October 2, 2023

Coalition Comments to FCC re: Proposed Rulemaking on Labeling for Internet of Things


Comments of the Cybersecurity Coalition
To the Federal Communications Commission

RE: Proposed Rule on Cybersecurity Labeling for Internet of Things

PS Docket No. 23-239

The Cybersecurity Coalition (the Coalition) submits the following comments in response to the Federal Communications Commission’s (the Commission) Proposed Rule on Cybersecurity Labeling for the Internet of Things. The Coalition appreciates the opportunity to provide input.

The Coalition is composed of leading companies with a specialty in cybersecurity products and services, who are dedicated to finding and advancing consensus policy solutions that promote the development and adoption of cybersecurity technologies. We seek to ensure a robust marketplace and effective policy environment that will encourage companies of all sizes to take steps to improve cybersecurity risk management.

The Coalition supports several aspects of the Commission’s proposed rule, particularly the binary and layered structure of the voluntary label. The Coalition believes the primary value of an IoT security labeling program is to better enable ordinary consumers to distinguish labeled products as likely providing better basic security than unlabeled products, and to make streamlined purchasing decisions on this basis. A widely used and well-designed security labeling program can help to foster market competition in product security, which can strengthen the resilience of the broader digital ecosystem.