FCC certification procedure, step by step

Hugues Orgitello updated 7 Oct 2026 14 min read

The FCC route is written down in one place, 47 CFR Part 2 Subpart J, and it is shorter than its reputation: the rule part decides the procedure, a TCB receives every Certification application, and the grant only exists once it is published by the FCC. This page follows that route in order, from SDoC or Certification to the FCC ID on the label, section by section, with the 2023 to 2026 Covered List and TCB integrity changes that now sit inside every application.

Which procedure: SDoC or Certification

The procedure is not a free choice. It follows from the device class in Part 15 (see FCC scope for the definitions in 15.3).

	SDoC (2.906)	Certification (2.907)
Typical devices	Most unintentional radiators, for example digital devices (15.101)	Intentional radiators (15.201(b)); scanning receivers and radar detectors among unintentional radiators (15.101)
Who acts	Responsible party, located in the United States (2.909(b))	Applicant, which becomes the grantee (2.909(a))
Third party	None; nothing filed unless the FCC asks for a sample or data (2.906(a)(2), 2.945)	A TCB reviews and grants (2.911(a), 2.962)
Test lab	No accreditation required; not a lab owned, controlled or directed by a prohibited entity (2.906(a)(1))	Accredited and FCC-recognized lab (2.948(a))
Identifier	A unique identification chosen by the responsible party, which must not look like an FCC ID (2.1074)	FCC ID: Grantee Code plus product code (2.926)
Paper that travels with the product	Compliance information statement (2.1077)	Grant published in the FCC database (2.915)
Records kept	Two-year period (2.938(f)), including the test record of 2.938(b)(1)	One year after marketing is permanently discontinued, or until an investigation ends (2.938(f))
Covered List	Not available to equipment produced by a Covered List entity (2.906(d))	Mandatory route for such equipment, even if otherwise exempt; covered equipment itself is barred (2.907(c), 2.903)

2.906(c) lets a responsible party certify a device that SDoC would allow. A product with a radio and a separate digital circuit can need both procedures; 2.925(b) allows one FCC ID on such a composite device, and 2.938(d) requires the records of both.

What SDoC actually requires

The SDoC responsible party is the manufacturer or assembler, or the importer for imported equipment (2.909(b)). It tests, keeps records, and supplies with the product, at marketing or importation, a compliance information statement giving the product identification, the compliance statement of 15.19(a)(3), and the name, address and telephone or internet contact of the US responsible party (2.1077(a)). The statement goes in the user manual or on a separate sheet (2.1077(c)). For Class A or Class B digital devices, the manual also carries the 15.105 text, and every Part 15 manual carries the 15.21 warning that unapproved changes can void the user's authority to operate. Since FCC 22-84, the SDoC records include a signed statement that the equipment is not produced by a Covered List entity (2.938(b)(2)).

Certification, in order

Step	What happens	Text
1	Register in CORES and obtain an FRN, the 10-digit FCC Registration Number	1.8001
2	Request a Grantee Code through the Equipment Authorization System, pay the fee within 30 days	2.926(c), 1.1103
3	Choose the product code (14 characters at most, never used before with that Grantee Code)	2.926(d)
4	Test in an accredited, FCC-recognized lab, using the measurement procedures in the rules and the KDB guidance	2.948(a), 2.947
5	Designate a US agent for service of process and sign the applicant certifications	2.911(d)
6	Submit the application and exhibits to a TCB, with any confidentiality request	2.911(a), 2.1033, 2.962(d)(6)
7	If the device is on the PAG list, the TCB asks the FCC for guidance and concurrence	2.964, KDB 388624
8	The TCB grants or dismisses through the FCC system; the grant takes effect on publication	2.962(d)(7), 2.915(d)
9	Label the device and market it; the grant can still be set aside within 30 days	2.925, 2.962(f)

The rules set no review time for a TCB, and this page does not quote one. What the rules do set is that the TCB may charge fees (2.962(e)), so its price is a commercial matter between applicant and TCB.

Steps 1 to 3: FRN, Grantee Code, product code

The Grantee Code is assigned permanently to the party named in the assignment and is reused for every later application (2.926(b), (c)(1)). The fee is $35 under the 1.1103 schedule (payment type code EAG); if it is not paid and validated within 30 days of issuance, the code is removed and a new one must be obtained (2.926(c)).

Grantee Code	Format	Text
Five characters	Issued since 1 May 2013: a digit from 2 to 9, then four capital letters or digits from 2 to 9	DA 13-669
Three characters	No longer issued; codes already issued and paid for remain valid	DA 13-669

The full FCC ID is the Grantee Code followed by the product code, so it can reach 17 characters with a three-character code and 19 with a five-character one. The FCC ID, Grantee Code and TCB guide reads 2.926 in detail.

Who should hold the grant. The grantee is the party responsible for compliance (2.909(a)) and the only one that can make Class I and Class II permissive changes (2.1043(b)(4)). A brand owner that wants to control later changes therefore applies in its own name. 2.929(b) lets a grantee license another party to manufacture under the same FCC ID, the grantee remaining responsible; 2.924 lets it market electrically identical devices under other model or trade names.

Step 5: what the applicant signs

Statement	Text	Since
All statements true and correct	2.911(d)(1)	Before 2023
Anti-Drug Abuse Act certification	2.911(d)(2), 1.2002	Before 2023
Equipment not prohibited under 2.903; whether the applicant is on the Covered List, renewed if the list changes before grant	2.911(d)(5), (6)	FCC 22-84, 6 February 2023
A US agent for service of process, signed by applicant and agent, kept for at least one year after marketing and importation end or after any related FCC proceeding, whichever is later; a US applicant may name itself	2.911(d)(7)	FCC 22-84, 6 February 2023

The same statements accompany every permissive change request (2.932(e)). Test data are signed by the person who performed or supervised the tests (2.911(e)).

Step 6: the exhibits of 2.1033(b)

An application is filed on FCC Form 731 with all questions answered (2.1033(a)). For Parts 11, 15 and 18 equipment, the technical report contains:

Exhibit	2.1033(b)
Applicant and US agent: names, mailing and physical addresses, email, telephone	(1)
Signed 2.903 statement, Covered List statement, 2.911(d)(7) certifications	(2) to (4)
FCC ID	(5)
Installation and operating instructions (a draft is accepted, the final document follows)	(6)
Description of circuit functions and how the device operates, including ground system and antenna	(7)
Block diagram with the frequency of all oscillators; a schematic for intentional radiators	(8)
Measurement report: test procedure, date, location, device tested, sample calculations	(9)
Photographs of exterior, construction, component placement and the label, or a sample label with a placement sketch	(10)
Description of peripherals or accessories used in test	(11)
Whether the 15.37 transition provisions are used	(12)
Exhibits for 57-64 GHz devices (15.255(g)), software defined radios (2.944) and U-NII devices in 5.15-5.35 and 5.47-5.85 GHz (security of RF parameters)	(14) to (16)
Test set-up drawing or photograph for each type of test	(17)

Every application for an RF source also contains a statement of compliance with the RF exposure rules (1.1307(b), 1.1310, 2.1091, 2.1093), with the technical basis supplied on request (2.1033(f)); that is where MPE or SAR data belong. A composite system can be filed in one application if it keeps one FCC ID, with a fee for each device; different FCC IDs need separate applications (2.1033(e)). The FCC technical file page covers how to assemble these exhibits.

Confidentiality

The TCB sends the FCC an electronic copy of the application and its exhibits, with any request for confidential treatment (2.962(d)(6)). The 1.1103 schedule lists a $50 fee for a confidentiality request. FCC guidance is in KDB 726920; the OET slides of the October 2020 TCB workshop summarise it:

Exhibit	Long-term confidentiality	Short-term (180 days at most from grant)
ID label and location, attestation statements, test report, RF exposure information, cover letters	No	No
External photos, test set-up photos	No	Yes
Block diagram, schematics, parts list and tune-up, operational description	Yes, with justification	Yes
Internal photos, user manual	Only under special conditions (for example internal parts sealed in epoxy, or a manual for professionals under NDA)	Yes
SDR software and security information	Automatic	Automatic

A request outside these cases needs a PAG inquiry. Once a grant is published, the application and its materials are open to inspection except what was given confidential treatment (0.457(d)(1)(ii)).

Steps 7 to 9: PAG, grant, set-aside

The FCC publishes a Pre-approval Guidance (PAG) list, KDB 388624, of equipment categories and test types for which the TCB must ask for guidance before granting (2.964(a)). The TCB reviews, submits the exhibits and the issues to the FCC, completes the review per the guidance, and grants only after the FCC gives its concurrence; the FCC may ask to test a sample first (2.964(b)). Since FCC 26-28 (amendment published 15 May 2026), 2.964(a) states that the PAG list prioritizes equipment tested in Trusted Test Labs, meaning labs in the United States or in an economy with reciprocal treatment through a trade agreement.

A grant shows its effective date and any special conditions (2.915(b)), runs from its publication on the FCC website, which holds the official copy (2.915(d)), and names the TCB and the Commission (2.915(e)). Within 30 days, the TCB or the FCC may set aside a grant that does not comply; after that only the FCC can revoke it (2.962(f), 2.939). Grants can be checked in the FCC ID search of the Equipment Authorization System (EAS).

Before the grant: what you may already do

Activity	Condition	Text
Display at a trade show or advertise	Conspicuous notice that the device is not authorized and may not be sold or leased until it is	2.803
Conditional sales contracts	Prominent disclosures to the buyer; no delivery to end users before authorization; records kept 60 months	2.803
Pre-sale transfer to distribution sites and retailers (Certification only)	After testing by an FCC-recognized accredited lab and submission to a TCB; temporary label; the expected FCC ID only if obscured	2.803
Import for testing and evaluation	4,000 units or fewer, not offered for sale	2.1204(a)(3)
Import for trade shows	400 units or fewer	2.1204(a)(4)
Import for pre-sale activity (Certification only)	12,000 units or fewer per FCC ID, after testing and TCB submission, temporary label, retrieval process, records kept 60 months	2.1204(a)(11)
Evaluation kits	Sold only to product developers, software developers and system integrators, with the FCC notice and legend	2.803

FCC 26-50 renumbers 2.803 from 13 October 2026 (the current paragraph (c) becomes (d)) and adds a new 2.803(c) on online marketplaces, which must show the FCC ID at the point of sale from 1 March 2027 or 1 June 2027 depending on their role. The quantities in 2.1204 are unchanged by that order.

Modules: what 15.212 really requires

Modular approval is defined in 15.212 and explained in KDB 996369. 15.212(a)(1) lists what a single modular transmitter must have:

Requirement	15.212(a)(1)
Its own shielding of the radio elements	(i)
Buffered modulation and data inputs	(ii)
Its own power supply regulation	(iii)
Antenna rules of 15.203 and 15.204: a permanently attached antenna or a unique coupler	(iv)
Tested in a stand-alone configuration	(v)
Its own FCC ID label, or an electronic display of the FCC ID	(vi)
Compliance with the specific operating rules, with integration instructions	(vii)
RF exposure statement; compliance in the final configuration	(viii)

A split modular transmitter (15.212(a)(2)) meets most of the same conditions, is tested in a representative host, and has a digital interface of at least 150 mV peak-to-peak. A limited modular approval (15.212(b)) covers a module that misses some requirements, or whose RF exposure compliance is shown only for particular host configurations; the applicant explains how control of the end product is kept.

When the module FCC ID is not visible inside the host, the host carries "Contains FCC ID:" followed by the module FCC ID, or similar wording (15.212(a)(1)(vi)(A)). The host still needs its own Part 15 Subpart B authorization for its digital circuitry unless that circuitry only enables the radio (15.3(k)). Since FCC 25-71 (effective 26 December 2025), a covered modular transmitter, and any host that incorporates one, cannot be authorized (2.903).

Changes after the grant

Class	2.1043(b)	Filing
Class I	Modifications that do not degrade the characteristics reported and accepted at grant	None
Class II	Modifications that degrade the performance characteristics reported at initial certification, while still meeting the rules	Test results for the affected characteristics, 2.903 and Covered List statements, US agent details; no marketing under the grant before acknowledgement
Class III	Software changes to a software defined radio that move frequency range, modulation type or maximum output power outside the approved parameters, or change the circumstances of operation	Description and test results with the new software, including RF exposure; same statements; only if no Class II change was made

Changes to the frequency determining and stabilizing circuitry (including clock or data rates), frequency multiplication, the basic modulator or the maximum power or field strength ratings need a new grant, except Class III changes (2.1043(a)). No class may change the FCC ID (2.1043(b)), and Class I and Class II changes are reserved to the grant holder (2.1043(b)(4)). From 13 October 2026, FCC 26-50 adds that any change made by a Covered List entity, or that would make the device covered equipment, needs a new grant (2.932(a), (f) and 2.1043(a) as amended). The Class II permissive change guide covers the workflow.

Labels and user information

Rule	Text	What it says
FCC ID label	2.925(a)(1), (d)	"FCC ID" followed by the identifier, permanently affixed and visible from outside the enclosure
Very small devices	2.925(f), 15.19(a)(5)	Only when a four-point font is impractical and there is no display: in the manual, plus on the packaging or a removable label
Electronic label	2.935	Only for a device with an integrated display (or that operates only with one): no special codes, at most three steps from the settings menu, and the device or packaging still identifies it at import and sale
Part 15 statement	15.19(a)(3)	On certified and SDoC devices alike
User warning	15.21	Changes not approved by the responsible party could void the user's authority to operate
Digital device information	15.105(a), (b)	Class A or Class B text in the manual

Electronic labeling has been in the rules since 2.935 was adopted in the SDoC order (82 FR 50827, 2 November 2017); OET guidance is in KDB 784748. FCC Parts gives the exact statement texts.

Dated changes that now sit inside the procedure

Date	Text	Effect on the procedure
1 May 2013	DA 13-669	Five-character Grantee Codes
12 June 2015	80 FR 33439 and following	All applications go to a TCB (2.911(a)); PAG procedure (2.964)
2 November 2017	82 FR 50825 and following	SDoC replaces verification and Declaration of Conformity; electronic labeling (2.935)
6 February 2023	FCC 22-84, 88 FR 7592	Covered equipment barred; Covered List statements and US agent for every applicant
23 April 2025 (published)	90 FR 17013	Current 1.1103 schedule, Grantee Code $35
8 September 2025	FCC 25-27, 90 FR 38045	TCBs, labs and accreditation bodies owned, controlled or directed by a prohibited entity lose recognition; SDoC testing barred in such labs; some provisions delayed
26 December 2025	FCC 25-71	Covered modular transmitters and their hosts barred
15 May 2026 (published)	FCC 26-28, 91 FR 27843	Trusted Test Lab priority on the PAG list; post-market surveillance updates
13 October 2026	FCC 26-50, 91 FR 57798	Logic-bearing components rule; new grant for changes by Covered List entities; marketing rules reach online marketplaces
1 March 2027 and 1 June 2027	FCC 26-50	Online marketplaces display the FCC ID at the point of sale

Claims the texts contradict

Common claim (some of them made by this page before October 2026)	What the text says
The SDoC compliance information statement is an internal document	It is supplied with the product, in the manual or on a separate sheet (2.1077(a), (c))
SDoC records are kept "at least two years after marketing ends", and Certification has the same rule	2.938(f): Certification records one year after marketing is permanently discontinued; a two-year period for the other records
A Grantee Code is assigned "for life" as soon as it is requested	The fee must be paid and validated within 30 days or the code is removed (2.926(c))
A module needs an enclosure, anti-tamper screws and thermal self-sufficiency to get modular approval	15.212(a)(1) asks for RF shielding, buffered inputs, its own power regulation, a permanent antenna or unique coupler, stand-alone testing, a label, instructions and an RF exposure statement; no enclosure, screws or thermal criterion
A "Single" modular approval works in any host	It works within the conditions of the grant; RF exposure must hold in the final configuration (15.212(a)(1)(viii)), and the host still needs its own digital device authorization (15.3(k))
The integrator files a Class II permissive change on the module grant	Class I and Class II changes may only be made by the grant holder (2.1043(b)(4))
Class II covers changes "within the approved characteristics"	Class II is a degradation of the reported characteristics that still meets the rules (2.1043(b)(2))
A very small device may replace its label with an e-label	2.935 requires an integrated display, or a device that only works with one; without a display, a small device follows 2.925(f)
A cellular certification file needs a PTCRB letter and an OTA report	2.1033 does not list them; PTCRB and carrier acceptance are industry programs outside the FCC grant
The Form 731 package must include a cover letter, a parts list and an "integration guide" for every product	2.1033(b) lists the exhibits; integration instructions are a module condition (15.212(a)(1)(vii)), and other documents are what the TCB asks for (2.911(d))
A US party is needed only for SDoC	Every Certification applicant designates a US agent for service of process (2.911(d)(7))
Nothing can happen before the grant	Display with a notice, conditional sales and, for Certification, pre-sale transfer and import of up to 12,000 units per FCC ID after TCB submission are allowed (2.803, 2.1204(a)(11))
A certification takes a fixed number of weeks and costs a fixed range	No FCC text sets a TCB review time; TCB fees are set by each TCB (2.962(e)); the FCC itself charges $35 for the Grantee Code and lists $50 for a confidentiality request (1.1103)