The FCC Wants to Retire Its 2002 Ultra-Wideband Rules. The New Device Category Has No Rule Text Yet.

“UWB devices may not be employed for the operation of toys.” That sentence has been in 47 CFR 15.521(a) since 2002 [6]. It is printed in the grant notes of many equipment certifications [1]. And in 24 years nobody wrote down what a toy is.

The FCC now admits the word “is not defined in the rules,” and that the gap “may create uncertainty for manufacturers” [1]. That admission sits inside the proposal it published in the Federal Register on Monday, a rewrite of the ultra-wideband rules that governs the radios behind phone item finders, car key fobs and smart locks [3, 4]. Comments are due December 2 [1].

What the FCC proposed, and what it only asked about

The notice, FCC 26-66 in ET Docket No. 26-245, was adopted September 30 and released October 1 [1]. It answers two petitions: one Robert Bosch LLC filed on June 18, 2019, and one filed December 18, 2025, by the Alliance for Automotive Innovation, the Car Connectivity Consortium, the FiRa Consortium, Profibus & Profinet International/omlox and the Ultra-Wideband Alliance [1]. Bosch’s petition said “[v]irtually all UWB devices” approved for sale had needed individual waivers [2].

The useful way to read this document is to split what has proposed rule text from what is still a question. The appendix amends a short list of sections [1]:

• The definition. Section 15.503(d) loses “at any point in time,” so a device that hits 500 MHz of bandwidth while stepping, sweeping or hopping, but not in every instant, still counts as UWB. The FCC calls this “essentially codifying the numerous granted waivers” [1].
• Measurement. Section 15.31(c), which makes swept devices stop their sweep for testing, would no longer apply to UWB, and pulse-gated devices could be measured in normal operating mode [1]. The FCC says it meant to codify this after a 2005 waiver and never did [1].
• Coordination. Section 15.525, which makes imaging-system operators file written notice with the FCC for review with NTIA, would be removed. The FCC says it is not aware of any case where that notice “has been used to respond to an interference concern” [1].
• Scope of use. Proposed 15.521(a) would read: “Operation onboard an aircraft, a ship not within inland waters, or a satellite is prohibited” [1]. The toy sentence is gone.

Most of the rest is a question: eligibility limits for imaging systems, labeling, the ten-second shutoff switch, emission limits, ground-penetrating radar, drone landing systems, and aircraft and satellites [1]. The FCC says it is not proposing any change to GPS protection [1].

The new device category sits in between. The FCC says it “proposes” one, and the preamble describes it in some detail: compact devices, fixed or mobile, indoors or outdoors, with height and mounting limits, emissions aimed downward, transmission only “during active, event-driven communication sessions,” no wide-area networks, and duty cycles under 1 percent in any 24-hour period [1]. The worked example is a door lock used up to ten times a day, each ranging round lasting 660 microseconds [1]. None of that is in the proposed amendments [1]. Neither is a definition for the separate AI-enabled sensing class the FCC floats [1].

Why the waiver line matters to hardware teams

Today, the waivers for UWB locks and anchors are waivers of 15.519, the hand-held rule [2]. That rule requires devices to be “hand held,” bars “any fixed outdoors infrastructure,” and allows antennas only on the device [5]. A door lock is not hand held. So lock makers have gone the waiver route. The full notice cites waiver orders for Assa Abloy in 2022, Schlage in 2023 and Piper Networks in 2020 [2]. Chairman Brendan Carr said “multiple providers had to wait an average of six months” for approval of door-unlocking products [3].

Those waiver orders are worth reading now, because they show what the category will probably look like. The Assa Abloy grant required that UWB sessions start only after discovery and credential checks over 2.4 GHz Bluetooth [2]. The Schlage grant was for a lock mounted no more than 48 inches off the ground [2]. The preamble’s “event-driven” sessions and mounting limits read like those conditions turned into a rule [1, 2]. If your firmware already wakes the UWB radio only after a Bluetooth handshake, you’re probably building to the eventual spec. If your product ranges continuously, look hard at the 1 percent number and at the FCC’s question about whether duty cycle should be measured over 24 hours, an hour or a minute [1]. A 24-hour window and a per-minute window are very different products.

This part is opinion. I like that the FCC is turning a stack of repeat waivers into rules. When I wrote about the CBRS sensor waivers last month, my complaint was that the fix for a known, recurring problem lived in filings drafted one at a time. A waiver regime mostly helps companies that can afford to wait six months. But a category that exists only as preamble prose doesn’t help anyone file a certification. The FCC’s own footnote says it is “not proposing to make any changes to our waiver process” [2]. Hogan Lovells Cadwalader’s alert says noncompliant products should keep pursuing case-by-case waivers and treat that strategy as a design-stage decision [7]. I’d take that advice. Whatever the category ends up saying, it has to go through comments, a further vote and, presumably, rule text that nobody has seen.

The cost math is also thin. The FCC’s savings estimate assumes about five waivers a year and comes to roughly $44,000 a year in staff review and $27,000 for industry [1]. The FCC calls that “conservatively low” [1]. I’d agree. The cost of a waiver regime is the product that ships six months late, and that isn’t in the number.

Who might push back

GPS and aviation users. When Bosch filed in 2019, the GPS Innovation Alliance and Aviation Spectrum Resources asked for more time to answer it, and the FCC said no, according to Inside GNSS [8]. The 2002 rules were conservative partly because of worry about UWB and GPS [8]. The 2026 notice keeps a door open for that side. It asks for coexistence studies “explicitly showing” no added harm to federal systems, asks whether narrower instantaneous bandwidths could concentrate power, and notes that NTIA’s research arm plans to test UWB against federal systems in the 7 GHz band [1, 2]. Carr says there has “never been a complaint against UWB operations for harmful interference” [3]. My own caution: that record was built under a cautious rulebook, and a looser one is a different experiment.

One more thing for anyone pairing UWB with autonomy. The notice says equipment “will continue to be examined” for national security, and that the FCC will act so that “UWB systems integrated with AI technologies are aligned with the national security interest” [1]. That’s the same posture behind the FCC’s component ban from July. Both Carr and Commissioner Olivia Trusty pitched the new category as a home for devices that use “super intelligence” [3, 4]. Nobody defines that term, and I’d bet it never appears in a rule.

What I’m watching

• December 2 and January 4. Comments and replies in ET Docket No. 26-245 [1]. I want to see whether the automotive and FiRa petitioners file actual rule text for the new category, and whether GPS and aviation groups ask for one.
• The NTIA 7 GHz testing. Whether the Institute for Telecommunication Sciences publishes its results before the FCC writes final limits [2].
• The grant notes. The FCC asks whether companies would have to request removal of the toy notes from existing certifications, or whether an administrative rule could do it [1].