Delete, Delete, Delete: TIA’s Proposal to Modernize Legacy FCC Regulations
The Telecommunications Industry Association (TIA) strongly supports Federal Communications Commission (FCC) Chairman Brendan Carr’s bold “Delete, Delete, Delete” initiative to eliminate outdated regulations that limit innovation and progress.
In response to this sweeping deregulatory effort, TIA has outlined key recommendations to modernize and streamline the FCC’s regulatory framework. This blog reviews those recommendations, which include updating labeling requirements to enable QR code use, expanding the Supplier’s Declaration of Conformity (SDoC) program, and simplifying testing procedures under the Telecommunications Certification Bodies (TCBs) framework.
TIA applauds Chairman Carr’s leadership in advancing a more modern, efficient, and innovation-friendly approach to equipment authorization and market access.
Modernizing Labeling Requirements for a Digital-First Economy
Labels on information and communications technology (ICT) devices and packaging provide essential compliance and operational details. Legacy FCC regulations require physical labels—even when space is constrained—limiting how manufacturers design and package their products.
The FCC has acknowledged the utility of QR codes through its Cyber Trust Mark program, which requires a QR code on ICT devices or packaging that links to detailed security information. Building on this precedent, TIA recommends the Commission update its broader labeling rules to mandate a single QR code on product packaging that would provide access to all required product information.
If adopted, the QR code would replace legacy requirements that no longer reflect how consumers access product information. These include compliance statements affixed to the device, packaging, and user manual; overlapping disclosures for unlicensed digital devices; and duplicate SDoC-related statements.
TIA recommends the FCC eliminate redundant requirements and implement a streamlined, digital-first framework that maintains access to key information while supporting more efficient, flexible, and user-centric packaging and labeling.
Expanding SDoC and Streamlining Testing Through TCBs
Like QR-based labeling, the FCC’s SDoC program reflects a shift toward more efficient equipment authorization. It allows manufacturers to self-approve certain low-risk devices, reducing time to market without compromising safety or compliance. Supported by both industry and the testing community, SDoC demonstrates self-approval is a viable and effective mechanism for qualifying such equipment. As noted in TIA’s 2024 comments on the Equipment Authorization Program NPRM, the FCC should build on this success by expanding SDoC eligibility to additional device categories.
The FCC’s delegation of testing and certification tasks to TCBs has similarly improved efficiency and conserved agency resources. TIA recommends reviewing additional requirements that could be delegated or eliminated, including those within the Pre-Approval Guidance (PAG) process.
TCBs should be authorized to submit declarations—such as those for software-defined radios and security documents—without further Commission review when using previously approved materials. Consolidating these declarations into a single SDoC will further reduce delays and help prevent certification bottlenecks slowing the release of new technologies.
Targeted Rule Revisions to Support Streamlined Authorization and Market Access
Building on the success of the SDoC and TCB frameworks, TIA encourages the FCC to further streamline equipment authorization by revisiting rules governing self-approval and third-party certification. Expanding the scope of equipment eligible for SDoC and empowering TCBs to make more independent decisions will help reduce bottlenecks and accelerate certification timelines, particularly when the FCC has already reviewed the relevant device documentation.
TIA also recommends the Commission revise its rules governing the importation and conditional sale of ICT equipment. Current restrictions slow the introduction of new technologies by limiting the number of pre-certified devices manufacturers can import for testing, marketing, or demonstration. The FCC should revisit these provisions to remove overly restrictive conditions and accelerate the importation process.
Conclusion
Chairman Carr’s bold “Delete, Delete, Delete” initiative offers the telecommunications industry a timely opportunity to modernize FCC regulations in step with evolving consumer and business expectations. TIA supports the Commission’s commitment to reducing legacy regulatory burdens and encourages continued, targeted reforms that streamline labeling, device approval, and market access. By adopting a digital-first approach, the FCC can improve efficiency while upholding safety, compliance, and public trust. TIA looks forward to continued collaboration and appreciates Chairman Carr’s leadership as the Commission advances this important initiative.
Read TIA’s Comments on FCC’s Delete, Delete, Delete initiative
