Federal Communications Commission	DA 26-148

Before the
FEDERAL COMMUNICATIONS COMMISSION
WASHINGTON, D.C. 20554

In the Matter of
TUV Rheinland/CCIC (Ningbo) Co., Ltd.
Designation No. CN1237
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ET Docket No. 25-269
ORDER WITHDRAWING RECOGNITION 
AS AN ACCREDITED TEST LABORATORY

Adopted:  February 12, 2026	Released:  February 12, 2026

By the Chief, Office of Engineering and Technology:

I. INTRODUCTION
1. In this Order, the Office of Engineering and Technology (OET) withdraws the recognition of TUV Rheinland/CCIC (Ningbo) Co., Ltd. (TUV/Ningbo or Company) as an accredited test laboratory pursuant to section 302(e) of the Communications Act of 1934, as amended (the Act), and sections 2.951(d) of the Commission’s rules. 47 U.S.C. § 302a(e); 47 CFR § 2.951(d).
  
II. BACKGROUND
2. Legal Framework.  Section 302 of the Act authorizes the Federal Communications Commission (Commission or FCC) to adopt rules, consistent with the public interest, governing the interference potential of equipment capable of emitting radio frequency (RF) energy. 47 U.S.C. § 302a(a); see generally 47 CFR pt. 2 subpt. J (equipment authorization procedures).
  The Act also allows the Commission to authorize the use of private organizations (test labs) to test for compliance with those rules, and to establish appropriate qualifications and standards for such test labs. 47 U.S.C. § 302a(e)(1), (3); see 47 CFR §§ 2.948, 2.951.
  The Commission will not recognize any test lab that fails to meet all of the appropriate standards, including standards that concern the integrity and trustworthiness of the test lab.  The Commission’s rules, in part, “ensure that [test labs] that participate in [the FCC’s] equipment authorization program are not subject to ownership, direction, or control by untrustworthy actors that pose a risk to national security.” Promoting the Integrity and Security of Telecommunications Certification Bodies, Measurement Facilities, and the Equipment Authorization Program, Report and Order and Further Notice of Proposed Rulemaking, ET Docket No. 24-136, 40 FCC Rcd 3616, 3617, para. 1 (2025) (EA Integrity Order).

3. Section 2.951(d)(1) of the Commission’s rules provides that the Commission will withdraw its recognition of any laboratory that is owned by, controlled by, or subject to the direction of a prohibited entity, as defined by section 2.902 of the Commission’s rules. 47 CFR § 2.951(d)(1).
  Section 2.902 defines “owned by, controlled by, or subject to the direction of” to mean any entity:
(1) In which any other entity has direct or indirect ownership or control of 10% or more equity, voting interest, or stock;
(2) In which any other entity directly or indirectly possesses or has the power (whether or not exercised) to determine, direct, or decide important matters affecting the subject entity; or
(3) That acts as an agent or representative of another entity or acts in any other capacity at the order or request of another entity or whose activities are directly or indirectly supervised, directed, controlled, financed, or subsidized in whole or in majority part, including being part of a governmental structure or hierarchy. 47 CFR § 2.902.
 
Section 2.902 of the Commission’s rules defines “prohibited entities” to include entities identified as “foreign adversaries” by the U.S. Department of Commerce pursuant to 15 CFR § 791.4. Id.  Prohibited entities are further defined to include entities identified on the Covered List as well as entities identified by specified sources.  Id. 
  The U.S. Department of Commerce, based on numerous Executive Branch sources, has determined that the People’s Republic of China (PRC or China) is a foreign adversary. “The Secretary has determined that the following foreign governments or foreign non-government persons have engaged in a long-term pattern or serious instances of conduct significantly adverse to the national security of the United States or security and safety of United States persons and, therefore, constitute foreign adversaries solely for the purposes of the Executive Order, this rule, and any subsequent rule:  (1) The People’s Republic of China, including the Hong Kong Special Administrative Region and the Macau Special Administrative Region (China)….”  15 CFR § 791.4(a)(1); see also TUV Rheinland/CCIC (Ningbo) Co., Ltd., Designation No. CN1237, ET Docket No. 25-269, Notice of Intent to Begin Proceedings to Withdraw Recognition as an Accredited Test Laboratory, DA 25-796 (OET Sept. 8, 2025) (Notice).

4. Factual Background.  TUV/Ningbo is an accredited test laboratory based in Ningbo, Zhejiang, China that was last recognized by the FCC to test a wide range of RF devices for compliance with applicable FCC technical rules in March of 2025. TUV/Ningbo (FCC designation number CN1237) was last recognized by the FCC on March 28, 2025, with a recognition expiration date of June 30, 2026.  
  Since its initial accreditation, TUV/Ningbo has performed testing that contributed to hundreds of equipment certifications.  TUV/Ningbo is connected to the Chinese government through its partnership with the China Certification & Inspection Group Co., Ltd. (CCIC Group). China Certification & Inspection Group, Group Introduction, https://www.ccic.com/gywm/jtjj/index.html (last visited Sept. 4, 2025).  According to its website, the CCIC Group provides inspection, verification, certification, and testing services that are intended to ensure the quality, safety, and compliance of telecommunications equipment.  
  The CCIC Group is a state-owned enterprise, established with the approval of the State Council of the PRC and under the supervision of the State-owned Assets Supervision and Administration Commission of the State Council (SASAC). China Certification & Inspection Group, Group Introduction, https://www.ccic.com/gywm/jtjj/index.html (last
visited Sept. 4, 2025) (“China Inspection and Certification Group (referred to as China Inspection, English
abbreviation CCIC) is a central enterprise approved by the State Council and managed by the SASAC of the State
Council, and is a comprehensive quality service organization with ‘inspection, testing, certification, standards, and
measurement’ as the main industry, which was created in 1980.”); see also State-owned Assets Supervision and
Administration Commission of the State Council, About Us, http://en.sasac.gov.cn/sasacaboutus.html (last visited
Sept. 4, 2025).
  SASAC exercises comprehensive control and oversight over state-owned assets and enterprises, with its functions directly mandated by the Central committee of the Chinese Communist Party. State-owned Assets and Supervision and Administrative Commission of the State Council, About Us,
http://en.sasac.gov.cn/aboutus.html (last visited Sept. 4, 2025).
 
5. On September 8, 2025, OET provided TUV/Ningbo with notice of the Commission’s intent to commence proceedings concerning the potential withdrawal of recognition of TUV/Ningbo as an accredited test laboratory. See Notice.
  In the Notice, OET tentatively determined that the Company is owned by, controlled by, or subject to the direction of a prohibited entity. Id.
  Because the PRC controls the State Council and the SASAC, which in turn controls the CCIC Group, Id. at para. 7 (internal citations omitted).
 the Notice tentatively determined that the PRC directly or indirectly has the power (whether or not exercised) “to determine, direct, or decide important matters” that affect TUV/Ningbo.  OET also tentatively determined that TUV/Ningbo acts “at the order or request of another entity,” or is an entity “whose activities are directly or indirectly supervised, directed, controlled, financed, or subsidized in whole or in majority part, including being part of a governmental structure or hierarchy.” Id. at para. 7 (internal citations omitted); see also 47 CFR § 2.902.
  The Notice thus tentatively determined that TUV/Ningbo is owned by, controlled by, or subject to control by and at the direction of the PRC (a prohibited entity) and provided the Company with an opportunity to respond to the Notice by October 14, 2025. Id. at paras. 7-8; 47 CFR § 2.951(e) (“The Commission will notify a laboratory in writing of its intention to withdraw the laboratory’s recognition and provide at least 30 days for the lab to respond.”).

6. On October 11, 2025, TUV/Ningbo submitted its response to the Notice. TUV Rheinland/CCIC (Ningbo) Co., Ltd., Designation No. CN1237, ET Docket No. 25-269, TUV/Ningbo Response to Notice of Intent to Begin Proceeding to Withdraw Recognition as an Accredited Test Laboratory (filed Oct. 11, 2025) (Response).  The Instituting Order incorrectly stated that the Response was dated October 14, 2025.  See Instituting Order at para. 7.
  TUV/Ningbo opposed the Commission’s action, stating that:
[T]he requirements for withdrawal under Sect. 2[.]951 (d)(1) and (e) of the FCC Rules are not satisfied as the company controlling the accredited laboratory is TÜV Rheinland (China) Ltd. (“TR”) rather than China Certification & Inspection Group Co., Ltd. (“CCIC”). TR is a Chinese entity indirectly controlled by TÜV Rheinland AG, a company organized under the laws of and domiciled in the Federal Republic of Germany. In this respect, the Company is not under the control or direction of a prohibited entity in the sense of Sect. 2[.]902 of the FCC Rules. Id. at 1.
  

7. TUV/Ningbo also submitted an unofficial English-language translation of its Articles of Association.  According to the submitted document, CCIC was one of two shareholders in the Company, and CCIC’s capital contribution to establishing the Company “account[ed] for 49% of the registered capital[.]” Response, Articles of Association, TÜV Rheinland / CCIC (Ningbo) Co., Ltd. (English translation), Chapter V, at 2 (“Chapter V. Name of Shareholders and Method and Amount of Capital Contribution, Article 6”).
  The document also states that CCIC was required to appoint two of the five directors on the Company’s board, and required certain matters to be decided by a unanimous vote of the board. Id. at 5-7 (Articles 18 and 23).
  The document further states that the interpretation and dispute resolution of Articles of Association “shall be governed by the relevant laws and regulations of the People’s Republic of China.” Id. at 11 (Article 41).

8. On October 24, 2025, OET commenced a proceeding to withdraw recognition of TUV/Ningbo as an accredited test laboratory. TUV Rheinland/CCIC (Ningbo) Co., Ltd., Designation No. CN1237, ET Docket No. 25-269, Order Instituting Proceeding to Withdraw Recognition As An Accredited Test Laboratory, DA 25-931 (OET Oct. 24, 2025) (Order Instituting Proceeding).
  OET considered the Company’s Response, including the Company’s opposition to the proceeding and its assertion that it is not under the control or direction of a prohibited entity because of its corporate governance structure. See id. at para. 9.
  OET noted that TUV/Ningbo’s corporate governance document indicates that CCIC is a shareholder in the joint venture and contributed 49% of the founding capital, CCIC was required to appoint two of the five directors on the Company’s board, and that the document specifies certain matters that must be decided by a unanimous vote of the board of directors. Id. at para. 8 (internal citations omitted).
  Finally, OET indicated that the document states that interpretation and dispute resolution of the Articles of Association “shall be governed by the relevant laws and regulations of the People’s Republic of China.” Id.

9. OET concluded that TUV/Ningbo failed to demonstrate why the Commission should not begin a proceeding to withdraw recognition of the Company as an accredited test laboratory. Id. at para. 9.
  Accordingly, OET initiated a proceeding pursuant to section 302(e) of the Act and sections 2.951(d) and (e) of the Commission’s rules to reach a final determination on whether to withdraw recognition of TUV/Ningbo as an accredited test laboratory. Id. at para. 10.
  The Order Instituting Proceeding provided the Company an opportunity to file a response within thirty-five (35) days after the release of the order, permitting TUV/Ningbo an additional opportunity to demonstrate why the Commission should not withdraw its recognition. Id. at para. 11.
  
10. On November 25, 2025, TUV/Ningbo filed its response to the Order Instituting Proceeding. TUV Rheinland/CCIC (Ningbo) Co., Ltd.,, Designation No. CN1237, ET Docket No. 25-269, TUV/Ningbo Response to Order Instituting Proceeding to Withdraw Recognition As An Accredited Test Laboratory (filed Nov. 25, 2025) (Response to the Order Instituting Proceeding).
  TUV/Ningbo asserts that it maintains a long-standing and unblemished record of professional testing. Id. at 1.
  TUV/Ningbo acknowledges the Commission’s 10% ownership threshold under section 2.902 but argues that an exception is legally appropriate when the entity in question lacks the structural capacity to exercise actual control over business operations. Id. at 2.
  TUV/Ningbo counters that the Commission’s focus on unanimous voting requirements by clarifying that such provisions are standard corporate safeguards. Id.
  Finally, the TUV/Ningbo requests that the Commission disclose any specific national security risks that remain so they may be addressed. Id. at 3.

III.	DISCUSSION  
11. Based on the information in the record, including TUV/Ningbo’s Response to the Order Instituting Proceeding, OET concludes that TUV/Ningbo has failed to demonstrate why the Commission should not withdraw recognition of TUV/Ningbo as an accredited test laboratory pursuant to section 2.951(d)(1) of the Commission’s rules. 47 CFR § 2.951(d)(1).
  
12. Section 2.951(d)(1) of the Commission’s rules provides that the Commission will withdraw its recognition of any laboratory that is owned by, controlled by, or subject to the direction of a prohibited entity pursuant to section 2.902 of the Commission’s rules. Id.
  The Order Instituting Proceeding directed TUV/Ningbo to provide a reasonable basis for why the Commission should not withdraw its recognition. Order Instituting Proceeding at para. 10.
  The Order Instituting Proceeding recognized TUV/Ningbo’s acknowledgment that the CCIC Group, a Chinese state-owned enterprise, is a shareholder in the joint venture, contributed 49% of the founding capital, appoints two of the five directors, and that some corporate matters require a unanimous vote of the board. Id. at para. 8-9.
  These facts were reaffirmed in TUV/Ningbo’s corporate governance document, which the Company provided in its Response to the Notice. Response, Articles of Association, TÜV Rheinland / CCIC (Ningbo) Co., Ltd. (English translation), Chapter V, at 2 (“Chapter V. Name of Shareholders and Method and Amount of Capital Contribution, Article 6”), Chapter VIII, at 5-7 (“Chapter VIII. Organizations, Method of Formation, Authorities and Rules of Procedures, Articles 18 and 23”).
  This document also contained a choice of law provision that specifies the laws and regulations of the PRC govern its establishment, validity, interpretation, performance, and settlement of disputes. Response, Articles of Association, TÜV Rheinland / CCIC (Ningbo) Co., Ltd. (English translation), Chapter XI, at 11 (Chapter XI. Miscellaneous, Article 41).
  The U.S. Department of Commerce has designated the PRC as a foreign adversary of the United States, 15 CFR § 791.4.
 and section 2.902 of the Commission’s rules provides that entities designated as foreign adversaries in this manner are considered “prohibited entities.” 47 CFR § 2.902.
  TUV/Ningbo, thus, “is owned by, controlled by, or subject to the direction of a prohibited entity.” 47 CFR § 2.951(d)(1).
  The Commission’s rules explicitly state that it will not recognize, and will withdraw recognition of, any laboratory that is owned by, or subject to the direction of a prohibited entity. 47 CFR § 2.951(b), (d). 
  
13. TUV/Ningbo’s Response to the Order Instituting Proceeding concedes the factual predicate for withdrawal of recognition but argues that the laboratory is effectively controlled by TR, an entity whose indirect corporate parent is the German-domiciled TUV Rheinland AG, and that the Chinese state-owned CCIC Group lacks any actual power to direct business operations. Response at 1.
  TUV/Ningbo acknowledges the FCC’s presumption of ownership at a 10% threshold but requests that the Commission grant TUV/Ningbo an exception “where a party deemed a foreign adversary does not and cannot exercise any actual control over the targeted company.” Response to the Order Instituting Proceeding at 2; Response, Articles of Association, TÜV Rheinland / CCIC (Ningbo) Co., Ltd. (English translation), Chapter V, at 2 (“Chapter V. Name of Shareholders and Method and Amount of Capital Contribution, Article 6”), Chapter VIII, at 5-7 (“Chapter VIII. Organizations, Method of Formation, Authorities and Rules of Procedures, Articles 18 and 23”).
  However, in the EA Integrity Order, the Commission already considered the policy issues at stake and determined that “it is critical for national security and the integrity of the supply chain that we prohibit from recognition or participation in the equipment authorization program of TCBs, test labs, or laboratory accreditation bodies that are owned by, controlled by, or subject to the direction of a prohibited entity.” EA Integrity Order at 3617, para. 1.
  While TUV/Ningbo argues that TR maintains majority control, Response at 1.
 the Commission’s standard set forth by section 2.902 prohibits ownership of 10% or more. 47 CFR § 2.902.
  
14. Even aside from the specific size of CCIC’s ownership interest, the Commission’s rules also captures entities that are "subject to the direction" of a prohibited entity and therefore cover TUV/Ningbo based on TUV/Ningbo’s own submissions. Id.  See generally Response, Articles of Association, TÜV Rheinland / CCIC (Ningbo) Co., Ltd. (English translation).
  Based on TUV/Ningbo’s corporate governance document, CCIC Group holds significant control by exclusively appointing the Vice-Chairman of the Board, two out of five directors, and one of two Vice-General Managers. Response, Articles of Association, TÜV Rheinland / CCIC (Ningbo) Co., Ltd. (English translation), Chapter V, at 2 (“Chapter V. Name of Shareholders and Method and Amount of Capital Contribution, Article 6”), Chapter VIII, at 5-7,  (“Chapter VIII. Organizations, Method of Formation, Authorities and Rules of Procedures, Articles 18, 23, and 25”).
  Through these appointments, CCIC Group is positioned to exert direction over core operational plans, investments, and management systems. Id.
  Furthermore, specific resolutions regarding the scope of management authority and amendments to the corporate governance document require unanimous consent, granting CCIC Group substantial influence over the Company's strategic direction. Id.
  In particular, we note that the Company’s Articles of Association require unanimous consent in connection with the “establishment of the internal management organizations of the Company” and any “determination of the authorities of the general manager and vice general manager of the Company.” Id. at 6.
  By addressing internal structure and managers’ scope of duties, the unanimity requirements provide CCIC further mechanisms to control the Company’s operations. We also note that the text of Article 23 is difficult to reconcile with the Company’s arguments in the Response to Order Initiating Proceeding, in which the Company represents to the Commission that unanimity of the board is limited to “cases which are absolutely exceptional in nature, including such matters as filing insolvency or dissolving the company” and that those requirements are “commonplace in any corporate venture agreement.”  Response to Order Initiating Proceeding at 2; see also Response, Articles of Association, TÜV Rheinland / CCIC (Ningbo) Co., Ltd. (English translation), Chapter VIII, at 6-7, (“Chapter VIII. Organizations, Method of Formation, Authorities and Rules of Procedures, Article 23”). 
  We therefore reject the Company’s arguments why OET should not withdraw its recognition of TUV/Ningbo as an accredited test laboratory.
15. After fully considering TUV/Ningbo’s arguments in its Response to the Order Instituting Proceeding, and pursuant to section 302(e) of the Act and section 2.951(d) of the Commission’s rules, OET hereby withdraws recognition of TUV/Ningbo as an accredited test laboratory. 47 U.S.C. § 302a(e); 47 CFR § 2.951(d).
  This action becomes effective immediately upon release of this Order.  The Commission will no longer recognize within its equipment authorization program test data or measurements that are performed after this date by the Company.
IV. ORDERING CLAUSES
16. Accordingly, IT IS ORDERED that, pursuant to section 302(e) of the Act, 47 U.S.C. § 302a(e), and sections 0.31, 0.241, and 2.951(d) of the Commission’s rules, 47 CFR §§ 0.31, 0.241, 2.951(d), the Commission HEREBY WITHDRAWS ITS RECOGNITION of TUV Rheinland/CCIC (Ningbo) Co., Ltd., Designation No. CN1237 as an accredited test laboratory.
17. IT IS FURTHER ORDERED that a copy of this Order shall be sent by e-mail to Thorsten.Keiter@tuv.com on the release date of this Order and a copy sent by regular first-class mail and certified mail, return receipt requested, to Thorsten Keiter, TÜV Rheinland / CCIC (Ningbo) Co. Ltd., Building C13 R&D Park No. 32 Lane 299 Guanghua Road National Hi-Tech Zone, Ningbo, China.

FEDERAL COMMUNICATIONS COMMISSION
						
						
						
						
Andrew C. Hendrickson
Chief 
Office of Engineering and Technology
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