The effective date also triggers compliance deadlines for the enhanced benchmarks. Manufacturers and service providers that offer six or more handset models per air interface will be required to abide by the following:
The new de minimis exception, applying to manufacturers and service providers that offer three or fewer handset models in an air interface, will take effect for each covered entity at the same time as the updated benchmarks (i.e, for non-tier 1 service providers, April 3, 2020). For enforcement purposes, the FCC will review compliance with the new benchmarks and de minimis requirements starting the first day of the month after the new benchmarks become effective.
Please contact us if you have any questions on your HAC obligations under the new rules.