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FCC Agent for Service of Process vs. Proposed "Liable Party"

An agent for service of process only accepts legal papers and FCC correspondence and forwards them. In its Third Further Notice of Proposed Rulemaking (FCC 26-50, 91 FR 51139, August 7, 2026), the FCC proposed that every certification grantee have a U.S.-based liable party. That is a proposal, not a rule. US Agent Desk does not offer the liable-party role.

What the proposal says

  • Amend 47 CFR 2.909 so each grantee has a U.S.-based party responsible for compliance: the manufacturer or assembler, otherwise the importer, otherwise a retailer by agreement
  • The FCC stated the agent requirement has "proven insufficient" for enforcement
  • Comments closed September 8, 2026 and replies September 21, 2026. No final rule has been adopted on this point

Our position

  • We act only as agent for service of process: accept, log, translate and forward within 1 business day
  • We are not your importer, distributor, responsible party or liable party, and we will not take that role
  • If a liable party is required, it should be your U.S. importer or distributor. Ask your attorney

Related: FDA renewal deadline calendar · Do I need a U.S. Agent? · US Agent Desk pricing

Sources

General information, not legal advice. Last reviewed October 21, 2026.