ALA Files FCC Comments

Federal Communications Commission

Protecting Against National Security Threats to the Communications Supply Chain Through the Equipment Authorization Program 
47 CFR Part 2, [ET Docket No. 21-232; FCC 25-71; FR ID 318981] 

Comments Submitted by Jon Melchi, President & CEO, American Lighting Association

The American Lighting Association (ALA) supports the Federal Communications Commission’s objective of protecting US communications networks and consumers from risks posed by insecure equipment. ALA agrees that the equipment authorization framework can and should address legitimate national security threats. At the same time, ALA respectfully urges the Commission to ensure that any new requirements adopted are clearly defined, narrowly tailored, and feasible for manufacturers to implement. Clear and specific rules will facilitate compliance by responsible companies, while ambiguity or over-broad obligations risk imposing unintended burdens without commensurate security benefits. 

ALA encourages the Commission to focus on measures that deliver demonstrable security value proportionate to their costs, and to avoid regulatory approaches that could unnecessarily hinder innovation or market participation in low-risk product categories. 

I. Low-Risk Profile of Residential Lighting Products 

ALA respectfully requests that the Commission recognize the unique characteristics and inherently low-risk profile of residential and decorative lighting products, smart lighting controls, and ceiling fans. These devices differ fundamentally from core telecommunications infrastructure. They generally operate at the network edge and have limited data-handling capabilities and access privileges. Unlike routers, modems, or security cameras, a smart light bulb or ceiling fan functions as an endpoint device with minimal capacity to compromise network integrity. 

To date, there is no evidence that lighting or fan products have served as vectors for espionage or serious cybersecurity threats. ALA appreciates the Further Notice of Proposed Rulemaking’s refined definition of “critical infrastructure,” which appropriately excludes general-purpose consumer devices. We encourage the Commission to continue tailoring its approach so that compliance obligations imposed on low-risk devices are proportionate to the actual threat level, ensuring that regulatory attention is focused where risks are greatest. 

II. Need for Component-Level Clarity and Guidance 

ALA requests clear and practical guidance on how manufacturers are expected to identify and avoid restricted components under any new rules. Manufacturers, particularly small and mid-sized firms, will need to determine whether specific semiconductors, modules, or software elements are prohibited. To facilitate compliance, the Commission should consider publishing and maintaining a list of specific chipsets, component models, or categories that are considered “covered” or otherwise restricted, or coordinating with other federal agencies to make such resources available. 

Additionally, further guidance regarding what constitutes a component that is controlled by a “foreign adversary” would help manufacturers avoid problematic sourcing decisions. A “trusted components” program or centralized database could significantly improve compliance across the industry. ALA also seeks clarity regarding supply chain responsibilities, including the respective due diligence obligations of US importers, distributors, and device manufacturers. Many small, locally owned lighting companies do not maintain extensive compliance departments, and plain-language explanations of expectations and compliance steps would greatly enhance the industry’s ability to meet the Commission’s objectives. 

III. Transition Periods and Minimizing Disruption, Particularly for Small and Mid-Sized Enterprises 

ALA urges the Commission to adopt reasonable transition periods and compliance mechanisms that minimize disruption, particularly for the small and mid-sized manufacturers that comprise a significant portion of the lighting industry. If new component restrictions are adopted, companies will require sufficient time to redesign products, qualify alternative suppliers, and manage existing inventory. 

The FNPRM appropriately seeks comment on transition timelines, including periods of 6, 12, or 18 months. ALA recommends a phased implementation period of no less than 18 months following adoption of final rules for any requirements that necessitate component changes. Such lead time is critical to prevent stranded inventory, reduce economic hardship, and maintain continuity of supply for consumers. ALA also encourages the Commission to consider grandfathering provisions or grace periods for products already in commerce or substantially developed, provided they do not present immediate security risks. 

In addition to transition timing, ALA welcomes compliance assistance initiatives, such as FCC-hosted workshops, guidance documents, or frequently asked questions, to ensure that manufacturers without dedicated regulatory staff can understand and meet new obligations. 

IV. Balanced Enforcement and Focus on High-Risk Actors 

ALA encourages the Commission to pursue a balanced, risk-based approach to enforcement. We support the Commission’s emphasis on holding domestic importers and distributors accountable, as this can help prevent noncompliant products from entering the US market. At the same time, enforcement should distinguish between willful or egregious violations and inadvertent, good-faith errors. 

Where a manufacturer unknowingly incorporates a component that is later identified as restricted, the Commission should consider allowing opportunities for remediation before imposing penalties, particularly where the company promptly cooperates. Enforcement efforts should prioritize actors that deliberately evade the rules or are aligned with adversarial interests, rather than broadly penalizing good-faith manufacturers. Clear rules and guidance will enable ALA members to comply fully and consistently. 

Conclusion 

ALA stands ready to work collaboratively with the Commission to implement effective supply chain safeguards that enhance national security. We share the Commission’s goal of securing communications technologies and believe that this goal can be achieved in a manner that also supports the lighting industry’s ability to deliver safe, innovative, and energy-efficient products to American consumers. The ALA respectfully submits these comments to assist the Commission in refining the proposed rules to maximize security benefits while minimizing unintended impacts on our sector.