- United States
- N.J.
- Letter
I am writing to express my concern regarding the Federal Communications Commission’s recent decision to restrict approval of foreign-made consumer Wi-Fi routers.
While I understand the importance of protecting U.S. networks from cybersecurity threats, this policy raises serious legal, economic, and practical concerns.
First, the rule appears to exceed the FCC’s statutory authority. The requirement that manufacturers disclose supply chains and develop plans for domestic production suggests that this policy is not purely about communications security, but instead functions as industrial policy. Courts have increasingly scrutinized such actions under the “major questions doctrine,” requiring clear congressional authorization for sweeping economic regulations.
Second, the rule may be arbitrary and ineffective. It applies only to new router models, while millions of existing foreign-made routers—potentially containing the same vulnerabilities—remain in use across the country. Experts have noted that this inconsistency undermines the stated goal of improving cybersecurity and suggests the policy may not withstand review under the Administrative Procedure Act.
Third, the policy will likely disrupt the consumer market. The vast majority of routers sold in the United States are manufactured overseas, including those from American companies. Restricting future imports could reduce competition, increase prices, and limit consumer choice without delivering meaningful security benefits.
Finally, the rule appears difficult to enforce in practice. Existing devices remain legal, and supply chain realities make rapid domestic production unrealistic. As a result, the policy risks imposing economic costs without achieving its intended outcomes.
For these reasons, I urge you to:
Support congressional oversight of this FCC action
Clarify the limits of the FCC’s authority in this area
Consider legislative measures to overturn or revise this rule
Promote alternative cybersecurity solutions, such as stronger device standards and update requirements
Protecting national security is essential, but it must be done in a way that is lawful, targeted, and effective.
Thank you for your time and consideration.