FCC certification, scope and applicability
FCC · Pillar
The FCC has jurisdiction over any electronic equipment liable to emit radio waves placed on the US market, whether intentional emission (radio) or unintentional (electromagnetic disturbances). This page details scope boundaries, exemptions, and specific obligations for importers and online sales platforms.
Regulated equipment categories
Section titled “Regulated equipment categories”47 CFR Part 15 distinguishes three main equipment categories:
Intentional radiators
Section titled “Intentional radiators”Any equipment that intentionally generates and emits radio waves. They generally require Certification by TCB:
- Wi-Fi (2.4 GHz, 5 GHz, 6 GHz)
- Bluetooth / BLE
- ZigBee, Thread, Z-Wave
- Cellular modems 2G/3G/4G/5G
- LoRa, Sigfox, other LPWAN
- Active NFC, RFID
- UWB
- Radio remote controls (toys, cars, drones)
- Wireless microphones
- Wireless cameras
- Personal FM transmitters (Bluetooth car kit, etc.)
Unintentional radiators
Section titled “Unintentional radiators”Any digital electronic equipment that generates but does not intentionally emit radio waves. These fall under Part 15 Subpart B and generally use SDoC:
- Personal computers and servers
- Computer peripherals (keyboards, mice, monitors)
- Industrial electronic equipment
- Switching power supplies
- Microcontroller-based home appliances
- LED equipment with electronic driver
- Power tools with electronics
Receivers
Section titled “Receivers”Pure receivers are regulated under certain conditions:
- Consumer FM/AM receivers (Part 15.121, 15.123)
- TV receivers (Part 15.117)
- Cellular receivers (per Parts 22, 24, 27 by band)
- GPS / GNSS receivers (typically Part 15.121 or SDoC depending on case)
Intentional emitters: 47 CFR Parts
Section titled “Intentional emitters: 47 CFR Parts”Each radio type falls under a specific Part:
| Radio type | 47 CFR Part | Approach |
|---|---|---|
| Wi-Fi 2.4 GHz | Part 15.247 | Spread spectrum, certification |
| Wi-Fi 5 GHz | Part 15.407 | U-NII, certification, DFS for U-NII-2 |
| Wi-Fi 6 GHz (6E/7) | Part 15.407 (U-NII-5 to -8) | DFS, AFC for low-power outdoor |
| BLE 2.4 GHz | Part 15.247 | Same as Wi-Fi 2.4 |
| LoRa 915 MHz | Part 15.247 or 15.249 | By power and frequency |
| Sigfox 902-928 MHz | Part 15.247 | Frequency hopping |
| RFID 902-928 MHz | Part 15.247 or 15.249 | By usage |
| NFC 13.56 MHz | Part 15.225 | Periodic operation possible |
| UWB | Part 15 Subpart F | UWB-specific |
| Cellular LTE | Parts 22, 24, 27 | By bands |
| 5G | Parts 27, 96 | By bands |
Part 15 exemptions
Section titled “Part 15 exemptions”Several unintentional equipment categories are exempted from SDoC and require no tests or file:
- Digital equipment exclusively DC battery powered (no AC mains, not rechargeable from AC)
- Digital equipment with clock < 1.705 MHz and not intended for use with AC mains
- Very low power equipment emitting below the Section 15.103 thresholds
- Equipment for use in vehicles or aircraft (under certain conditions)
- Equipment for use by a US federal government agency
- Industrial, scientific or medical (ISM) equipment under certain Part 18 conditions
Note: "exempted" does not mean "out of jurisdiction". The equipment must still respect emission limits; it is simply spared the formal SDoC or Certification procedure.
Special case: radio modules (modular approval)
Section titled “Special case: radio modules (modular approval)”The FCC has a specific procedure for radio modules intended for integration into other products. Documented by KDB 996369 and KDB 484596, it distinguishes:
Single Modular Transmitter
Section titled “Single Modular Transmitter”Module designed to operate in precise conditions (supplied antenna, isolation distance). Once certified, the module's FCC ID can be reused by integrators under strict conditions:
- the antenna remains the approved one;
- isolation distance is respected;
- thermal and ground plane conditions are met;
- the integrator affixes a label indicating
Contains FCC ID: <module FCC ID>on their final product.
Limited Modular Approval
Section titled “Limited Modular Approval”Module certified for specific integration conditions: e.g. only with a precise antenna, in a defined product type. Reuse conditions are restricted.
Split Modular Approval
Section titled “Split Modular Approval”For modules with RF components split across multiple boards (rare in practice). Complex procedure often requiring a Class II Permissive Change by the integrator.
Importers and economic operators
Section titled “Importers and economic operators”Any equipment imported to the US must respect FCC rules. Obligations differ by status:
US-established manufacturer
Section titled “US-established manufacturer”The manufacturer directly assumes responsibilities: tests, TCB submission, DoC signature or FCC ID assignment.
Non-US manufacturer
Section titled “Non-US manufacturer”Must designate a U.S. Agent for Service established in the US. This agent:
- is reachable for FCC inquiries;
- retains documentation for 10 years;
- cooperates in market surveillance actions;
- is mentioned in the file submitted to the TCB.
Since 2023, the FCC has reinforced this obligation: without U.S. Agent for Service, the FCC ID is no longer assigned.
Importers
Section titled “Importers”Importers verify that:
- the equipment carries the appropriate FCC ID;
- mandatory markings and warnings are present;
- documentation is available.
Online sales and marketplaces
Section titled “Online sales and marketplaces”Since 2024, the FCC has reinforced surveillance of marketplaces (Amazon, eBay, etc.):
- Platforms must verify FCC registration of listed radio products
- Listings of uncertified equipment can be removed at FCC's request
- International sellers must designate a U.S. Agent to sell directly to US consumers
CISA (Cybersecurity and Infrastructure Security Agency) has been collaborating since 2024 with the FCC to identify non-compliant IoT products sold online.
Reserved ISM bands
Section titled “Reserved ISM bands”47 CFR Part 18 regulates ISM (Industrial, Scientific, Medical) equipment with non-communicational intentional RF emission:
- Microwave ovens (2.4 GHz)
- Induction welding
- Medical diathermy
- Industrial RF heating
ISM frequencies are shared between Part 15 (communication) and Part 18 (energy):
- 6.765-6.795 MHz
- 13.553-13.567 MHz (inductive NFC)
- 26.957-27.283 MHz
- 40.66-40.70 MHz
- 902-928 MHz (used by LoRa, Sigfox, RFID)
- 2400-2483.5 MHz (Wi-Fi, BLE)
- 5725-5875 MHz (Wi-Fi 5 GHz)
- 24-24.25 GHz
This co-usage of ISM bands explains why Wi-Fi equipment is subject to strict power limits (1 W EIRP in 2.4 GHz for example).
Key differences with the EU
Section titled “Key differences with the EU”Three fundamental differences from the RED directive:
- No regulated cybersecurity, the FCC has no equivalent to RED 3.3. Ongoing initiatives (U.S. Cyber Trust Mark program launched in 2024) but voluntary status.
- FCC ID mandatory for Certification, not just DoC, each certified product has a unique searchable identifier in the EAS.
- Different limits in Wi-Fi 2.4 GHz: 1 W EIRP in US vs 100 mW in EU. A full-power US Wi-Fi product does not meet European limits.
To sell the same product on both markets, two separate certifications are required and often two different hardware/software configurations (regional power limitation).
In summary
Section titled “In summary”FCC scope reduces to three questions:
- Does my product emit radio waves (intentionally or not)? If yes, FCC applies.
- Is the emission intentional? If yes, Certification regime (FCC ID required). Otherwise, SDoC.
- Is the equipment placed on the US market? If yes, complete file required with U.S. Agent for non-US manufacturers.
For practical implementation, see 47 CFR Parts and FCC procedure.
Sources & references
- 47 CFR Part 15 Subpart A: General , FCC www.ecfr.gov/current/title-47/chapter-I/subchapter-A/part-15
- FCC Equipment Authorization System (EAS) , FCC apps.fcc.gov/oetcf/eas/reports/GenericSearch.cfm