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FCC Latest News | Update on Model Variant Data Reference Rules

Author.

LCS

Source:

Post time:

2026-03-09

On January 28, 2026, the Federal Communications Commission (FCC) released guidelines for the Telecommunications Compliance Board (TCBC) meeting, introducing significant additions to the data citation rules for equipment certification! Key points are highlighted below 👇

 

Luxshare Testing extracts the core points and provides response suggestions for you:

 

1. Function-enhanced variant

 

Software/debugging changes: Enabling a new frequency band solely through software can often leverage existing data, requiring only testing of the newly added components.

 

Hardware "embedded" change: To achieve the intended function, new transmitting components are added to the existing PCB layout. It may only require testing for the newly added frequency bands, while data from other frequency bands can be referenced.

 

2. Component replacement

 

Replacing components to enable different frequency bands will no longer automatically qualify for model variants. The new regulations emphasize:

 

Additional technical justification must be provided to demonstrate that the change has not altered the electromagnetic emission characteristics.

Suggested solution: Conduct a specialized comparative test to demonstrate the RF equivalence between the new component and the original component through data, and include the complete report in the data reference plan for submission to the TCB for approval.

 

3. Add a new "Customized Testing" path

 

When component manufacturers fail to provide sufficient support, applicants can independently develop testing hardware and methods for preliminary equivalence verification. This independent testing is a crucial prerequisite for referencing application data.

 

4. Pay attention to the opportunity for changes related to "circuits not in use within the United States"

 

Variants may be permitted if the changes are only made to circuit parts of the device that cannot be activated in the United States (such as specific country frequency bands), and technical analysis can prove that they do not affect the authorized emission characteristics. This provides flexibility for the localization adaptation of globalized devices.

 

5. PCB layout

 

Modifications should be made cautiously to ensure they do not affect the physical field distribution of authorized antennas. Simple replacement of patch components usually carries lower risks, but avoid adding large or towering components near critical antennas to prevent accidental changes to the radio frequency exposure (TER) characteristics.

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