In our filing, we highlighted several key points:
🟢 Modern communications and computing equipment rely on complex, multi-tiered supply chains. Broad or ambiguous rules risk excluding trusted products and exposing equipment-authorization applicants to liability for information they cannot independently verify.
🟢 Congress established a defined process for addressing supply chain risks: designated national security sources make the determinations supporting Covered List entries while directing the Commission to implement, not expand, these determinations, through the equipment authorization process.
🟢 The Commission’s definition of “produced by” should remain closely tied to the underlying national security determination and should not extend the Covered List prohibition beyond the scope of that determination.
🟢 Section 302(a) of the Communications Act authorizes rules addressing the interference potential of radiofrequency devices. That authority can support software requirements tied to RF compliance, but it does not, by its terms, create general authority to regulate the provenance of every component incorporated into a device.