[MarcoPerazaFCC]

Re: the licensing issue, companies wanting to put a label on their product would probably want to extract similar guarantees up their supply chain. Especially with a voluntary program like the one the FCC is proposing, good practices won't become the norm across the market overnight. But maybe, at the very least, the segment of product and component makers that take security seriously will begin to grow. I encourage you to share your thoughts in an official comment.

[structural]

As someone who designs IoT devices like these for a living, the device manufacturers here are in many cases the smallest companies in the supply chain and have very little ability to influence things upstream of them, especially for specialty products or companies entering a new market. It's often a major win to get a chipmaker to pick up the phone and sell us their product, much less receive any support at all.

I wish I could put a label like this on all of my products and I've been wishing for this for over twenty years, but the reality on the ground is that our support ends when the support for the individual parts in our product ends. We've looked at our supply chain periodically to see if we can replace parts with better documented/supported comparable parts, but frequently there just really aren't any better options.

This is a great idea in concept, but I fear that the flaw in the FCC's proposed rulemaking is that only indirectly addresses the root cause (the software, documentation, and support/updates provided by chipmakers for their parts). Furthermore, by focusing on device manufacturers who are the weaker partners in the chain, the regulation is likely to punish smaller, more innovative manufacturers.

[happymellon]

If it was forward looking, rather than retroactive then it would at least mean that chip manufacturers wouldn't be able to sell their undocumented/unsupported crap because all the buyers have to have it?

If there are no buyers then their attitude should change.

[structural]

This is incorrect, because you're assuming that all the buyers have to have it, when the chip manufacturer is selling into many industries/markets.

Since the specific "IoT device for the USA market" set of buyers is actually a small percentage of sales for most of the parts they sell, they really don't care to support their product from the IoT security perspective. This support is expensive, so it would very likely be cheaper for them to ignore the market completely.

[sumtechguy]

> This support is expensive

Most of IoT is that way. We had sales cycles that were 2-3 years long and they would in the end buy 300 units. I then go back to my suppliers and say 'hey support these 500 ic's that you sold me for 10 years from right now' They would laugh me out of the room unless I am showing up with big bags of cash. That instantly makes the whole project unviable to sell/support.

[structural]

Yes, absolutely. This is the exact conditions of most of our higher-end products (500-1000 units sold of a particular configuration is common). It's funny to get laughed out of the room even asking some chipmakers "can you sell us 1000 parts, please?"

[sumtechguy]

It is tough to explain to people that 1000 is not even alot for some of these guys. 1000 parts at say a fun price of 20 each. That is Maybe a 20-25k sale at most. For some of these companies that is a rounding error. You get lower priced parts and they just do not care much. There is no margin in it for them. Especially if you are not coming back every few months.

[happymellon]

Disappointingly that makes sense.