STATEMENT OF 
COMMISSIONER MICHAEL O’RIELLY
Re: Amendment of Parts 0, 1, 2, 15 and 18 of the Commission’s Rules regarding Authorization of 
Radiofrequency Equipment; Request for the Allowance of Optional Electronic Labeling for 
Wireless Devices, ET Docket No. 15-170, RM-11673  
While this item contains many components, I wish to focus on just a few.  
A major function of this proceeding is the implementation of the E-LABEL Act, which Congress 
enacted to facilitate the optional use of electronic labels, instead of physical ones, on radiofrequency 
devices.  Having spent a considerable amount of time on this particular issue, including working with its 
lead proponent, the Telecommunications Industry Association, I am pleased to see proposals to update 
rules to meet the real world needs of electronic device manufacturers.  Without sacrificing important 
functions of our equipment authorization process, e-labels can provide a mechanism to facilitate device 
shipping, design, and ascetics, and reduce costs.  Much credit for the E-LABEL Act is due to Senator Deb 
Fischer, Former Senator Rockefeller, and Representatives Latta, Eshoo, Blackburn, and Welch.  
In addition, the item also proposes rule modifications for radiofrequency-producing modular 
components.  While some claim modular devices may become the next big thing and others argue they
will ultimately fail in the laboratory, it is important for the Commission to be ahead of the process.  In 
reality, modularity already exists in some electronic devices, such as desktop and laptop computers.  But, 
this item sets the stage to prevent our rules from becoming a hindrance to innovation and creativity, while 
at the same time maintaining our ability to prevent harmful interference from radiofrequency emitting 
devices.  I look forward to reviewing the comments received in this proceeding and engaging with 
stakeholders on ways to further fine tune our equipment authorization process.
I thank the staff of the Office of Engineering and Technology for working with me on a couple of 
technical issues involving the item and for their overall hard work.