VoIP and Other Communications Providers That Bundle Routers with Their Services Should Review Future Equipment Deployments
The Federal Communications Commission (“FCC” or “Commission”) continues to implement its Consumer Router Security Program through Public Notices granting Conditional Approval for certain foreign-manufactured consumer-grade routers. In its latest Public Notice, the FCC granted additional Conditional Approvals covering specified manufacturers and router models.
As discussed in a prior CommLaw Group Client Advisory, the Conditional Approval process permits certain new consumer-router models to obtain FCC equipment authorization notwithstanding restrictions associated with the Commission’s Covered List. These approvals are product-specific and remain subject to the conditions, limitations, and expiration dates established by the FCC.
Although the Commission’s Public Notices are directed principally toward router manufacturers, importers, and equipment-authorization applicants, they also have practical implications for Voice over Internet Protocol (“VoIP”) providers and other communications service providers that furnish routers or related networking equipment to their customers.
Why This Matters to VoIP Providers
Many VoIP and managed communications providers bundle customer-premises equipment with services such as:
- Hosted PBX and Unified Communications as a Service (“UCaaS”);
- SIP trunking;
- Managed voice and network services;
- Broadband and voice bundles; and
- Managed routers, gateways, firewalls, and Wi-Fi access devices.
Providers that sell, lease, install, or otherwise furnish routers as part of a service offering should therefore understand whether the equipment they purchase and deploy is affected by the FCC’s Covered List restrictions or Conditional Approval requirements.
The Commission’s current policy is focused primarily on new router models seeking FCC equipment authorization. The Public Notices do not generally require service providers to remove or replace routers that were lawfully authorized and deployed before the applicable restrictions took effect.
Accordingly, providers should focus their compliance reviews on:
- Future equipment purchases;
- Newly introduced router models;
- Changes in equipment manufacturers or distributors;
- Customer equipment refreshes; and
- Planned network upgrades or replacements.
Recommended Compliance Steps
VoIP and other communications providers that furnish routers to customers should consider taking the following steps:
- Inventory Current Equipment. Identify the router and gateway models currently sold, leased, installed, or managed for customers.
- Review Planned Deployments. Identify new models expected to be purchased or introduced as part of future deployments, upgrades, or equipment-refresh programs.
- Confirm Supplier Status. Ask manufacturers and distributors whether the equipment is affected by the FCC’s Covered List restrictions.
- Verify Model-Specific Approval. When purchasing equipment from a manufacturer implicated by the Covered List, confirm that the specific router model—not merely the manufacturer generally—has received any required FCC Conditional Approval.
- Retain Supporting Documentation. Maintain supplier certifications, FCC authorization records, Conditional Approval documentation, and related correspondence supporting the compliance status of newly deployed equipment.
While equipment manufacturers and importers are generally responsible for obtaining FCC equipment authorization, service providers should not assume that every product offered by a supplier is eligible for lawful marketing or deployment in the United States.
A reasonable supplier-verification process can help reduce the risk of equipment shortages, delayed deployments, supply-chain disruptions, or the need to substitute equipment during a customer rollout or network upgrade.
What Providers Should Do Now
The FCC is continuing to implement national-security restrictions affecting consumer routers and other communications equipment. Providers that incorporate routers into their service offerings should coordinate with their manufacturers, distributors, and equipment vendors before introducing new models into their networks or customer deployments.
At a minimum, providers should confirm that each newly purchased router model:
- Is not subject to the FCC’s Covered List restrictions;
- Remains eligible for FCC equipment authorization; or
- Has received any product-specific Conditional Approval required by the Commission.
Providers should also consider incorporating FCC equipment-compliance representations, documentation requirements, and notification obligations into their supplier and distributor agreements.
NEED ASSISTANCE WITH FCC EQUIPMENT COMPLIANCE?
The CommLaw Group Can Help
The FCC’s equipment-authorization requirements continue to evolve as the Commission implements new national-security initiatives affecting consumer routers and other communications equipment.
Companies that manufacture, import, market, distribute, purchase, or deploy communications equipment should periodically review their equipment-compliance procedures, supplier relationships, and supporting records.
The CommLaw Group advises communications service providers, equipment manufacturers, importers, distributors, and other industry participants regarding:
- FCC equipment-authorization requirements;
- Covered List restrictions;
- Conditional Approval requirements;
- Equipment marketing and importation rules;
- Radiofrequency-emissions compliance;
- Supplier and distributor compliance procedures; and
- FCC investigations and enforcement matters.
CONTACT US TO DISCUSS YOUR FCC COMPLIANCE OBLIGATIONS
Jonathan S. Marashlian
Tel: (703) 714-1313
E-mail: jsm@CommLawGroup.com
Ronald E. Quirk
Tel: (202) 299-7732
E-mail: req@CommLawGroup.com