized competition
The Solution Proposed:
Schafer’s letter requested immediate executive action to ban foreign adversary testing labs, mirroring China’s own policy against American facilities. The proposal emphasized that complex ownership thresholds would be easily circumvented, advocating instead for geographic-based restrictions.
Strategic Framing:
The briefing connected to Peter Navarro’s Death by China thesis, positioning testing lab sovereignty as essential to national security and economic independence. Schafer emphasized the proposal aligned with Trump’s America First agenda and could be implemented rapidly—”fixing big problems in weeks not years.”
National Security Angle:
Every smartphone, computer, and IoT device tested by Chinese labs represents potential espionage opportunities. Foreign adversaries could gather intelligence on American technology, insert vulnerabilities, or compromise device security during the certification process.
Letter Recipients:
- President Donald J. Trump
- Vice President JD Vance
- FCC Commissioner Brendan Carr
- Elon Musk (via White House)
- Vivek Ramaswamy (via White House)
- Congressional representatives including David Schweikert, Josh Hawley, Jim Jordan
Death by China Connection:
As Navarro wrote: “Only the Chinese can turn a leather sofa into an acid bath, a baby crib into a lethal weapon.” If Chinese manufacturers can’t be trusted with basic consumer safety, why should their testing labs be trusted to certify electronic safety?
2021.11.11: FEDERAL POLICY – Secure Equipment Act Foundation Established
Full Document (.pdf): Read the Full Secure Equipment Act
November 11, 2021 – Congress passes the Secure Equipment Act of 2021 (Public Law 117-55), establishing the legal precedent for banning foreign adversary equipment from US markets based on national security concerns.
Key Provisions:
- Prohibits FCC authorization of equipment on the “Covered List” of foreign adversary entities
- Requires FCC to update equipment authorization procedures
- Establishes geographic and entity-based restrictions as legitimate federal policy
- Critical Gap: Only addresses equipment manufacturers, NOT testing laboratories
Why This Matters: This federal law proves Congress already recognizes Chinese equipment poses “unacceptable national security risks” and supports geographic bans. Michael’s campaign extends this proven approach to close the testing laboratory loophole.
What US Testing Labs Should Do Based on This Law:
Immediate Actions:
- Monitor the FCC’s Covered List – Track which entities are prohibited under the Secure Equipment Act
- Document Testing Requests – Refuse testing for any equipment from Covered List entities
- Verify Client Compliance – Ensure your clients aren’t seeking authorization for prohibited equipment
- Report Violations – Alert FCC if you discover Covered List equipment seeking unauthorized testing
The Secure Equipment Act establishes the legal framework that Michael Schafer’s “Ban China Test Labs” campaign seeks to complete by extending proven Congressional policy from equipment manufacturers to testing laboratories.
2017.01.04: Schafer Letter to Senator John McCain – No Response
Document: Full Letter from Michael Schafer to Senator John McCain
Michael Schafer, President of Compliance Testing LLC and FCC-accredited testing expert since 2003, identified the China testing lab threat and reached out to Senator John McCain seeking federal action.
The Core Concerns Identified:
- Chinese labs capturing U.S. market share through artificially low pricing (30-70% below U.S. rates)
- China’s complete ban on American labs testing products for Chinese market
- Quality control failures in Chinese testing not meeting U.S. standards
- Potential national security implications of foreign adversary access to electronic device specifications
Historical Significance:
This early advocacy demonstrated that industry professionals recognized the strategic vulnerability years before federal policymakers. The lack of response highlighted how testing infrastructure—though critical to national security—remained invisible to most lawmakers focused on manufacturing and military hardware.
The Parallel to Navarro’s Thesis:
Schafer’s concerns about testing labs mirrored Navarro’s warnings about Chinese market capture strategies. Just as Death by China documented pharmaceutical and food safety compromises, Schafer identified the same pattern in electronics certification.
What Could Have Been:
Had McCain’s office responded in 2017, the U.S. might have addressed the testing lab vulnerability eight years earlier, potentially preventing billions in lost revenue and national security exposure.
Death by China Vindication:
Navarro warned: “China’s currency manipulation is like putting lead weights on American runners while putting rocket boosters on Chinese runners.” This perfectly captured how Chinese labs undercut U.S. labs not through efficiency but through government manipulation.
2011: Death by China Published – The Foundation of the Bad Lab Rule
Book: Death by China: Confronting the Dragon – A Global Call to Action by Peter Navarro and Greg Autry
Peter Navarro and Greg Autry documented China’s systematic economic warfare against the United States, exposing how China uses unfair trade practices, product safety violations, and strategic market capture to undermine American industry.
Key Themes Relevant to Testing Labs:
Chapter 2: Death by Chinese Poison
Documented dangerous product exports and compromised safety standards. China captured 70% of penicillin market, 50% of aspirin, showing systematic penetration of critical industries—including testing and certification.
Notable Quote: “Chinese drug companies have also captured much of the world market in antibiotics, enzymes, primary amino acids, and vitamins.”
Chapter 3: Death by Chinese Junk
Documented dangerous consumer products from toxic toys to faulty electronics. Chinese manufacturers consistently ignored safety standards.
Notable Quote: “Only the Chinese can turn a leather sofa into an acid bath, a baby crib into a lethal weapon.”
Chapter 9: Death by Chinese Spy
Revealed systematic technology theft through infiltration of American institutions, foreshadowing concerns about testing lab espionage.
Notable Quote: “China doesn’t innovate—it infiltrates and imitates.”
Chapter 10: Death by Red Hacker
Exposed cyber warfare capabilities that could be enhanced through access to electronic device specifications during testing.
Notable Quote: “Chinese hackers are the new barbarians at the digital gates.”
The Testing Lab Connection:
Navarro’s central thesis—that China doesn’t innovate, it infiltrates and imitates—directly applies to electronics testing. Just as China captured pharmaceutical and food safety testing markets, they systematically targeted electronics certification.
The Warning:
“Every dollar spent on Chinese goods finances a threat to our own soil.” This resonated with testing industry professionals who saw American labs losing market share to subsidized Chinese competitors.
Industry Impact:
While policymakers focused on manufacturing jobs, testing industry professionals recognized Navarro’s framework applied to regulatory infrastructure. China’s strategy wasn’t limited to making products—it extended to controlling the certification process itself.
Next Steps – in the FCC Bad Labs – Ban China Test Labs Initiative
Contact the FCC: Federal Communications Commission
45 L Street NE Washington, DC 20554 www.fcc.gov
Contact the White House: The White House 1600 Pennsylvania Avenue NW Washington, DC 20500 www.whitehouse.gov/contact
Support U.S. Testing Labs: Choose American-based testing laboratories for your electronics certification needs.
Share This Timeline: Help raise awareness about testing infrastructure sovereignty and national security.
About the Expert
Michael Schafer has been President of Compliance Testing LLC since 2003, operating one of Arizona’s oldest continuously operating FCC/Canada recognized testing laboratories. With ISO/IEC 17025 certification (AT-2901) and TCB recognition (ISO/IEC 17065), Schafer has advocated for testing lab sovereignty for over a decade.
About Compliance Testing:
- FCC-accredited testing laboratory since 2003
- ISO 17025 and ISO 17065 accredited • Thousands of successful certifications
- Full-spectrum testing for FCC, IC, and international standards
- Rated Top Telecom Testing Company of 2023
Learn More About Compliance Testing
This page is continuously updated as new developments occur. Bookmark this resource to track the movement’s progress.
COMMENT: Let The FCC and White House Hear from You
Please SAVE OUR US TEST LABS and PROTECT US IMPORTED PRODUCTs by being tested only by US Labs AND protect our US ENGINEER’S JOBS
Suggested Comments to Send to the FCC and the White House:
Click on the Golden Button or the Form to send your comments to the FCC.
Review the proposed elements below to include in your comments to the FCC
1. Why would the FCC allow China labs to perform critical regulatory testing which protects us from problem products and electronics when CHINA HAS NOT ALLOWED THE U.S. Test Labs to perform similar testing on U.S. products going to China?
2. China also tests food coming to the U.S. and few years ago the dog food killed dogs.
3. China still has a test lab in Wuhan from which they shipped the U.S. COVID virus, can we trust the China Labs to test anything. This has to stop
4. The FCC is already planning to remove the most obvious Test Labs, that tested transmitters that violated U.S. National Security. We need to do that on all China Test Labs.
5. The FCC has estimated about 75% of U.S. Regulatory Testing is performed by China Labs. Estimates of this are $28bb to $400bb in lost U.S. Test revenue to China.
6. Improper testing can be fatal. RF and EMC labs test to critical requirements including protecting RF emissions from causing brain damage from cell phone and other transmitters, to RF emissions which could fatally interfere pace makers for fatal results. Or interference with police radios. Data can be taken via Chinese made electronics as a form of spying via wifi, cellular, routers, sensors, IoT devices, drones,voting machines connected to the internet and much more. Imagine most or all of all China made transmitters having the ability to spy us with their products – just like they do on their own citizens.
7. Thousands of American jobs have been lost to China Test Lab Engineers
8. We cannot trust the testing of China Test Labs as many devices retested in the us when originally tested by a Chinese Lab fail the real U.S Standards.
9. Europe currently requires cybersecurity testing for internet-connected devices falling under the RED directive, with broader requirements starting in 2027.
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