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This is likely outside of the scope of this proposal, but my red team brain sees IoT devices from China as a distributed Trojan Horse.

In a time of conflict with China, firmware updates will be sent which will create the largest DDOS botnet in history.

Our cheap IoT lightbulbs will take down major internet infrastructure.

I don’t know the solution to that problem, but it’s a problem. Isn’t it?

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This is something that has us worried too. The FCC took some action on this issue last year by outright banning equipment from certain companies (e.g. Huawei), but we haven't even scratched the surface of this pervasive problem. I really encourage you to share your concerns through an official comment. Maybe the label can include commitments about the provenance (and, e.g., control of signing keys) of the on-device software and associated cloud services?

Look into the ESP32 chip. It's by a Chinese company and is used in almost all cheap IoT products.

Not just on the firmware level. Many cheap IoT products are based on the Chinese ESP32 SoC.

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