FCC ID, Grantee Code & TCB: equipment authorization

Hugues Orgitelloupdated 7 Oct 202616 min read

An FCC ID is not a product number the manufacturer invents. It is two elements in a fixed order, a Grantee Code the FCC assigns once per company and a product code of 14 characters at most, and it only becomes valid when a TCB publishes a grant of certification. This page reads the sections of 47 CFR Part 2 Subpart J and Part 15 that build that identifier, the role of the TCB, the label, modular approval and permissive changes, with the changes made by the 2023 to 2026 Covered List and TCB integrity orders.

Two procedures, one rulebook

The rules live in 47 CFR Part 2 Subpart J. For the devices this page covers, Subpart J offers two procedures:

• SDoC (Supplier's Declaration of Conformity, 2.906): the responsible party makes the measurements and keeps the records. Nothing is filed with the FCC unless a sample or data is requested under 2.945.
• Certification (2.907): a grant "approved by the Commission or issued by a Telecommunication Certification Body (TCB)", based on the test data the applicant submits. It attaches to every unit marketed by the grantee that is identical to the sample tested, except for permissive changes under 2.1043.

The route is set by the rule part, not chosen freely, which is the US counterpart of the split discussed in self-declaration vs Notified Body. 2.906(c) lets any SDoC device be certified instead, and since FCC 22-84 equipment produced by an entity on the Covered List can only use Certification (2.906(d), 2.907(c)).

Unintentional, intentional and incidental radiators

Device class (47 CFR 15.3)	Definition	Procedure	Typical examples
Unintentional radiator	Generates RF energy for use inside the device, or sends it by conduction over wiring, but is not intended to emit by radiation or induction	Mostly SDoC or Certification at the choice of the responsible party (15.101)	Computers, peripherals, power supplies, receivers
Intentional radiator	Intentionally generates and emits RF energy by radiation or induction	Certification (15.201(b)), with a few SDoC exceptions in 15.201(a)	Wi-Fi, Bluetooth, sub-GHz, UWB transmitters
Incidental radiator	Generates RF energy during operation although not designed to	No authorization; good engineering practice (15.13)	DC motors, mechanical light switches

A connected product usually holds a radio and a digital device. The radio needs Certification. The digital part is only exempt from the digital device rules when its circuitry is "used only to enable operation" of the radio (15.3(k)); otherwise it needs its own Part 15 Subpart B authorization. 2.925(b) allows a device subject to more than one procedure to carry a single FCC ID. FCC scope maps these boundaries section by section, and the FCC procedure covers the full route.

What SDoC requires

Requirement	Section	What the text says
Responsible party	2.909(b)	Located in the United States: the manufacturer or assembler, or the importer for imported equipment
Test lab	2.906(a)(1), 2.948	No accreditation required for SDoC, unlike Certification (2.948(a)); since FCC 25-27, testing may not be done in a lab owned, controlled or directed by a prohibited entity
Identification	2.1074	A unique identification chosen by the responsible party, in a format that cannot be confused with an FCC ID; the SDoC logo is voluntary
Compliance information	2.1077	Supplied with the product: product identification, compliance statement, and the name, address and telephone or internet contact of the US responsible party
Label statement	15.19(a)	The Part 15 compliance statement, which applies to SDoC and certified devices alike
Records and samples	2.938, 2.945	Records and samples supplied on request, within 21 days

Identity: FRN, Grantee Code, FCC ID

Step 1, the FRN

The FRN (FCC Registration Number) is "a 10-digit unique identifying number" assigned to entities doing business with the Commission, obtained through CORES (47 CFR 1.8001). Registration asks for the entity name, contact, address, email and taxpayer identifying number, to be updated within 10 business days of any change (1.8002(b)). The FRN is not specific to equipment authorization.

Step 2, the Grantee Code

The Grantee Code is requested electronically through the Equipment Authorization System, at any time before the first application (2.926(c)). What the texts fix:

Point	Text	What it says
Format	2.926(c)	Specified by the Office of Engineering and Technology, not by the rule itself
Five-character codes	DA 13-669	Issued since 1 May 2013: a digit from 2 to 9, then four capital letters or digits from 2 to 9
Three-character codes	DA 13-669, April 2013 TCB workshop	No longer issued; codes already issued and paid for remain usable; they start with a letter
Fee	2.926(c), 1.1103	Must be paid and validated within 30 days of issuance, or the code is removed and a new one must be obtained
Permanence	2.926(b), (c)(1)	Assigned permanently, valid only for the party named in the assignment, reused for every later application
Name or ownership change	2.926(c)(1), 2.929	Reported to the FCC so that a new code can be assigned "if appropriate"; name and address changes within 30 days, transactions within 60 days

Step 3, the FCC ID

Element	Assigned by	Length	Rule
Grantee Code	FCC	3 characters (older codes) or 5 characters (since 2013)	2.926(b), (c)
Equipment product code	Grantee	1 to 14 characters: capital letters, digits, dash or hyphen	2.926(d)
Full FCC ID		17 characters at most with a 3-character code, 19 with a 5-character code	DA 13-669

The product code must not have been used before with the same Grantee Code, nor in an application that was denied (2.926(d)). No FCC ID may appear on marketed equipment until a grant validates it, and nobody may place it on equipment without the grantee's authorization (2.926(e)). Equipment shown at a trade show before its grant may carry a model number but not a purported FCC ID.

Two rules keep one FCC ID usable across a range. 2.924 lets the grantee market electrically identical devices under different model numbers or trade names, "electrically identical" meaning no change or only Class I permissive changes. 2.929(b) lets the grantee license a second party to manufacture under the same FCC ID, with the grantee still responsible, and the second party may not be on the Covered List. Any change of the FCC ID itself needs a new application (2.933), with an abbreviated filing when design and circuitry are unchanged.

The role of the TCB

Since the 2015 revision of Subpart J, 2.911(a) reads: "All requests for equipment authorization shall be submitted in writing to a Telecommunication Certification Body (TCB)". The TCB sends an electronic copy with all exhibits to the FCC before grant or dismissal, and grants or dismisses through the FCC system (2.962(d)(6) and (7)). The conformity assessment bodies and accreditation guide describes the same delegated model for third parties generally.

Point	Section	What the text says
Accreditation	2.960(a)(4), (6)	ISO/IEC 17065 for the scope of equipment certified, and ISO/IEC 17025 for testing competence
Reassessment	2.960(a)(7)(ii)	Assessed for accreditation at intervals not exceeding two years
Designation	2.960(c), (d)	In the United States, by NIST under NVCASE; outside, under an MRA to which the United States is a party
Ownership	2.960(b), (h)	No recognition if a prohibited entity holds 10% or more of equity or votes; FCC 25-27 adds a duty to report interests of 5% or more, but that paragraph (2.962(d)(9)) and its lab and accreditation-body equivalents are still delayed: 91 FR 27843 excludes them from the June 15, 2026 effective date pending a separate notice (see our FCC 26-28 note)
Review	2.962(a)(2), (b), (d)(2)	Typically one unmodified sample per product type; review and certification decision are never outsourced; test data from any FCC-recognized lab accepted without needless repeat testing
Set-aside	2.962(f)	Within 30 days of grant, the TCB or the FCC may set aside a non-compliant grant; after that, only the FCC can revoke (2.939)
Limits	2.962(g)	A TCB may not grant waivers, take enforcement action or authorize a transfer of control
Post-market surveillance	2.962(i), 2.945(b)(2)	Type testing of a share of certified products; samples requested from the grantee or bought on the market
PAG list	2.964	For categories on the Pre-approval Guidance list, the TCB asks the FCC for guidance and needs its concurrence before granting

The FCC publishes the PAG list (2.964(a)); the OET Knowledge Database (KDB) holds the advisory measurement guidance referred to in 2.947(a)(3). Since FCC 26-28 (effective 15 June 2026), 2.964(a) adds that the PAG list prioritizes equipment tested in Trusted Test Labs, meaning labs in the United States or in an economy that grants reciprocal treatment through a trade agreement.

Testing for Certification is done by a lab that is accredited and recognized by the FCC (2.948(a)). The TCB may test itself or use external labs, but stays responsible for the evaluation (2.962(c)).

What the applicant signs

Statement	Section	Since
Truth of all statements, Anti-Drug Abuse Act certification	2.911(d)(1), (2)	Before 2023
Equipment not prohibited under 2.903, and whether the applicant is on the Covered List, renewed if the list changes before grant	2.911(d)(5), (6)	FCC 22-84, 6 February 2023
A US agent for service of process, maintained for at least one year after marketing and importation end or after any related FCC proceeding ends, whichever is later; a US applicant may designate itself	2.911(d)(7)	FCC 22-84, 6 February 2023

These statements also accompany every permissive change (2.932(e)) and every name, address or ownership notice (2.929(c), (d)).

The equipment authorization database

A grant shows its effective date and any special conditions (2.915(b)). It takes effect from its publication on the FCC website, which keeps the official copy (2.915(d)), and it identifies the approving TCB and the Commission as issuing authority (2.915(e)). Applications are not public before that date, which the applicant can ask to defer; afterwards the application and related materials, including technical specifications and test measurements, are open to inspection (0.457(d)(1)(ii)), except material given confidential treatment, which the TCB requests with the filing (2.962(d)(6)).

For an integrator, the grant and its published exhibits are the documents to read before choosing a module, because the special conditions printed on the grant bind every host that relies on it. A module approved only with a specific antenna, or only as a limited modular approval, narrows the host design before layout starts.

Labeling rules

Rule	Section	What the text says
Content	2.925(a)(1)	The FCC ID, preceded by "FCC ID" in capital letters on a single line, legible without magnification
Permanent and visible	2.925(d)	Etched, engraved, stamped, indelibly printed, or a nameplate that cannot be readily detached; visible from outside the enclosure
Type size	2.925(f)	Need not exceed eight-point
Very small device	2.925(f), 15.19(a)(5)	If a four-point font is impractical and there is no display: in the user manual, plus either on the packaging or on a removable label
Several sections	2.925(b)(1)	Separate FCC IDs allowed for separate boards with independent frequency control, marked TX FCC ID and RX FCC ID
Validity	2.927(a)	A grant is valid only when the device is labeled per 2.925
Part 15 statement	15.19(a)(3)	"This device complies with part 15 of the FCC Rules..." on certified and SDoC devices

Electronic labeling (2.935)

Condition	Paragraph
Device with an integrated display, or one that can only operate with a device that has one	(a)
Instructions on how to access the information, in the manual, packaging inserts or a website named on the packaging	(b)
No special codes, accessories or permissions; no more than three steps from the settings menu	(c)
Programmed by the responsible party and secured against modification by third parties	(e)
The device or its packaging still carries the FCC ID or other information that identifies it at importation and sale	(f)

From 1 March 2027 or 1 June 2027 depending on their role, online marketplaces must also display the FCC ID at the point of sale under FCC 26-50 (see FCC scope and FCC 26-50 in force).

Modular approval (15.212)

15.212(a) defines two kinds of modular transmitter, both approved with an antenna.

Requirement, 15.212(a)(1)	Single modular	Split modular, (a)(2)
(i) Own shielding of the radio elements	Yes	Radio front end only
(ii) Buffered modulation and data inputs	Yes	Yes
(iii) Own power supply regulation	Yes	Yes
(iv) Antenna rules of 15.203 and 15.204; permanently attached antenna or unique coupler	Yes	Yes
(v) Tested stand-alone	Yes	No: tested in a representative host
(vi) Own FCC ID label, or electronic display of the FCC ID	Yes	Yes
(vii) Specific operating rules met, with instructions for the integrator	Yes	Yes
(viii) RF exposure statement, compliance in the final configuration	Yes	Yes
Digital interface of at least 150 mV peak-to-peak; only parts approved together can operate together		Yes

A limited modular approval (15.212(b)) may be granted for a single or split module that misses some of these requirements, if the application shows by other means that it meets Part 15 in its intended operating conditions, or where RF exposure compliance is shown only for particular product configurations. The applicant must state how control of the end product is maintained so that full compliance is always ensured.

What the host maker inherits, and what stays with it:

• Label. If the module FCC ID is not visible once installed, the host carries "Contains FCC ID: XYZMODEL1" or similar wording (15.212(a)(1)(vi)(A)); with an electronic display, "Contains FCC certified transmitter module(s)" (15.212(a)(1)(vi)(B)).
• Grant conditions. Antenna types and gains, host restrictions and the integration instructions of 15.212(a)(1)(vii). OET guidance on integration is KDB 996369.
• RF exposure. The module must comply "in its final configuration" (15.212(a)(1)(viii)), so a host that places the antenna closer to the body than the grant assumes is outside it. SAR or MPE then has to be addressed in a filing.
• Digital device. The host still needs its own Part 15 Subpart B authorization for its digital circuitry, unless that circuitry only serves the radio (15.3(k)).
• Covered List. Since FCC 25-71 (effective 26 December 2025), 2.903 bars authorization of a covered modular transmitter and of any host product that incorporates one.

Permissive changes

A change in design, circuitry or construction needs a new application, except for permissive changes (2.932(a), (b)). Changes to the frequency determining circuitry, frequency multiplication, the basic modulator or the maximum power or field strength ratings always need a new grant, except Class III software changes (2.1043(a)). Software changes that do not affect RF emissions need no filing and may be made by others than the grantee.

Class	What 2.1043(b) says	Filing
Class I	Modifications that do not degrade the characteristics reported and accepted at grant	None
Class II	Modifications that degrade the performance characteristics reported at initial certification, the degraded performance still meeting the minimum requirements of the rules	Test results for the affected characteristics, Covered List statements, US agent details; not marketed 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, test results with the new software (including RF exposure), same statements; software not loaded before acknowledgement; only if no Class II change was made

Class I and Class II changes may only be made by the grant holder (2.1043(b)(4)); for equipment outside Parts 15 and 18, another party may supply the Class II data (2.1043(f)). None of the classes may change the FCC ID. From 13 October 2026, FCC 26-50 requires a new grant for any change made by a Covered List entity. The Class II permissive change guide reads 2.1043 paragraph by paragraph and compares it with ISED and the RED.

Dated changes to the identifier and the TCB rules

Date	Text	Change
13 June 2012 (adopted)	Order, 27 FCC Rcd 6565	2.925 and 2.926 amended to allow five-character Grantee Codes
1 May 2013	Public Notice DA 13-669	OET starts issuing five-character codes; three-character codes no longer issued
12 June 2015	80 FR 33439 to 33445 (amended sections)	Subpart J revised: all applications submitted to TCBs (2.911(a)), pre-approval guidance procedure (2.964), name change and modification rules rewritten
2 November 2017	82 FR 50825 and following	SDoC replaces the former verification and Declaration of Conformity procedures; electronic labeling rule 2.935
6 February 2023	FCC 22-84, 88 FR 7592	Covered equipment barred; Covered List attestations and US agent for service of process for every applicant
8 September 2025	FCC 25-27, 90 FR 38045	TCBs, labs and accreditation bodies owned, controlled or directed by a prohibited entity lose recognition; SDoC testing barred in such labs; some provisions delayed indefinitely
26 December 2025	FCC 25-71, 90 FR 53227	Covered modular transmitters and hosts that incorporate them barred; prohibition extended to changes
15 June 2026	FCC 26-28, 91 FR 27843	Trusted Test Lab priority on the PAG list; post-market surveillance updates; some provisions delayed
13 October 2026	FCC 26-50, 91 FR 57798	Logic-bearing components from Covered List entities; full certification for any change by such an entity; marketing rules reach online marketplaces
1 March 2027 and 1 June 2027	FCC 26-50	Online marketplaces display the FCC ID at the point of sale

Claims the texts contradict

Common claim	What the text says
A Class II change is one that "affects compliance but stays within the same basic design" (this page said so until October 2026)	2.1043(b)(2): a Class II change degrades the performance characteristics reported at grant while still meeting the rules. Changes to the basic frequency or modulator circuitry or the power rating need a new grant whatever the design (2.1043(a))
Grantee Codes "never contain 0 or 1"	DA 13-669 excludes 0 and 1 from five-character codes only. It says nothing about the characters of older three-character codes
The FCC ID is 14 characters at most	14 is the limit for the product code (2.926(d)); a full FCC ID can reach 17 or 19 characters (DA 13-669)
Hyphens in the product code must not be consecutive	2.926(d) allows capital letters, digits and the dash or hyphen, with no such condition
Only SDoC needs a party in the United States	Every Certification applicant designates a US agent for service of process (2.911(d)(7)), since 6 February 2023
The radio drives the procedure and the digital part is covered by the same certification	The digital part needs its own Part 15 Subpart B authorization unless its circuitry only enables the radio (15.3(k)); 2.925(b) only allows one FCC ID for both
Unintentional radiators use SDoC	15.101 lists SDoC or Certification for most of them, and scanning receivers need Certification; Covered List producers must certify (2.907(c))
A small device may put its FCC ID on the packaging and manual	Only below a four-point font with no display, and then in the manual plus either the packaging or a removable label (2.925(f))
SDoC devices carry no label statement	15.19(a) applies to SDoC and certified devices alike; 2.1074 also requires a unique identification
Certification testing must be at an ISO/IEC 17025 lab, SDoC "where the rules call for it"	Certification labs must be accredited and FCC-recognized (2.948(a)); SDoC has no accreditation requirement, only the prohibited-entity bar (2.906(a)(1))
A Grantee Code is permanent as soon as it is issued	The fee must be validated within 30 days or the code is removed (2.926(c))
The public database always shows schematics and block diagrams	Materials given confidential treatment are withheld (0.457, 2.962(d)(6))

Relationship with ISED Canada

ISED certifies radio apparatus under RSP-100 and issues its own certification number, shown with the "IC:" prefix. Under the Canada-US mutual recognition arrangement, laboratories and certification bodies designated on one side can be recognised on the other; on the FCC side, 2.960(d) recognises TCBs outside the United States only when designated under an MRA, and not if the partner economy refuses US TCBs. One test campaign can therefore feed both files, but the Canadian file must show compliance with the RSS standards, and the two grants stay separate applications with separate identifiers. The ISED Canada radio certification guide covers the Canadian side.

A practical sequence

1. Classify the device under 15.3 and the rule part, and check whether its digital part needs its own authorization.
2. Register an FRN in CORES, then request a Grantee Code and pay the fee within 30 days.
3. Choose a product code of 14 characters at most, not used before with your Grantee Code.
4. Test at an accredited, FCC-recognized lab, after reading the relevant KDB guidance and checking whether the device is on the PAG list.
5. Designate a US agent for service of process and sign the 2.911(d) statements.
6. File with a TCB, with any confidentiality request; the grant takes effect when published.
7. Label under 2.925, 2.935 and 15.19, and keep the SDoC material for any part authorized that way.
8. Plan changes under 2.1043 and notify name, address or ownership changes under 2.929.

See also

• FCC scope: which devices need authorization
• FCC permissive changes: Class I, II, III and RED delta
• Conformity assessment bodies and accreditation
• EMC Directive 2014/30/EU: a guide
• NRTL / UL listing: US product safety explained
• Radio spectrum: SRD and license-free bands
• Substantial modification: when to re-certify in the EU

Working on FCC equipment authorization, FCC ID and modular approval for a real product? AESTECHNO can audit your design and certification plan. Get in touch

Sources & references

1. 47 CFR Part 2, Subpart J, Equipment Authorization Procedures (eCFR), eCFR www.ecfr.gov/current/title-47/chapter-I/subchapter-A/part-2/subpart-J
2. 47 CFR 15.212, Modular transmitters (eCFR), eCFR www.ecfr.gov/current/title-47/chapter-I/subchapter-A/part-15/subpart-C/section-15.212
3. 47 CFR 15.19, Labeling requirements (eCFR), eCFR www.ecfr.gov/current/title-47/chapter-I/subchapter-A/part-15/subpart-A/section-15.19
4. 47 CFR Part 1, Subpart W, FCC Registration Number (eCFR), eCFR www.ecfr.gov/current/title-47/chapter-I/subchapter-A/part-1/subpart-W
5. 47 CFR 0.457, Records not routinely available for public inspection (eCFR), eCFR www.ecfr.gov/current/title-47/chapter-I/subchapter-A/part-0/subpart-C/section-0.457
6. Public Notice DA 13-669 (April 9, 2013): OET to begin issuing five-character Grantee Codes, FCC docs.fcc.gov/public/attachments/DA-13-669A1_Rcd.pdf
7. TCB Workshop, April 2013: EAS and Grantee Code update (slides), FCC Office of Engineering and Technology transition.fcc.gov/bureaus/oet/ea/presentations/files/apr13/3b-EAS_Grantee-Update_v3-GT.pdf
8. FCC 22-84, Report and Order, 88 FR 7592 (February 6, 2023), Federal Register www.federalregister.gov/documents/2023/02/06/2022-28263/protecting-against-national-security-threats-to-the-communications-supply-chain-through-the
9. FCC 25-27, TCB and test lab integrity Report and Order, 90 FR 38045 (August 7, 2025), Federal Register www.federalregister.gov/documents/2025/08/07/2025-14970/promoting-the-integrity-and-security-of-telecommunications-certification-bodies-measurement
10. FCC 26-28, Trusted Test Lab fast track and post-market surveillance, 91 FR 27843 (May 15, 2026), Federal Register www.federalregister.gov/documents/2026/05/15/2026-09822/promoting-the-integrity-and-security-of-telecommunications-certification-bodies-measurement
11. FCC 26-50, Third Report and Order, 91 FR 57798 (September 11, 2026), Federal Register www.federalregister.gov/documents/2026/09/11/2026-18535/protecting-against-national-security-threats-to-the-communications-supply-chain-through-the
12. RSP-100, issue 12: Certification of Radio Apparatus and Broadcasting Equipment, ISED Canada ised-isde.canada.ca/site/spectrum-management-telecommunications/en/devices-and-equipment/radio-standards-procedures-rsp/rsp-100-certification-radio-apparatus-and-broadcasting-equipment
13. OET Knowledge Database (KDB), FCC Office of Engineering and Technology apps.fcc.gov/oetcf/kdb/index.cfm
14. FCC ID Search (Equipment Authorization System), FCC www.fcc.gov/oet/ea/fccid