What a US contract with a Shenzhen team gives you
Aximora Labs Inc. signs the contract. Our Shenzhen team designs and builds the device. Here is what that gives you, and the limits of each promise.
PCB layoutEvery source file is yours
IP assigned and native files handed over at every paid gate.
IP and source files →Certification, planned
FCC, lab and module rules settled at Gate 0. Grants in your name.
FCC planning →Your cloud, your keys
No China-hosted cloud. Firmware source and an SBOM delivered.
Data sovereignty →Small batches of 10–1,000 units
Pilot builds on a real line, with fixtures and yield tracking.
Small-batch builds →Reviews in the Bay Area
Gate reviews in person with the founder in the San Francisco Bay Area.
Meet in the Bay Area →You own the design and every source file, gate by gate
Pay for a gate and its work is assigned to you, with the native files in your hands. Stop, switch teams or move production without rebuilding the design.
- One US contract. Aximora Labs Inc. signs the MSA and one fixed-price SOW per gate, each listing its deliverables file by file.
- Assignment on payment. Designs, firmware, documents, test data and tooling from that gate become yours.
- Native files and a SHA-256 manifest at every gate, so you can check nothing is missing.
- Firmware in your repository from the first commit, in your GitHub, GitLab or Bitbucket organization.
- Molds and fixtures you paid for are labeled with your name and tracked in a tooling register.
- A clean chain. Our Shenzhen engineers work under agreements that pass their work to Aximora Labs Inc., so it can be assigned to you. [Back-to-back IP agreement with the Shenzhen entity — to confirm with counsel]
| Discipline | What you receive |
|---|---|
| Electrical | Native schematic and PCB project, libraries, Gerbers, stackup, pick-and-place, BOM with approved alternates |
| Mechanical | Native CAD, STEP, 2D drawings, mold drawings and the tooling register |
| Firmware | Full source in your Git organization, pinned toolchain, provisioning scripts, OTA procedure, SBOM |
| Test and quality | Bring-up logs, power profiles, RF pre-scans, EVT / DVT reports, test-station software, fixture designs, per-unit records |
| Certification | Reports and grants in your company’s name, label artwork, report-to-version index |
What we cannot assign. Third-party IP such as chip vendor SDKs, modem firmware and licensed codecs stays under its own license, and we list it in the SBOM. Our pre-existing reference designs and libraries are licensed to you for your product. [License scope for background IP — to confirm with counsel] We do not file patents or give freedom-to-operate opinions.
Download a sample handover tree · Who owns the files under a US contract →
One number for the device on your dock, tariffs included
A DDP quote covers the unit price, freight, every US duty layer for your HTS code, customs fees, brokerage and delivery to your warehouse or 3PL. Engineering (NRE) is billed by gate. Certification fees are separate and paid by you.
Worked example: 500 trackers, two HTS codes
Illustrative, not a quote. Unit price, freight, brokerage and delivery are hypothetical. Duty and fee rates are as of October 2026.
| Line (air, 500 units) | HTS 8526.91.0040 | HTS 8517.62.0090 |
|---|---|---|
| Goods at $38.00 a unit | $19,000.00 | $19,000.00 |
| Section 301, China list | $4,750.00 (List 1, 25%) | $1,425.00 (List 4A, 7.5%) |
| Section 301, forced labor (12.5%) | $2,375.00 | $2,375.00 |
| MPF (0.3464%) | $65.82 | $65.82 |
| Freight, brokerage, last mile | $1,830.00 | $1,830.00 |
| Landed DDP per unit | $56.04 | $49.39 |
Base duty is free for both codes. HMF (0.125%) applies to ocean freight only. Budgeting on FOB would understate cost by $18.04 a unit in the first column, and classification alone is worth $6.65 a unit.
The 2026 tariff picture, as of October 2026
- IEEPA duties are gone. The Supreme Court held on 2026-02-20 that IEEPA does not authorize tariffs. The temporary 10% Section 122 duty that followed expired on 2026-07-24.
- Forced-labor Section 301 duty. In force since 2026-07-24. The rate for China is 12.5% (91 FR 47318).
- 2018–2019 China lists still apply. 25% for Lists 1–3, 7.5% for List 4A (USTR). Some exclusions are set to expire on 2026-11-10.
- HTS code decides the list. 8526.91.0040 is on List 1; CBP has classified cellular GPS trackers there (N315940). 8517.62.0090 is on List 4A. Where it is unclear, we prepare a binding ruling request under 19 CFR Part 177 at Gate 3.
- Assembly outside China is not a clean escape. Vietnam and Thailand also pay 12.5%, Vietnam is named in the open overcapacity investigation, and moving final assembly may not change origin under the substantial transformation test. We evaluate it case by case.
Fees: MPF, 19 CFR 24.23. HMF, 19 CFR 24.24. This is not customs advice.
You get a landed estimate at Gate 0 and a firm DDP quote for each Gate 3 and Gate 4 shipment. Try the estimator · What a 2026 DDP price includes →
FCC, lab and module rules, planned at Gate 0
Radios, module, antenna, distance from the body and lab location decide cost and schedule. We settle them before the first board, and grants are issued in your company’s name. Rules below are as of October 2026.
What your device needs
- SDoC or Certification. No transmitter: SDoC (47 CFR 2.906). Bluetooth, Wi-Fi or LTE: Certification through a recognized lab and a TCB (47 CFR 2.907).
- Modular approval has limits. A module grant (47 CFR 15.212) holds only with the listed antenna type and gain, at 20 cm or more from people. A worn device, a new antenna, radios that transmit together or a chip-down design need more.
- SAR for body-worn LTE. Limits under 47 CFR 2.1093. We check it on EVT hardware so the formal test at Gate 3 is a confirmation.
- PTCRB and carriers. AT&T and T-Mobile require PTCRB. Verizon uses its own ODI process. FCC plus PTCRB plus carriers often totals $30,000 to $100,000 over two to four months. That is a planning estimate; we get written lab quotes at Gate 0.
Lab and supply-chain rules
- Lab recognition. Since 2025 the FCC has withdrawn or denied recognition for labs tied to prohibited entities, and in July 2026 opened a proceeding against a Shenzhen lab for false test results (DA 26-745).
- Lab choice. Formal certification testing runs at FCC-recognized labs outside mainland China, such as Taiwan, Hong Kong or the US. Pre-scans stay in Shenzhen.
- Covered List. Under FCC 26-50, from 2026-10-13 the FCC does not authorize new devices with certain logic-bearing components from Covered List entities. The common Chinese cellular module makers are not on the list.
- A non-Chinese module option on every LTE design, such as Nordic nRF91, Telit Cinterion, u-blox or Semtech (Sierra Wireless). You see both BOMs at Gate 0 and choose.
Lab, TCB, PTCRB and carrier fees are paid by you. We manage the labs, samples and documents. Not legal advice. Labs and certification bodies we work with: [Named partner labs and TCB, with written permission — to fill].
FCC modular checklist · Is a pre-certified LTE module enough? →
Your device talks to your cloud, and you hold the keys
No China-hosted cloud and no vendor platform in the middle. You get firmware source and an SBOM, so your team can verify what runs on the device.
| Item | Where it lives | Notes |
|---|---|---|
| Device data and audio | Your cloud, or a US region of AWS, Google Cloud or Azure in your account | No Duobay or China-hosted server in the path |
| Firmware updates (OTA) | Your update service, signed with your key | We cannot push an update to your fleet |
| Device identity | Your CA or your cloud’s IoT service | Private keys generated on the device where the silicon supports it |
| Production signing key | Held by you, ideally in an HSM or cloud KMS | We sign engineering builds with development keys only |
| Source code | Git repository in your organization | Our engineers work there with access you control |
- App and cloud, your choice. By default we deliver the device, firmware and an SDK, tested against your backend. As an option we build the companion app and backend, deployed in your own cloud account under your credentials. Scope options.
- Secure boot and signed OTA. After you generate the production key, no one at Duobay can produce firmware your devices accept.
- Debug locked on production units, with readout protection where the silicon supports it.
- CycloneDX SBOM with every tagged release and production lot, listing each component, version, supplier and license.
- Module origin. The FCC does not authorize new equipment with a modular transmitter from a Covered List company (FCC 25-71, effective December 26, 2025). Quectel is on the Department of Defense 1260H list and is challenging that in court. As of October 2026.
- Recording that respects bystanders. Voice devices default to push-to-record and a visible indicator. California requires all-party consent for confidential conversations (Penal Code 632).
- Limits. We do not host your data on our servers. We cannot see inside closed vendor binaries such as modem firmware; we list them in the SBOM. We do not give legal opinions on privacy law.
Download a sample SBOM · Voice wearables without a China cloud · SBOM and handover checklist →
Duobay, a direct Shenzhen ODM or a US design firm
The Duobay column states our terms. The others describe what is typical; individual companies differ, so ask each one the same questions.
| Duobay | Shenzhen ODM, direct | US design firm | |
|---|---|---|---|
| IP and source files | Assigned to you at every paid gate, native files included. | The ODM often keeps the platform design and firmware. | Usually assigned to you. You then manage the factory. |
| Where device data goes | Your cloud or a US region. No China-hosted cloud. You hold the keys. | Often the vendor’s own platform, sometimes hosted in China. | Depends on who builds the connectivity stack. |
| Minimums | From 10 units. 10–1,000 units is normal work. | Custom changes usually come with a larger order commitment. | Prototype quantities. The factory sets production minimums. |
| Pricing | Fixed price per gate. Unit price from a costed BOM. Gate 0 credited if you continue. | Low or no NRE, recovered in the unit price and minimum order. | Hourly or fixed design fees. Manufacturing priced separately. |
| Tariffs | Landed DDP quote, every duty line shown with the HTS code assumed. | Usually FOB or EXW. You import and pay the duties. | Not in scope. |
| Certification | Planned at Gate 0, grants in your name, tested at FCC-recognized labs outside mainland China. | Often mainland China labs. The grant may be in the ODM’s name. | Often handed to a separate consultant. |
| Speed | Works-like units in 3–6 weeks. EVT in 6–10 weeks after that. Small batch in 8–16 weeks. | Fast on an existing platform. Slower with real design changes. | Strong on industrial design. Production handoff adds time. |
| Contract | Aximora Labs Inc., a US company, under US law. Paid in USD. | Usually a Chinese entity under PRC law. | US entity, US law. |
| Walk away | At any gate, with every file and the hardware you paid for. | Hard without source files. Molds may be held. | Per contract. Files are yours once paid. |
When we are the wrong choice
- You need 100,000+ units from day one, or an off-the-shelf white-label device with no changes.
- The product is for children. Our companion work is for adults, teens 13 and older, and older adults.
- It is a government, defense or FirstNet project.
- You need “Made in USA,” Buy American or TAA compliance. Our engineering and production are in China.
Ask any partner, in writing
- Which entity signs, in which country, under which law?
- Which files do I get at each milestone? Is firmware source included?
- Where does device data go, and who holds the keys?
- FOB, EXW or DDP? Which HTS code and duty rates?
- Whose name is on the FCC grant, and which lab tests it?
- If I stop after the next milestone, what do I keep?
Questions about working with us
Is Duobay a Shenzhen ODM with a US address?
No. Aximora Labs Inc. is a US company and signs every contract. Our own engineers in Shenzhen do the electrical, firmware, mechanical, app and test work. Partner factories run SMT, assembly and molding under our engineering control.
When exactly does ownership transfer?
When you pay the invoice for a gate, the work from that gate is assigned to you and we deliver its files. If you stop partway through a gate, you receive the files for the work completed and paid for. Settlement is set out in the SOW. See engagement terms.
Can you reuse our design for another client?
No. We can reuse general know-how and our own pre-existing building blocks, such as a power-management library, but never your schematics, firmware, enclosure or anything that identifies your product.
Can we move production to another factory?
Yes, at any gate. The handover package is built so a competent factory can build from it, and the FCC grant moves with you. If you contract directly with one of our partner factories, the non-solicitation term in the MSA applies for a limited period.
What happens to the landed price if tariffs change after you quote?
Every quote names the HTS code and duty rates it assumes, with the date we checked them. If a rate changes before entry, the duty line moves by the same amount, up or down, and we share the entry summary (CBP Form 7501). Freight and unit price do not move. [Tariff-change clause wording — to confirm against the engagement terms]
Who is the importer of record?
Under DDP, the seller side files the entry and pays the duties, so nothing is due at your door. Each quote states who acts as importer of record. [Importer of record arrangement (Aximora Labs Inc. or broker as agent) — to confirm]
We use a pre-certified LTE module. Do we still need certification?
Usually yes for a wearable or handheld. Most LTE module grants are limited to use 20 cm or more from the body, so a body-worn device needs its own SAR evaluation and a new grant or permissive change. PTCRB and carrier approval are also needed. Read the full answer.
How long does certification take?
A Bluetooth or Wi-Fi device often needs a few weeks of lab time once samples pass pre-scan. An LTE device with PTCRB and carrier approval commonly takes two to four months end to end. We plan it at Gate 0 and test formally at Gate 3 (8–16 weeks). For Canada (ISED) or the EU, tell us at scoping so the plan covers them.
Your engineers are in Shenzhen. Do they see our data?
They work with test devices, test accounts and synthetic data. They do not need access to your production cloud or customer data, and we do not ask for it. If a field issue needs real logs, you decide what to share and for how long.
Do you build the mobile app and cloud backend?
If you want us to. By default we deliver the device, firmware and an SDK, tested against your backend. As an option we build the iOS and Android app and the backend, deployed in your own cloud account. App, cloud and AI.
Are you cheaper than going to an ODM directly?
Per unit, a direct ODM with an existing platform is often cheaper, especially above a few thousand units. With us you pay for engineering, and you get a design you own, a data path on your side and a price that already includes tariffs. At 10–1,000 units that trade is often worth it. Sometimes it is not.
What does it cost to find out if this works for us?
The first calls are free. Gate 0 Feasibility is a paid, fixed-fee study that takes 1–2 weeks, credited against later work if you continue. What Gate 0 delivers.
This page is a summary. The signed MSA and SOWs govern, and the engagement terms explain them in plain English. Nothing here is legal or customs advice.
Next step. Tell us what you are building and bring your security questionnaire. If it fits, you get a scoping call and a fixed Gate 0 quote. A Duobay engineer replies within 2 business days.