E-Labeling Deserves Serious Consideration

Wireless devices have changed substantially over the last two decades.  Consumers have migrated from block-like flip-phones with monochromatic screens to advanced, all-in-one smartphones,[1] tablets, and even wrist devices.  As these devices continue to shrink, their functionality continues to grow.  To keep pace with these technological advancements, I believe it is time for the FCC to consider modernizing our labeling requirements.  Electronic labeling, or e-labeling, could replace the current system of etched labels containing FCC certification information on the outside body of each electronic device.  Instead, this information could be provided through software on device screens. 

There are numerous potential benefits to e-labeling.  Specifically, e-labels can provide more information to consumers than is conveyed today.  Beyond the required FCC certification information, details can be added by manufacturers regarding device warranties, recycling, and trade-in opportunities.  In addition, e-labels can be updated remotely to address any inaccuracies, such as typographical errors. 

Another advantage of e-labeling is cost savings.  As devices have become smaller and more aesthetically appealing, etching the labels requires more design time and expensive equipment.  E-labeling could dramatically reduce or eliminate these costs without sacrificing consumer information.  The Commission has already permitted e-labeling for a small subset of devices.  In 2001, the Commission’s rules authorizing software defined radios (SDR) permitted the voluntary use of e-labeling by device manufacturers.       

Along with the proposed benefits, there may be some perceived drawbacks to e-labeling that can be addressed.  For example, some may argue that e-labels would be unavailable if devices could not be turned on for whatever reason (e.g., new, broken, or lost power).  To mitigate this concern, manufacturers could put peel-away screen labels with the appropriate labeling information on newly deployed devices.  In addition, certification information could continue to be included in the owner’s manual and could also be prominently displayed on manufacturers’ websites.  

E-labeling should never be allowed in any way to short-circuit or undermine the FCC's certification process.  For the time being, FCC certification remains a critical process to confirm compliance with FCC rules, to prevent harmful interference, and to transmit important information about wireless devices to consumers.  This is an issue the Commission should examine closely and guard against, but I do not see that e-labeling would necessarily undermine compliance with FCC rules. 

The FCC should take every opportunity to ensure that its rules and procedures take advantage of modern technology and are as user-friendly as possible.  That is why I hope that the Commission will, in the near future, turn its attention to the possibility of permitting e-labeling through a means that will expedite its use.  Doing so would not only be good government, it would stand to benefit equipment manufacturers, and more importantly, consumers.