FCC certification, scope and applicability

Author Hugues Orgitello Last updated 12 July 2026 ~7 min read

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

47 CFR Part 15 distinguishes three main equipment categories:

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

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

Pure receivers are regulated under certain conditions (Section 15.101):

TV and FM broadcast receivers: SDoC (or optional Certification)
Scanning receivers and radar detectors: Certification mandatory
Only receivers tuning between 30 and 960 MHz (plus CB receivers and radar detectors) are subject to authorization
Receivers operating above 960 MHz, such as GPS / GNSS, are exempt from authorization but remain subject to the non-interference condition (Section 15.5)

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)	LPI indoor, AFC for Standard Power
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

Several unintentional equipment categories are exempted from SDoC by Section 15.103 and require no tests or file:

Digital devices whose highest clock frequency is below 1.705 MHz and which cannot operate from (or be charged on) AC mains
Digital devices used exclusively in transportation vehicles, including cars and aircraft
Control or power systems used by a public utility or in an industrial plant
Industrial, commercial or medical test equipment
Digital circuits used exclusively in appliances (microwave ovens, dishwashers, air conditioners, etc.)
Specialised medical digital devices used under the supervision of a licensed practitioner
Devices consuming less than 6 nW

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)

The FCC has a specific procedure for radio modules intended for integration into other products. Documented by Section 15.212 and KDB 996369 (Module Certification Guide), it distinguishes:

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

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

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

Any equipment imported to the US must respect FCC rules. Obligations differ by status:

US-established manufacturer

The manufacturer directly assumes responsibilities: tests, TCB submission, DoC signature or FCC ID assignment.

Non-US manufacturer

Must designate a U.S. Agent for Service of Process established in the US. This agent:

is reachable for FCC inquiries;
accepts legal service of process on behalf of the manufacturer;
is identified (name, address, contact details) in the certification application submitted to the TCB.

Since February 2023, the FCC requires this designation in every certification application: without a U.S. Agent for Service, the FCC ID is not assigned. For SDoC, the responsible party itself must be located in the US (47 CFR 2.909).

Importers

Importers verify that:

the equipment carries the appropriate FCC ID;
mandatory markings and warnings are present;
documentation is available.

Online sales and marketplaces

Since 2024, the FCC has stepped up enforcement against online sales of unauthorised radio equipment:

In March 2024, FCC commissioners sent letters to major retailers (Amazon, Walmart, Temu, Shein, etc.) about listings of insecure or unauthorised devices, and the FCC opened an investigation into Amazon over listings of signal jammers
Listings of uncertified equipment are removed under FCC pressure; the FCC reported millions of non-compliant listings taken down by retailers in 2025
The main platforms require, as a marketplace policy, a valid FCC ID for radio products in their listings

There is no general legal obligation on marketplaces to verify FCC registration yet, but in practice a missing FCC ID blocks or removes a listing.

Covered equipment: the security prohibition

Since 6 February 2023, the FCC no longer grants any equipment authorization for "covered" equipment on its Covered List (FCC 22-84 order under the Secure Equipment Act of 2021; the list itself stems from the Secure and Trusted Communications Networks Act of 2019 and is published at fcc.gov/supplychain/coveredlist). The scope is two-tiered:

Huawei and ZTE (including subsidiaries and affiliates): all telecommunications and video surveillance equipment is covered, whatever the intended use.
Hytera, Hikvision and Dahua (including subsidiaries and affiliates): video surveillance and telecommunications equipment is covered when intended for public safety, government facilities, critical infrastructure surveillance or other national security purposes.

Every certification applicant must attest that the equipment is not covered equipment and, since the same order, designate a US-based agent for service of process. The FCC OET details the mechanics in KDB 986446 (Covered Equipment Guidance).

The programme keeps tightening: the "Bad Labs" order (FCC 25-27, adopted 22 May 2025) bars test labs, TCBs and accreditation bodies owned or controlled (10 % equity or more) by prohibited entities, foreign adversaries included, from the equipment authorization programme, with ownership-disclosure duties for every participating lab. For a European manufacturer the practical impact is indirect but real: component sourcing (modules, cameras) and the choice of test laboratory both need a check against these lists.

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)
2400-2500 MHz (of which 2400-2483.5 MHz is used by 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 conducted in 2.4 GHz for example).

Key differences with the EU

Three fundamental differences from the RED directive:

No regulated cybersecurity, the FCC has no equivalent to RED 3.3. The voluntary U.S. Cyber Trust Mark label (rules adopted by the FCC in 2024) is still being rolled out in 2026 and does not yet accept product applications.
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 conducted power (up to 4 W EIRP with a 6 dBi antenna) in the US vs 100 mW EIRP in the 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

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.