FCC scope: which devices need authorization

Hugues Orgitello updated 7 Oct 2026 14 min read

FCC equipment authorization does not hinge on whether a product "has a radio". It hinges on how the product generates radio frequency energy (intentionally, unintentionally or incidentally, as defined in 47 CFR 15.3), on the authorization route the rule part assigns to it (Certification or Supplier's Declaration of Conformity, 47 CFR Part 2 Subpart J), and, since 2023, on who produced it and its parts (the Covered List). This page maps those boundaries section by section, with the import conditions and the online marketplace duties that apply from 2027.

Three kinds of radiators

47 CFR 15.1 says Part 15 governs the operation without an individual licence of intentional, unintentional and incidental radiators, and that marketing one that does not comply, "including prior equipment authorization, as appropriate", is prohibited under section 302 of the Communications Act. The definitions in 15.3 decide which regime applies.

Category (47 CFR 15.3)	What the definition says	Typical examples	Authorization
Intentional radiator, 15.3(o)	Intentionally generates and emits RF energy by radiation or induction	Wi-Fi, BLE, Zigbee, LoRa, NFC readers, UWB, remote controls	Certification by a TCB (15.201(b)), with a few SDoC exceptions (15.201(a))
Unintentional radiator, 15.3(z)	Generates RF energy for use within the device, or sends RF signals by conduction over wiring, but is not intended to emit by radiation or induction	Computers, peripherals, power supplies, any "digital device" (timing signals above 9,000 pulses per second, 15.3(k)), receivers	Mostly SDoC or Certification at the choice of the responsible party (15.101)
Incidental radiator, 15.3(n)	Generates RF energy during operation although not designed to generate or emit it	DC motors, mechanical light switches	No authorization; good engineering practice (15.13)

Two consequences are often missed. First, a radio product usually contains a digital device too: 15.3(k) only exempts it from the digital device limits when that circuitry is "used only to enable operation" of the radio, so a host with its own processor, display or interfaces still needs its Part 15 Subpart B authorization. Second, every category, exempt or not, operates under 15.5: no harmful interference, and acceptance of interference from licensed stations, other Part 15 devices and ISM equipment.

Authorization route by device type

47 CFR 2.906 defines SDoC (the responsible party tests, no filing with the FCC unless a sample is requested under 2.945) and 2.907 defines Certification (a grant issued by a TCB or the FCC on submitted test data, attached to identical units). 2.906(c) lets any SDoC device be certified instead. The rule parts then assign the route:

Device type	Route	Section
Scanning receiver, radar detector	Certification	15.101(a)
TV, FM and CB broadcast receivers, superregenerative receivers, other receivers subject to Part 15	SDoC or Certification	15.101(a)
TV interface devices, cable system terminal devices	SDoC or Certification	15.101(a)
Class B personal computers, peripherals, CPU boards and internal power supplies for them	SDoC or Certification	15.101(a)
Class B external switching power supplies, other Class B digital devices	SDoC or Certification	15.101(a)
Class A digital devices, peripherals and external switching power supplies	SDoC or Certification	15.101(a)
Access Broadband over Power Line	Certification	15.101(a)
Intentional radiators in general	Certification	15.201(b)
Carrier current systems, devices under 15.211, 15.213 and 15.221, devices below 490 kHz with all emissions 40 dB under the 15.209 limits	SDoC	15.201(a)
Consumer ISM equipment	SDoC or Certification	18.203(a)
Non-consumer ISM equipment, consumer ultrasonic equipment under 500 W operating below 90 kHz	SDoC	18.203(b)
Any equipment produced by a Covered List entity	Certification only (and prohibited if covered)	2.906(d), 2.907(c), 15.103(j), 2.903

Class A means marketed for commercial, industrial or business use and not to the general public (15.3(h)); Class B means marketed for residential use, even if also used elsewhere (15.3(i)). The class follows the marketing, not the intended customer's opinion.

Receivers

Under 15.101(b), only receivers that tune within 30 to 960 MHz, plus CB receivers and radar detectors, need the authorizations in the table. Receivers operating above 960 MHz or below 30 MHz (a GNSS receiver, for example) are exempt from the technical provisions of Part 15 but remain subject to 15.5.

Subassemblies and peripherals

15.101(d)(1) needs no authorization for a peripheral or subassembly sold to a manufacturer for further fabrication: that manufacturer authorizes the end product. Under 15.101(e), subassemblies of digital devices (boards fully enclosed in the host, non-PC CPU boards sold without enclosure or power supply, internal switching power supplies for non-PC devices) are not subject to the technical standards unless marketed as part of a system. Personal computer CPU boards and power supplies are the exception and keep their own row in the table above.

Intentional radiators: where the technical rules sit

Part 15 Subpart C holds most unlicensed transmitter rules; licensed services have their own parts.

Technology	Rule	Note
Wi-Fi 2.4 GHz, Bluetooth, BLE, many 902-928 MHz LPWAN and RFID radios	15.247	Digital modulation or frequency hopping; 1 W peak conducted output in 902-928, 2400-2483.5 and 5725-5850 MHz with antennas up to 6 dBi, reduced dB for dB above that (15.247(b)(3) and (b)(4))
Low-power transmitters in 902-928 MHz and other listed bands	15.249	Field strength limits, no spread spectrum requirement
Wi-Fi 5 GHz (U-NII-1 to U-NII-4)	15.407, Subpart E	DFS applies in U-NII-2A and U-NII-2C
Wi-Fi 6 GHz (5.925-7.125 GHz)	15.407, Subpart E	Device classes in the rule: standard power under AFC, low-power indoor, very low power (14 dBm e.i.r.p. maximum), fixed client and geofenced variable power
NFC and other 13.56 MHz devices	15.225	13.553-13.567 MHz
UWB	Part 15 Subpart F	Ultra-Wideband Operation
Cellular (2G to 5G)	Parts 22, 24, 27, 96 (CBRS) and 30 (mmWave UMFUS), by band	Licensed services, Certification under Part 2

Section numbers above come from the current eCFR; the detailed limits and test methods are on 47 CFR Parts and FCC tests.

Part 15 exemptions (15.103)

An exempt digital device is "subject only to the general conditions of operation in §§ 15.5 and 15.29" and is exempt from the technical standards and other requirements of Part 15. The FCC can order it shut down if it causes harmful interference, and the rule adds: "Although not mandatory, it is strongly recommended" that the manufacturer meet the technical standards anyway.

Paragraph	Exempt device	Limit of the exemption
(a)	Digital device used exclusively in a transportation vehicle, including motor vehicles and aircraft	Exclusively in the vehicle
(b)	Electronic control or power system used by a public utility or in an industrial plant	Utility equipment only in a dedicated building or large room of the utility, not at a subscriber's premises
(c)	Industrial, commercial or medical test equipment	Exclusively test equipment
(d)	Digital device used exclusively in an appliance (microwave oven, dishwasher, clothes dryer, air conditioner)	The digital circuitry must serve only the appliance
(e)	Specialized medical digital device used at the direction or under the supervision of a licensed health care practitioner	Retail medical devices for the general public, and record keeping functions, are not exempt
(f)	Digital device consuming 6 nW or less
(g)	Joystick, mouse or similar with only non-digital circuitry or a simple conversion circuit	Treated as a passive add-on
(h)	Highest frequency generated and used below 1.705 MHz, and no AC mains operation	Lost if the device can run while charging, uses an AC adaptor or battery eliminator, or draws power through another mains-powered device
(i)	Equipment with several devices	Exempt only if every device in it qualifies
(j)	Equipment produced by a Covered List entity	Never exempt: certification rules apply

Separately, 15.23 needs no authorization for home-built devices that are not marketed, not built from a kit and built in quantities of five or fewer for personal use.

Radio modules (15.212)

15.212(a) defines two kinds of modular transmitter. A single modular transmitter is a self-contained transmitter with its own shielding, buffered data inputs, its own power supply regulation and an approved antenna (permanently attached or using a unique coupler), tested stand-alone. A split modular transmitter has a radio front end with antenna and a separate transmitter control element, joined by a digital interface of at least 150 mV peak-to-peak and designed so that only parts approved together can operate together. 15.212(b) allows a limited modular approval for modules that miss some of these requirements, or whose RF exposure compliance is shown only for particular host configurations.

Where the module FCC ID is not visible once installed, the host must carry a label such as "Contains FCC ID: XYZMODEL1" (15.212(a)(1)(vi)). The OET guidance on integration is KDB 996369. Since FCC 25-71 (effective 26 December 2025), 2.903 also bars authorization of a covered modular transmitter, of a module that could be certified as one, and of any host product that incorporates one.

Who is responsible, and where

Role	Rule	Requirement
Grantee (Certification)	2.909(a)	Responsible for compliance; a party modifying the device outside the grantee's authority becomes responsible
SDoC responsible party	2.909(b)	Must be located in the United States: the manufacturer or assembler, or the importer for imported equipment; a retailer or OEM can take over by agreement
Agent for service of process	2.911(d)(7)	Every applicant for Certification designates an agent located in the United States; a US-located applicant may designate itself; the agent must be maintained for at least one year after marketing and importation end, or after any related FCC proceeding ends, whichever is later
Applicant attestations	2.911(d)(5) and (6)	Signed statement that the equipment is not prohibited under 2.903 and whether the applicant is on the Covered List, renewed if the list changes before grant

The agent requirement and the attestations come from FCC 22-84 (adopted 11 November 2022, effective 6 February 2023). They apply to permissive changes as well (2.932(e)).

Importing into the United States

2.1203 bars importing a radio frequency device unless the importer, the ultimate consignee or their customs broker determines that it meets one of the 2.1204 conditions, and that party must document the basis on request within one year of entry.

2.1204(a)	Import condition	Quantity
(1)	Device covered by a valid FCC equipment authorization not limited under 2.939(e)
(2)	Device that needs no authorization and complies with the technical and administrative rules
(3)	Testing, evaluation, product development or market suitability, not for sale	4,000 units or fewer per model without OET approval
(4)	Demonstration at trade shows, not for sale	400 units or fewer without OET approval
(5)	Import solely for export
(6)	Exclusive use by the US Government
(7)	Personal use, not for sale, limited categories	Three or fewer
(8)	Repair
(11)	Pre-sale activity for a device whose Certification application is already filed with a TCB after testing by a recognized lab, with a temporary label and 60 months of records	12,000 units or fewer per FCC ID without OET approval

Online marketplaces from 2027

FCC 26-50 (Third Report and Order, adopted 22 July 2026, published at 91 FR 57798 on 11 September 2026, effective 13 October 2026) amends the marketing rule, 2.803:

listing regulated equipment on an online marketplace, combined with consignment, warehousing, order processing, packaging, billing or fulfilment services, counts as marketing even when a third-party seller makes the sale (2.803(a)(1));
a marketplace that sells the device itself, or has physical access to or title over a third-party seller's device, must display a valid and accurate FCC ID at the point of sale, with compliance required from 1 March 2027 (2.803(c)(1));
a marketplace without physical access or title must display a valid FCC ID, verify it against the Equipment Authorization System and require the seller to certify it, from 1 June 2027 (2.803(c)(2));
listings published before 13 October 2026 and not later updated, listings by sellers that are not "high-volume third-party sellers" under the INFORM Consumers Act, and used devices are excluded (2.803(c)(3)).

Covered equipment: the national security layer

2.903 prohibits any equipment authorization (Certification, SDoC or otherwise exempt) for equipment on the Covered List kept under 47 CFR 1.50002. FCC 22-84 explains that the list initially named equipment from five producers and their subsidiaries and affiliates: "telecommunications equipment" and "video surveillance equipment" produced by Huawei and ZTE, and the same equipment from Hytera, Hikvision and Dahua to the extent used for public safety, security of government facilities, physical security surveillance of critical infrastructure or other national security purposes. FCC 26-50 records later additions for uncrewed aircraft systems, UAS critical components and routers "produced in a foreign country" (see Covered List: all foreign-made drones added).

Date	Instrument	What changed
6 February 2023	FCC 22-84, 88 FR 7592	Covered equipment barred from authorization; Covered List producers forced onto Certification; US agent for service of process and Covered List attestations for every applicant
8 September 2025	FCC 25-27, 90 FR 38045 (adopted 22 May 2025)	TCBs, test labs and accreditation bodies owned (10% or more of equity or votes), controlled or directed by a prohibited entity lose recognition, and SDoC testing may not be done in such labs (2.906(a)(1)); interests of 5% or more must be reported; some provisions delayed pending approval
26 December 2025	FCC 25-71, 90 FR 53227	Covered modular transmitters, and hosts incorporating them, barred; procedure to limit earlier grants to stop further import and marketing
15 June 2026	FCC 26-28, 91 FR 27843	Fast-track review for devices tested in trusted test labs, post-market surveillance updates, consolidated list of prohibited entities; some provisions delayed
13 October 2026	FCC 26-50, 91 FR 57798	Devices incorporating a logic-bearing hardware component produced by a Covered List entity barred where the whole device would be; any change by a Covered List entity needs a new Certification and no SDoC; marketplace rules above

The logic-bearing component rule applies to new applications only; applications pending on 13 October 2026 are exempt unless amended to add or change such a component, and it does not reach production-location entries such as foreign-made UAS or routers unless the producer is itself listed. For a manufacturer outside the United States, the practical checks are therefore component sourcing (modules, cameras, any logic-bearing part from a listed producer) and the ownership of the test lab and TCB. See also FCC test labs: fast track and new disclosures and FCC brings radio modules into the Covered List.

ISM equipment (Part 18)

Part 18 covers equipment that generates and uses RF energy locally for industrial, scientific, medical, domestic or similar purposes, excluding telecommunication (18.107(c)): microwave ovens, industrial heating, medical diathermy, ultrasonic equipment, magnetic resonance equipment. 18.301 designates these ISM frequencies:

ISM frequency	Tolerance	Resulting band
6.78 MHz	±15 kHz	6.765-6.795 MHz
13.56 MHz	±7 kHz	13.553-13.567 MHz
27.12 MHz	±163 kHz	26.957-27.283 MHz
40.68 MHz	±20 kHz	40.66-40.70 MHz
915 MHz	±13 MHz	902-928 MHz
2450 MHz	±50 MHz	2400-2500 MHz
5800 MHz	±75 MHz	5725-5875 MHz
24.125 GHz	±125 MHz	24.0-24.25 GHz
61.25 GHz	±250 MHz	61.0-61.5 GHz
122.5 GHz	±500 MHz	122-123 GHz
245 GHz	±1 GHz	244-246 GHz

Part 15 radios in these bands share them with ISM equipment on unequal terms: 15.5(b) makes Part 15 devices accept interference from ISM equipment, and 18.111(c) relieves an ISM operator of the duty to cure interference to radio devices operating in an ISM band.

Key differences with the EU

Prior authorization instead of self-declaration for radios. The RED lets a manufacturer self-assess radio equipment when it fully applies harmonised standards; under 15.201(b) an intentional radiator generally needs a grant from a TCB, and its FCC ID is publicly searchable in the EAS.
A US presence. SDoC requires a responsible party located in the United States (2.909(b)) and Certification requires a US agent for service of process (2.911(d)(7)).
Cybersecurity is voluntary. The FCC has no mandatory equivalent of RED Article 3(3)(d)(e)(f). The U.S. Cyber Trust Mark is a voluntary label (FCC 24-26, rules effective 29 August 2024); UL Solutions withdrew as Lead Administrator effective 19 December 2025 and the ioXt Alliance was selected on 13 April 2026. See NISTIR 8425.
Supply chain rules attach to the producer. The Covered List rules above have no counterpart in the EU conformity assessment.

The RF limits differ band by band, so a product sold on both markets usually needs separate test campaigns and region-specific power settings; see CE vs FCC for EMC.

Claims the texts contradict

Common claim (including earlier versions of this page)	What the text says
Exempt devices "must still respect emission limits"	15.103 exempts them from the technical standards; only 15.5 and 15.29 apply, and meeting the limits is "strongly recommended", not mandatory
Microcontroller-based home appliances need an SDoC	15.103(d) exempts a digital device used exclusively in an appliance; a separate function (Wi-Fi, a user-facing computer) falls outside the exemption under 15.103(i)
Only non-US manufacturers need a US agent	2.911(d)(7) applies to every applicant for Certification; a US-located applicant may designate itself
Split modular approval is for RF parts spread over several boards and needs a Class II permissive change by the integrator	15.212(a)(2) defines it as a radio front end plus a separate control element, approved together; nothing requires a Class II change by the integrator
A single modular approval depends on "isolation distance, thermal and ground plane conditions"	15.212(a)(1) lists shielding, buffered inputs, power regulation, antenna, stand-alone testing, labelling, instructions and RF exposure
No legal obligation on marketplaces regarding FCC IDs	FCC 26-50 makes marketplaces display FCC IDs from 1 March 2027 or 1 June 2027, and treats listing plus fulfilment services as marketing
Wi-Fi power limits are strict because ISM bands are shared	15.247 sets the power limits without reference to ISM sharing; the sharing shows up instead as the 15.5(b) duty to accept ISM interference and the 18.111(c) relief for ISM operators
A Covered List producer can still use SDoC for low-risk products	2.906(d) and 2.907(c) force Certification, and 2.903 bars covered equipment altogether

In summary

Which radiator is it? Intentional, unintentional or incidental under 15.3, and often more than one in the same product.
Which route does the rule part assign? Certification for most transmitters, SDoC or Certification for most digital devices and receivers, nothing for incidental radiators and exempt devices.
Who produced it and its parts? Covered List producers, their modules and, from 13 October 2026, their logic-bearing components change the answer to "Certification" or "no authorization at all".
How does it enter and get sold? A 2.1204 import condition, a US responsible party or agent, and an FCC ID on marketplace listings from 2027.

For practical implementation, see 47 CFR Parts, FCC procedure, technical file and common pitfalls.