Good info on the retroactive part. You can't do that for FCC.

FWIW the CFR is he
http://ecfr.gpoaccess.gov/cgi/t/text...6:1.0.1.3.17.2

or http://tinyurl.com/ypv4ld. A mariner can not certify a light as
USCG approved at any time but a non USCG approved light may be in
compliance with COLREGS.

-- Tom.