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The US Federal Communications Commission has voted unanimously to advance new restrictions on foreign electronic device testing, adding fresh uncertainty for China's smart lock industry as it expands overseas.

In a move adopted on 30 April (Eastern Time), the Federal Communications Commission approved two proposals aimed at tightening oversight of foreign telecommunications and electronics-related entities. The measures would: first, restrict FCC recognition of testing laboratories located in countries that do not maintain Mutual Recognition Agreements (MRAs) with the United States; and second, further limit the ability of entities on the FCC's “Covered List” to participate in certain US telecommunications activities.

Both measures remain at the proposal stage and must still undergo a public comment process before any final implementation. However, the direction of US technology policy is increasingly clear. Washington is extending national-security scrutiny beyond telecom equipment and semiconductors into areas such as testing, certification and Internet of Things (IoT) devices. For Chinese smart lock manufacturers seeking overseas growth, the proposed changes could significantly complicate market access.

Certification pathway under pressure – large share of US-bound electronics tested in China

Any smart lock sold in the United States with wireless functionality — including Bluetooth, Wi-Fi or ZigBee connectivity — requires FCC authorization before entering the market. Chinese manufacturers have long relied on domestic laboratories for FCC compliance testing because of lower costs, proximity to production bases and shorter turnaround times.

Under the FCC proposal, laboratories located in countries without FCC-recognized reciprocity agreements could lose eligibility to conduct testing used in FCC equipment authorization procedures. China is not currently an FCC MRA partner country. If the rule is ultimately finalized, manufacturers would need to rely more heavily on laboratories located in the United States or in countries with qualifying agreements.

According to Reuters, 126 of the 591 laboratories currently recognized by the FCC are located in mainland China or Hong Kong. FCC officials have also stated that a large proportion of electronics destined for the US market are currently tested in China, reflecting the country’s central role in global electronics manufacturing and compliance infrastructure.

The proposal follows earlier FCC actions targeting selected Chinese laboratories over national-security concerns. Industry observers view the latest move as a broader expansion of scrutiny over foreign testing and certification systems rather than isolated enforcement actions against individual labs.

Higher compliance costs and longer certification timelines may pressure smaller exporters

For Chinese smart lock firms expanding into the US market, the proposed changes could create two immediate challenges: higher certification costs and longer product approval timelines.

Industry participants note that testing services conducted in China are generally cheaper and faster than equivalent services in the United States or Europe. If manufacturers are required to shift more certification work overseas, additional expenses related to testing fees, sample shipping, customs procedures and project coordination could materially increase compliance costs.

Longer waiting times are another concern. Because a substantial share of FCC-related testing capacity currently operates in China, any reduction in recognized Chinese laboratory participation could redirect demand toward a smaller pool of overseas facilities. This could potentially lengthen certification queues and delay product launches, especially for consumer electronics companies operating on short development cycles.

Large multinational companies with diversified global compliance networks would likely be better positioned to absorb these changes. Smaller Chinese smart lock brands and OEM manufacturers, many of which rely heavily on domestic testing infrastructure and operate on thinner margins, may face greater operational pressure.

Tariffs, cybersecurity requirements and compliance standards continue to raise barriers

The proposed FCC restrictions arrive alongside broader trade and regulatory pressures already affecting Chinese electronics exporters.

The US smart lock market continues to grow rapidly, while competition inside China’s domestic smart lock sector has intensified amid slowing price growth and margin compression. As a result, overseas expansion has become an increasingly important strategy for many Chinese manufacturers.

At the same time, Chinese smart lock brands entering the US market must navigate a growing set of compliance requirements. In addition to existing tariffs on many Chinese goods, connected devices increasingly face cybersecurity-related expectations and industry certification standards.

The FCC-backed “US Cyber Trust Mark” program, an IoT cybersecurity labeling initiative currently being developed in the United States, is expected to encourage manufacturers to meet baseline cybersecurity practices involving software updates, data protection and vulnerability disclosure processes. Although participation is voluntary, the label could become an important commercial signal for retailers and consumers.

In addition, smart lock products sold through major US retail channels often require industry certifications such as ANSI/BHMA standards, which involve additional testing expenses and periodic factory audits. For smaller exporters, the cumulative burden of tariffs, radio-frequency compliance testing, cybersecurity requirements and industry-standard certifications may substantially increase the cost of entering the US market.

China’s Ministry of Commerce has criticized recent FCC actions, arguing that the United States is expanding national-security concepts into normal commercial and technological activities. Chinese officials have warned that such measures could disrupt global supply chains and increase uncertainty for international electronics trade.

Looking ahead, the FCC proposals could increase compliance costs for Chinese smart lock exporters and slow the speed of product launches in the United States if ultimately implemented. Some firms may seek alternative testing arrangements in third countries or expand overseas compliance operations. More broadly, the episode highlights the growing regulatory and geopolitical risks associated with dependence on any single export market and underscores the importance of diversified international strategies for Chinese electronics manufacturers.