FCC technical file, FCC ID and labels

Hugues Orgitello updated 7 Oct 2026 14 min read

An FCC certification file is not a free-form dossier: 47 CFR 2.1033 lists the exhibits, the label rules sit in 2.925, 2.935 and 15.19, and the records you keep afterwards are defined in 2.938. Unlike the European technical documentation kept by the manufacturer, a granted FCC application is open to public inspection in the EAS (Equipment Authorization System) except for the exhibits granted confidential treatment. This page reads those sections exhibit by exhibit, then covers the FCC ID, the label, the e-label, the records and what the FCC can do when they are missing.

The exhibits, as 2.1033 lists them

An application for certification is filed on FCC Form 731, with every question answered and items that do not apply marked as such (2.1033(a)). Form 731 is an FCC form; in practice it is submitted through the TCB that reviews the application (see FCC procedure). The technical report differs depending on the rule part.

Exhibit	Parts 11, 15, 18 (2.1033(b))	Other parts, for example licensed transmitters (2.1033(c))
Applicant and US agent for service of process: names, mailing and physical addresses, email, telephone	(b)(1)	(c)(1)
Signed statement that the equipment is not prohibited under 2.903	(b)(2)	(c)(2)
Whether the applicant is on the Covered List	(b)(3)	(c)(3)
Certifications of 2.911(d)(7) (US agent)	(b)(4)	(c)(4)
FCC ID	(b)(5)	(c)(5)
Installation and operating instructions (a draft is accepted, the final document follows)	(b)(6)	(c)(6)
Description of circuit functions and how the device operates, including ground system and antenna	(b)(7)	Not listed as such
Block diagram with the frequency of every oscillator, signal path, tuning ranges and IFs	(b)(8)	Not listed as such
Schematic	Intentional radiators (b)(8)	Circuits that determine and stabilise frequency, suppress spurious radiation, limit modulation and limit power (c)(13)
Emission types, frequency range, power range and maximum power rating, DC voltages and currents of the final RF amplifier, tune-up procedure	Not listed	(c)(7) to (c)(12)
Description of a digital modulation system, including filter response and modulating wave train	Not listed	(c)(16)
Measurement report: test procedure, date, location, device tested, sample calculations	(b)(9)	Data of 2.1046 to 2.1057, measured per 2.1041 (c)(17)
Photographs: exterior, construction, component placement, label (or a sample label with a placement sketch)	(b)(10)	Label photo or drawing (c)(14), construction photos (c)(15)
Peripherals or accessories used in test	(b)(11)	Not listed
Use of the 15.37 transition provisions	(b)(12)	Not applicable
59.0 to 64.0 GHz devices: exhibit for 15.255(g)	(b)(14)	Not applicable
Software defined radio: information of 2.944	(b)(15)	(c)(21)
U-NII devices in 5.15 to 5.35 and 5.47 to 5.85 GHz: high level description of the security that controls RF parameters	(b)(16)	Not applicable
Test set-up drawing or photograph for each type of test	(b)(17)	(c)(24)

Three more rules apply to every application:

RF exposure. An application for an RF source contains a statement confirming compliance with 1.1307(b), 1.1310, 2.1091 and 2.1093, and the technical basis is submitted on request (2.1033(f)). 2.1091 covers mobile devices, used with at least 20 cm normally kept from the body; 2.1093 covers portable devices used closer, which is where SAR data belong. MPE evaluation is the field-strength route of 1.1310 and 2.1091. See the SAR procedures guide.
Composite systems. One application can cover devices certified under several rule parts if they share one FCC ID, with a fee for each device; different FCC IDs need separate applications (2.1033(e)).
Samples. The FCC or the TCB may ask for one or more sample units before grant; if none is supplied, the TCB may dismiss the application without prejudice (2.945(a)).

What 2.1033 does not list: a PTCRB letter, an OTA report, a quick start guide, a safety guide or a risk file. A TCB can ask for more than the list (the October 2020 TCB workshop slides show "cover letters" and "parts list/tune-up" among the exhibits it handles), but those are not FCC exhibits by rule for a Part 15 device.

Confidentiality: what stays out of the public file

Applications and related materials are not routinely available for inspection before the grant takes effect; after that, the application and its materials, including technical specifications and test measurements, are open to inspection on request (0.457(d)(1)(ii)). What stays private is what was granted confidential treatment. The 1.1103 schedule lists a $50 fee for a confidentiality request, and FCC guidance is in KDB 726920. The OET slides of the October 2020 TCB workshop summarise it exhibit by exhibit:

Exhibit	Long-term confidentiality	Short-term confidentiality
ID label and location	No	No
Attestation statements	No	No
Test report	No	No
RF exposure information	No	No
Cover letters	No	No
External photos	No	Yes, 180 days at most from grant
Test set-up photos	No	Yes, 180 days at most from grant
Block diagram, schematics, parts list and tune-up, operational description	Yes, justification required	Yes, 180 days at most from grant
Internal photos	Only under special conditions: parts clearly not accessible to users (enclosed in epoxy, for example), or a device not accessible to the public with an NDA filed	Yes, 180 days at most from grant
User manual	Only under special conditions: a manual for professional technicians bound by an NDA filed with the application	Yes, 180 days at most from grant
SDR software and security information	Automatic	Automatic

The same slides add that long-term confidentiality cannot cover information already known to the public or not held confidential by the grantee, that short-term confidentiality cannot exceed 180 calendar days from the grant date (the alternative is to dismiss and refile later), and that any request outside KDB 726920 needs a PAG inquiry.

The FCC ID

Element	Rule	Text
Grantee Code	Assigned permanently to the party named in the assignment, reused for every later application; the $35 fee (1.1103) must be paid and validated within 30 days or the code is removed	2.926(b), (c)
Grantee Code format	Set by OET: five characters since May 1, 2013 (a digit from 2 to 9, then four capital letters or digits); three-character codes issued earlier remain valid	2.926(c), Public Notice DA 13-669
Product code	Arabic numerals, capital letters and dashes, 14 at most, never used before with the same Grantee Code or in a denied application	2.926(d)
Use	No FCC ID may be used on marketed equipment before a grant validates it; it may not be placed on equipment without the authorization of the grantee	2.926(e)
Change of name or owner	Report it to the FCC, which assigns a new Grantee Code if appropriate	2.926(c)(1)

Lowercase letters are not allowed in either part. The FCC ID, Grantee Code and TCB guide reads 2.926 in detail, and the FCC procedure page covers the Grantee Code request.

Several FCC IDs in one enclosure

2.925(b) lets a device subject to more than one procedure carry a single FCC ID, and requires one when the sections share an enclosure, chassis or board and common frequency-controlling circuits. Sections on separate boards with independent frequency control may carry separate identifiers, labelled TX FCC ID, RX FCC ID and FCC ID for the remaining sections (2.925(b)(1)). When a host integrates separately certified modules, for example Wi-Fi, BLE and cellular, each module keeps its own FCC ID and the host label points to it (see below).

EAS search

Every grant can be looked up in the FCC ID search of the EAS. The grant runs from its publication there (2.915(d)), and the exhibits that did not receive confidential treatment can be consulted there.

The label

Requirement	Text
"FCC ID" in capital letters, followed by the identifier, on a single line	2.925(a)(1)
Type legible without magnification, consistent with the size of the device; never required to be larger than eight-point	2.925(a)(1), (f)
Permanently affixed: etched, engraved, stamped, indelibly printed, or a nameplate welded, riveted or fixed with permanent adhesive that lasts the life of the equipment	2.925(d)(1)
Readily visible: visible from the outside of the enclosure; visible during normal use is preferable but not required	2.925(d)(2)
Other statements of the rule part (for example the Part 15 statement of 15.19(a)(3)) may be on a separate label	2.925(a)(2), 15.19(a)(3)
Devices in several sections connected by wires and marketed together: the 15.19 statement on the main control unit only	15.19(a)(4)
A host using a certified module whose FCC ID is not visible: "Contains FCC ID:" followed by the module FCC ID, or similar wording	15.212(a)(1)(vi)(A)

The rules set no colour requirement. Minimal forms:

FCC ID: <Grantee Code><product code>
Contains FCC ID: <module FCC ID>

Very small devices

Only when a font of four points or larger is impractical and the device has no display that can show an electronic label, the FCC ID goes in the user manual and also either on the packaging or on a removable label attached to the device (2.925(f)); 15.19(a)(5) applies the same rule to the Part 15 statement. A device implanted in a test animal or person is the example the note to 2.925(f) gives.

Electronic label (2.935)

Congress passed the E-LABEL Act on November 26, 2014 (Public Law 113-197). The FCC rule that implements electronic labeling for equipment authorization, 2.935, was published on November 2, 2017 (82 FR 50827), in the SDoC order. OET guidance is in KDB 784748.

Condition	2.935
The device has an integrated electronic display, or works only together with a device that has one	(a)
FCC ID, warning statements and other label information readily accessible on the display; prominent access instructions in the manual, a packaging insert or another format available at purchase (a web site is allowed if the packaging says how to find it, and the instructions go into the application)	(b)
No special codes, accessories or permissions; at most three steps from the device settings menu, not counting screen locks or passcodes	(c)
Clearly legible without magnification	(d)
Programmed by the responsible party and secured so third parties cannot modify it	(e)
The device or its packaging still carries the FCC ID, or other information such as a model number and a web page, so that the device can be identified at importation, marketing and sale; a removable label must survive shipping and handling and be removed only by the customer	(f)

A software defined radio may also show its FCC ID on a user display, with the manual describing how to reach it (2.925(e)). An SDoC compliance information statement can be provided electronically under 2.935 too (2.1077(c)).

SDoC products: what travels with the product

For an SDoC product nothing is filed with a TCB, but a compliance information statement is supplied with the product at marketing or importation: product identification, the compliance statement (15.19(a)(3) for Part 15), and the name, address and telephone or internet contact of the responsible party, which must be in the United States (2.1077(a)). For a product assembled from authorized modular components without further testing, the statement also identifies the components, with the FCC ID of each certified one, and includes copies of the component statements (2.1077(b)). It goes in the user manual or on a separate sheet (2.1077(c)).

Records: what to keep and for how long

Record	Who	Text
Original design drawings and specifications, and all changes that may affect compliance	Every responsible party	2.938(a)(1)
Production inspection and testing procedures	Every responsible party	2.938(a)(2)
Test results that demonstrate compliance	Every responsible party	2.938(a)(3)
SDoC test record: dates, lab, procedure and test equipment, EUT and support equipment, cables, at least two set-up photos or drawings, modifications made to pass, signatures, copy of the 2.1077 statement	SDoC responsible party	2.938(b)(1)
Signed statement that the SDoC equipment is not produced by a Covered List entity	SDoC responsible party	2.938(b)(2)
Records under every procedure that applies to a composite device	Responsible party	2.938(d)
Which transition provisions applied	Responsible party	2.938(e)
Changes made by a party other than the original responsible party	The modifying party	2.938(g)

How long. For certification, one year after marketing of the equipment is permanently discontinued, or until the end of an investigation or proceeding the responsible party has been notified of; for all other records, a two-year period (2.938(f)). A contract manufacturer that keeps the records satisfies the grantee obligation (2.938(c)).

When the FCC asks. Records must be sent within 21 days of an FCC request, failing which a forfeiture may follow (2.945(c)); samples or marketplace vouchers are also due within 21 days (2.945(b)); and the responsible party makes its plant available for inspection on request (2.945(d)). A TCB may request samples of equipment it certified for post-market surveillance (2.945(b)(2)).

Changes after the grant

Class	2.1043(b)	What the file needs
Class I	Changes that do not degrade the characteristics reported and accepted at grant	No filing; the change is recorded in the 2.938(a)(1) design records
Class II	Changes that degrade the reported performance characteristics while still meeting the rules	Filing with test results for the affected characteristics and the 2.932(e) statements; 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

Class I and Class II changes are made only by the grant holder (2.1043(b)(4)), and no class may change the FCC ID. Changes to the frequency determining and stabilizing circuitry, frequency multiplication, the basic modulator or the maximum power or field strength ratings need a new application (2.1043(a), 2.932(a)), except Class III changes. A new grant carries a product code not used before (2.926(d)). From October 13, 2026, FCC 26-50 adds that changes by a Covered List entity, or that would make the device covered equipment, need a new grant (see FCC procedure). The Class II permissive change guide covers the workflow.

Software and security exhibits

A software defined radio must only load software approved with it and must not let the user operate outside the approved frequencies, power or modulation; the application describes the means used (signed software, authenticated private network, hardware coding) and includes a high-level operational description or flow diagram of the software controlling RF parameters (2.944). Separately, 15.407(i) requires every U-NII device to carry security features against unauthorized software changes, while 2.1033(b)(16) asks for the security description exhibit only for 5.15 to 5.35 and 5.47 to 5.85 GHz devices. Standard power access points and fixed clients in the 6 GHz band that are controlled by an AFC system have their own security obligations (15.407(k)(8)(v)).

Sanctions

Measure	Text
Revocation of the grant for false statements, non-conformity with the application, unauthorized changes, or conditions that would justify refusing it	2.939(a)
Revocation when the application falsely stated the equipment was not covered equipment	2.939(d)
Limits on existing authorizations of covered equipment, after a public notice and at least 30 days of comment	2.939(e)
Suspension of pending applications when a grantee fails to supply a sample within 21 days	2.945(a)(4), (b)(5)
Forfeiture: base amounts of $7,000 for importation or marketing of unauthorized equipment, $7,000 for failure to permit inspection, $1,000 for failure to maintain required records	1.80(b)(11), table 1
Forfeiture ceiling in the current eCFR (2025 inflation adjustment): $25,132 per violation or per day of continuing violation, $188,491 for any single act or failure to act	1.80(b)(10)

The base amounts are guidelines that the FCC can raise or lower; the ceilings are adjusted for inflation each year.

Claims the texts contradict

Common claim (several made by this page before October 2026)	What the text says
An FCC file has "8 to 12 standardised documents", or 17 including a quick start guide and a safety guide	2.1033(b) lists 16 numbered items plus a reserved one for Part 15; some apply only to certain devices, and quick start or safety guides are not among them
Form 731 is the TCB electronic form	FCC Form 731 is the FCC application form (2.1033(a)), submitted through the TCB
The user manual is always public	It can get long-term confidentiality under special conditions, for example a manual for professionals bound by an NDA (KDB 726920, October 2020 TCB workshop)
Short-term confidentiality is "typically 180 days"	180 calendar days from the grant is the maximum, not a typical value
E-label is allowed "since 2014"	The E-LABEL Act dates from November 26, 2014; the rule, 2.935, was published on November 2, 2017
E-label: three steps from the main menu, and a physical label on the packaging	Three steps from the device settings menu, screen locks not counted (2.935(c)); the device or packaging must carry the FCC ID or other identifying information such as a model number and a web page (2.935(f))
A very small device just puts its FCC ID on packaging and manual	Only if a four-point font is impractical and there is no display; then the manual plus the packaging or a removable label (2.925(f))
The label has no minimum size but must be in a contrasting colour	No colour rule; the type must be legible without magnification and need never exceed eight-point (2.925(a)(1), (f))
A Class II permissive change covers an antenna "with equivalent or lesser gain" and costs a known range	2.1043(b)(2) defines Class II as a degradation of reported characteristics that still complies; it names no antenna case and no price
Records include every intermediate test and retest	2.938(a) lists design records and changes, production test procedures and test results that demonstrate compliance; no rule asks for intermediate tests
Co-located transmitters need "co-existence tests" and a documented minimum antenna distance	No such exhibit in 2.1033; what the rules address is one or several FCC IDs (2.925(b)) and the RF exposure statement (2.1033(f))
The FCC orders formal recalls of non-compliant products	The texts provide revocation and limitation of grants (2.939), sample and record demands (2.945) and forfeitures (1.80)