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FCC file and FCC ID

FCC · Pillar

The FCC file submitted to the TCB comprises 8 to 12 standardised documents. Unlike the European file kept by the manufacturer, the FCC file is published in the EAS (Equipment Authorization System) with partial public access, internal schemas typically remaining confidential but photos and manuals accessible.

The FCC ID consists of two parts:

<Grantee Code><Product Code>
  • Grantee Code: 5 alphanumeric characters, assigned once for life by the FCC to the certificate holder (cost: $60).
  • Product Code: 1 to 14 characters chosen by the holder (letters, digits, hyphens).

Examples:

2AB4Z-SP-CT-100
RYK-SPCT-100
A3LSM-J100

Any FCC ID can be searched publicly in the Equipment Authorization System:

https://apps.fcc.gov/oetcf/eas/reports/GenericSearch.cfm

The search reveals:

  • The grantee (manufacturer or certificate holder)
  • Assignment date
  • Authorised frequencies and powers
  • Public documents: photos, manuals, some test reports

Confidential documents (internal schemas, detailed functional description) are protected by a Letter of Confidentiality submitted during certification.

Manufacturers can request permanent confidentiality for certain documents (typically schemas, detailed functional descriptions). The request is made via a Letter of Confidentiality signed by the grantee, submitted to the TCB with the file.

Documents that may be protected:

  • Internal schemas
  • Detailed block diagram
  • Proprietary modulation descriptions
  • Technical trade secrets

Always public documents:

  • External photos
  • User manual
  • Label sample
  • Cover letter (non-confidential summary)

A short-term confidentiality (180 days typically) may also be requested for products with future launch, but it expires automatically.

  1. Form 731 (Application for Equipment Authorization): TCB's electronic form
  2. Cover letter describing the product, radio modes, tested configurations
  3. Grantee authorization letter if submitter differs from grantee (e.g. consultant)
  4. Letter of Confidentiality (optional)
  1. Test report signed by an accredited lab, covering all applicable Parts
  2. Block diagram electrical and functional
  3. Schematics detailed
  4. Operational description, explanation of radio modes, modulations, protocols
  5. Antenna specifications, gain, pattern, impedance
  1. External photos, external views of the product from all angles
  2. Internal photos, disassembled product with FCC ID label visible and RF components identifiable
  3. Label sample, image of the label with FCC ID and warnings
  1. User manual complete, with Part 15.19 / 15.105 / 15.21 mentions as applicable
  2. Quick start guide if separately provided
  3. Safety guide if applicable
  1. SAR report for worn equipment
  2. MPE evaluation for fixed equipment (often simple documentary calculation)

The FCC ID must appear legibly and indelibly:

  • Minimum height: no absolute minimum, but must be legible at normal use distance.
  • Indelibility: not removable by normal use or light cleaning.
  • Colour: contrasting with background.
  • Position: visible without disassembling the product.
FCC ID: 2AB4Z-SP-CT-100

Or for products containing a certified module:

Contains FCC ID: <module FCC ID>

For products with screen, e-label is admitted per KDB 784748:

  • FCC ID displays via menu accessible in 3 clicks maximum from main menu
  • Menu must be in English (at least)
  • Access must not require password or login
  • A physical label remains mandatory on packaging

For products too small to carry the FCC ID:

  • FCC ID appears on packaging and manual
  • A removable label may be attached for initial sale

The file is:

  • Published in EAS (public part) by the TCB
  • Retained by the holder (Grantee) for 10 years after last unit produced
  • Available to FCC on request for inspection

Retention includes all test reports, even those not submitted (intermediate tests, retests). In case of Permissive Change (modification), complete history must be maintained.

Permissive Changes, modifications after certification

Section titled “Permissive Changes, modifications after certification”

Three classes of modifications after FCC ID assignment:

Modifications without RF impact:

  • Cosmetic changes (colour, design)
  • Equivalent non-RF component changes
  • Software modifications without radio impact

No TCB resubmission required. To be documented in internal file.

Modifications with limited RF impact:

  • Antenna change (with equivalent or lesser gain)
  • Minor radio software modification
  • Equivalent RF component change

TCB resubmission required but simplified (no new FCC ID, simple amendment). Typical cost: $2,000 to $6,000.

Substantial modifications:

  • Band change
  • New modulation
  • Power increase
  • Radio architecture modification

Equivalent to a new complete certification with its tests and new FCC ID.

The FCC may conduct audits on marketed products:

  • Verification of FCC ID affixing
  • Verification of consistency with submitted file
  • Compliance tests on samples (Market Surveillance)

Non-compliance sanctions include:

  • Cease and desist marketing-stop order
  • Recall product recall
  • Forfeitures fines (up to $115,000 per day per violation in 2026)
  • Revocation FCC ID withdrawal

A voluntary recall procedure is generally preferable to the formal FCC procedure.

When multiple transmitters coexist in the same product (Wi-Fi + BLE + cellular), co-existence tests may be required:

  • Maximum simultaneous emission complying with individual limits
  • No excessive mutual degradation
  • Documentation of minimum distance between antennas

For SDRs with software-modifiable radio configurations, documentation includes:

  • List of authorised configurations (bands, powers, modulations)
  • Protection mechanisms against unauthorised configurations
  • Signed software update procedure

These points are minor in the US compared to the EU (RED 3.3), but the FCC is starting to publish KDBs on the topic (notably for 6 GHz AFC).

Sources & references

  1. FCC Equipment Authorization System (EAS) , FCC apps.fcc.gov/oetcf/eas/reports/GenericSearch.cfm
  2. KDB 784748, e-label , FCC apps.fcc.gov/oetcf/kdb/