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FCC certification, step-by-step procedure

FCC · Pillar

FCC certification follows a formalised process that differs significantly from the European approach. Two main regimes coexist: SDoC (self-declaration) and Certification (with TCB). This page details the concrete steps, from regime choice to FCC ID assignment, via the Grantee Code, TCB, and the EAS database.

SDoC: Supplier's Declaration of Conformity

Section titled “SDoC: Supplier's Declaration of Conformity”

SDoC applies to unintentional equipment (Part 15 Subpart B, digital equipment) and some simple radio-emitting equipment. It is equivalent to the European module A:

  1. The manufacturer has tests performed in an accredited lab (ISO/IEC 17025 with FCC competence typically).
  2. The manufacturer drafts an internal Compliance Information Statement.
  3. The manufacturer affixes required markings (Part 15.105 text in manual).
  4. The manufacturer retains documentation for 10 years.

No FCC ID assigned: the product is simply declared compliant by its manufacturer. The "FCC ID" equivalent in documentation is a mention "Tested to comply with FCC standards".

Certification: The standard regime for intentional emitters

Section titled “Certification: The standard regime for intentional emitters”

Certification is mandatory for intentional emitters (Wi-Fi, BLE, cellular, etc.). Procedure:

  1. Obtain a Grantee Code from the FCC (one-time step for manufacturer).
  2. Select a TCB from the FCC-published list.
  3. Perform tests in an FCC-accredited lab.
  4. Assemble the file (test report, user manual, photos, schemas, etc.).
  5. Submit to TCB via its online interface.
  6. Revise per TCB comments.
  7. Obtain the FCC ID once certification validated.
  8. Affix the FCC ID on product and publish authorisation in EAS.

The TCB validates the file and registers it in the Equipment Authorization System (EAS), the FCC's public database accessible at https://apps.fcc.gov.

The Grantee Code is a 5-character prefix assigned by the FCC to the manufacturer (or certificate holder). One application per entity, valid for life.

  • Cost: $60 (paid to FCC via Pay.gov)
  • Assignment delay: 1 to 3 business days
  • Required document: Form 159 + entity name and address

The Grantee Code identifies the certificate holder in the EAS. All FCC IDs assigned to this entity begin with this prefix.

Grantee choice: manufacturer or integrator?

Section titled “Grantee choice: manufacturer or integrator?”

For a manufacturer certifying its own products → direct grantee code.

For a private-label product (company A designs, company B resells under their brand) → generally B applies for its own grantee code and submits the certification, using a file provided by A.

For a radio module intended for integration → the module manufacturer obtains the grantee code and FCC ID. The integrator reuses this FCC ID in their final product via Modular Approval.

TCBs (Telecommunication Certification Bodies) are FCC-accredited. The public list of TCBs is available on the FCC website. Selection criteria:

  • Accredited scope: verify the TCB is authorised for the relevant Parts (e.g. not all TCBs are accredited for 5G millimetre bands).
  • Lead times: 2 to 6 weeks typically, faster for standard Wi-Fi/BLE products.
  • Costs: TCB fees of $3,000 to $8,000 depending on complexity.
  • Industry reputation: some TCBs are preferred by major OEM customers (Apple, Samsung often use the same TCBs for consistency).
  • Submission interface: most have online portals; check ergonomics and support.

TCBs commonly used for IoT products:

TCBSpecialties
Bureau Veritas Consumer ProductsAll types, IoT experience
TÜV Rheinland of North AmericaAll radio types
SGS-CSTCMultiprotocol
Element Materials TechnologySDR, cellular, cybersecurity
UL Verification ServicesAll types
Telefication BVAll types
SIEMIC Inc.Cellular, Wi-Fi
EMCC Dr. RasekWi-Fi, BLE, sub-GHz
CETECOMCellular specialist, OTA

An FCC certification file typically contains:

  1. Application form (Form 731 or TCB equivalent)
  2. Cover letter describing the product and radio modes
  3. Test report signed by accredited lab
  4. Block diagram electrical and functional
  5. Schematics detailed
  6. External photos of the product
  7. Internal photos of the opened product (with FCC ID label visible)
  8. Label sample showing the FCC ID and warnings
  9. User manual complete with Part 15 mentions
  10. Antenna specifications (for intentional emitters)
  11. Operational description detailing radio modes
  12. MPE / SAR report if applicable

For a cellular product, add:

  • OTA report (Over-The-Air performance, distinct from SAR)
  • PTCRB letter or equivalent

For a modular product, add:

  • Integration guide (integration notice for future integrators)
  • Modular approval letter
Week 1 : TCB selection + scope definition
Week 2-3 : Internal pre-tests
Week 4-6 : Tests at FCC-accredited lab
Week 7 : File assembly
Week 8 : TCB submission
Week 9-11: TCB review + comments + corrections
Week 12 : FCC ID assignment + EAS publication
Week 13 : Marking application, market placement

Total: 3 to 4 months for a standard product. Cellular products typically add 4 to 8 weeks for 3GPP tests.

Modular Approval: Reusing certified modules

Section titled “Modular Approval: Reusing certified modules”

The FCC has a specific regime for radio modules documented by KDB 996369 and KDB 484596.

For a module to benefit from the modular regime, it must:

  1. Have an integrated antenna or be supplied with a terminated RF cable.
  2. Have an enclosure or at least partial casing.
  3. Have anti-modification systems (screws, soldering) to discourage modifications.
  4. Have a permanent label with its FCC ID.
  5. Comply with thermal requirements without assistance.
  • Single Modular Transmitter: module usable in any host product, subject to respecting documented integration conditions.
  • Limited Modular Transmitter: module usable only in specific configurations (e.g. with a precise listed antenna).

When an integrator reuses a certified module in their final product, they affix a label:

Contains FCC ID: <module FCC ID>

This mention is sufficient: no need to re-certify the final product for the radio part, provided integration conditions are respected.

If the integrator modifies the module (e.g. different antenna, higher gain), they must file a Class II Permissive Change (PC2) with the TCB. This is essentially a mini-certification that modifies the existing FCC ID without creating a new one.

Three modification classes:

  • C1PC (Class 1): modifications without RF impact (cosmetic): no PC required
  • C2PC (Class 2): modifications with limited RF impact: PC required
  • C3PC (Class 3): substantial modifications, complete new certification required

The FCC ID must be legible and indelible:

  • On the product itself (except very small objects, e-label possible since 2014)
  • On packaging
  • In user manual

For e-labels, the FCC ID is displayed on screen via a standardised menu accessible in ≤ 3 clicks from the main product menu. Conditions documented in KDB 784748.

See FCC Parts for the exact text of Part 15.19 mentions (intentional emitters) and Part 15.105 (digital equipment).

ItemCost
Grantee Code (one-time)$60
Part 15 emissions tests$4,000 - $12,000
Wi-Fi/BLE 2.4 GHz tests$5,000 - $15,000
Wi-Fi 5/6 GHz tests$7,000 - $18,000
LTE/5G cellular tests$20,000 - $80,000
SAR tests$4,000 - $10,000
TCB fees$3,000 - $8,000
Modular Approval$5,000 - $15,000 (additional)
C2PC (modification)$2,000 - $6,000

Typical total for a Wi-Fi/BLE IoT product first certification: $10,000 to $30,000. For a complete cellular product: $50,000 to $150,000.

Sources & references

  1. 47 CFR Part 2 Subpart J: Equipment Authorization Procedures , FCC www.ecfr.gov/current/title-47/chapter-I/subchapter-A/part-2/subpart-J
  2. FCC Grantee Code application , FCC www.fcc.gov/oet/ea/grantee