SRRC vs FCC: China and US radio approval
Guide, SRRC FCC comparison
Placing a radio product on the Chinese market and on the US market does not call on the same regulatory machinery. The US FCC bundles, in a single dossier materialised by the FCC ID, both the intentional radio and the unintentional digital emissions. China's SRRC, by contrast, covers only the radio portion through the CMIIT ID, and leaves safety and EMC to a parallel scheme, CCC, plus a separate operator qualification for cellular. This guide compares the two regimes axis by axis: issuing bodies, scope, identifiers, labelling, frequency plans and test location, then closes on the choice to make depending on the target market.
SRRC vs FCC decision table
Section titled “SRRC vs FCC decision table”Before the detail, here is the side-by-side reading of the two regimes. It serves as the grid for each axis developed below.
| Criterion | FCC (United States) | SRRC / CMIIT (mainland China) |
|---|---|---|
| Issuing body | Federal Communications Commission (FCC), OET bureau | State Radio Regulatory Commission (SRRC), under MIIT |
| Reference text | 47 CFR Parts 2 and 15 (and 22, 24, 27 for cellular) | PRC Radio Regulations, MIIT notifications |
| Scope of the scheme | Intentional radio + unintentional emissions, in one dossier | Radio only; safety and EMC via CCC in parallel |
| Product identifier | FCC ID (Grantee Code + Product Code) | CMIIT ID (year + category + serial) |
| Conformity route | Certification via TCB, or SDoC for some equipment | Systematic MIIT examination, no radio self-declaration |
| Test location | Outside the US allowed (ILAC lab recognised by the FCC via MRA) | Mainland China, Chinese accredited lab |
| Local representative | US agent for service of process (foreign manufacturer) | Representative resident in China, registered with MIIT |
| Marking language | English | Simplified Chinese |
| Safety and non-radio EMC | Outside FCC scope (UL, NRTL on the safety side) | Separate CCC (3C) scheme |
| Cellular network access | Operator qualification (AT&T, Verizon, T-Mobile) on top | China Mobile / Telecom / Unicom qualification on top |
The quick reading fits in one sentence: the FCC bundles, China splits. A single FCC dossier covers most of the radio product on the US side, where China imposes a stack of independent schemes. The sections below detail each row.
Issuing bodies and legal architecture
Section titled “Issuing bodies and legal architecture”The two regimes rest on distinct institutional logics.
US side: the FCC writes the rule directly
Section titled “US side: the FCC writes the rule directly”The FCC (Federal Communications Commission) is an independent federal agency. It does not delegate to a standards body: the technical requirements are written into the 47 CFR, notably FCC Part 15 for unlicensed devices. The measurement method references ANSI C63.4 for digital emissions and ANSI C63.10 for unlicensed radio. Equipment Authorization is run by the OET bureau (Office of Engineering and Technology), and the grant is issued by a private accredited TCB (Telecommunication Certification Body).
China side: SRRC under MIIT
Section titled “China side: SRRC under MIIT”The SRRC (State Radio Regulatory Commission) is the Chinese radio regulator. Historically a distinct entity, it was integrated into MIIT (Ministry of Industry and Information Technology) through reorganisations of the central administration. The framing instrument is the Radio Regulations of the People's Republic of China, expanded by MIIT notifications that set the frequency plans and power limits per band. The examination is conducted by MIIT, which issues the CMIIT ID at the end of the procedure.
Practical consequence
Section titled “Practical consequence”| Aspect | FCC | SRRC |
|---|---|---|
| Source of limits | 47 CFR (direct rule) | MIIT notifications + GB standards |
| Prior examination | Private TCB, or SDoC with no examination | Systematic MIIT examination for radio |
| Body that issues | Accredited TCB | MIIT |
| Public database | FCC ID database (fcc.gov/oet/ea/fccid) | CMIIT ID database (srrcccc.miit.gov.cn) |
Scope of the scheme: what each one covers
Section titled “Scope of the scheme: what each one covers”This is the most structural axis and the most common source of error.
The FCC bundles radio and digital emissions
Section titled “The FCC bundles radio and digital emissions”For a Wi-Fi or cellular product, the FCC handles within one path:
- the intentional radio (the emitter itself) under FCC Part 15 Subpart C (15.247, 15.407) or Parts 22, 24, 27 for cellular;
- the unintentional emissions (clocks, power supply, digital logic) under Part 15 Subpart B, method ANSI C63.4.
The result is a single FCC ID, or an SDoC for the equipment eligible for it. Electrical safety sits outside FCC scope: in the US it falls to an NRTL (UL for example), with no mandatory federal mark equivalent to CCC.
SRRC covers only the radio
Section titled “SRRC covers only the radio”SRRC issues the CMIIT ID for the radio portion alone: spectral occupancy, conducted and radiated power, harmonics, on the Chinese bands. Electrical safety and non-radio EMC fall under a parallel scheme, CCC (China Compulsory Certification, 3C mark), administered by CQC under SAMR. Cellular network access adds an operator qualification (China Mobile, China Telecom, China Unicom).
| Product function | FCC side | China side |
|---|---|---|
| Radio emitter | FCC ID (Part 15 C or Parts 22/24/27) | CMIIT ID (SRRC) |
| Digital emissions | Included in the FCC dossier (Part 15 B) | Handled on the EMC side under CCC |
| Electrical safety | NRTL (no federal mark) | CCC (3C) |
| Mains EMC | Included Part 15 B | CCC (GB standards) |
| Cellular network access | US operator qualification | Chinese operator qualification |
The practical rule: a consumer IoT product combining radio and mains supply needs one FCC dossier on the US side, and at least SRRC plus CCC on the China side, in parallel. See the dedicated guide CCC / 3C, China product safety for the detail of the parallel scheme, and SRRC / CMIIT, China radio for the full procedure.
Identifiers: FCC ID vs CMIIT ID
Section titled “Identifiers: FCC ID vs CMIIT ID”Both regimes materialise the approval through an identifier carried on the product, of close logic but distinct format.
FCC ID
Section titled “FCC ID”The FCC ID combines two blocks:
- a Grantee Code of three to five characters, uniquely assigned by the FCC to the holder;
- a Product Code, chosen by the applicant, up to a limited number of characters.
Conventional form: FCC ID: 2AABC-XYZ123. It is verifiable in the OET public database. A pre-certified radio module carries its own FCC ID, which allows a modular build without recertifying the host product under certain conditions (modular approval).
CMIIT ID
Section titled “CMIIT ID”The legacy CMIIT ID, still valid, takes the form CMIIT ID: 2013DJ9946: ten characters made of a four-digit year of issuance, a two-letter type code, and a four-digit serial, where "DJ" denotes short-range or micro-power devices. Since 1 December 2023 the current format runs to twelve characters, starting with a two-digit year, then a single category letter, then territorial, enterprise, and serial codes. It must be permanently and legibly affixed, accompanied by the regulatory text in Simplified Chinese. It is verifiable in the srrcccc.miit.gov.cn database.
| Criterion | FCC ID | CMIIT ID |
|---|---|---|
| Structure | Grantee Code + Product Code | Year + category + serial |
| Assignment | FCC (Grantee Code) + applicant (Product Code) | MIIT |
| Public database | fcc.gov/oet/ea/fccid | srrcccc.miit.gov.cn |
| Associated text | FCC statement (15.19) in English | Regulatory text in Simplified Chinese |
| Modular approach | Modular approval provided for | Possible but framed by notification |
Marking and labelling
Section titled “Marking and labelling”FCC side
Section titled “FCC side”Marking follows 47 CFR 15.19: display of the FCC ID and the compliance statement, in English. For products too small, e-labelling is allowed (FCC ID shown on screen or via the menu), framed by the FCC's electronic labelling rules. The typical statement is: "This device complies with Part 15 of the FCC Rules."
SRRC side
Section titled “SRRC side”Marking requires the full CMIIT ID, legible to the naked eye, plus the regulatory text in Simplified Chinese (model, manufacturer, importer, usage restrictions). For products subject to CCC, the 3C logo and the CCC number are added, separate from the CMIIT ID. English-only labelling is a recurring ground for rejection in market surveillance on consumer products.
| Criterion | FCC | SRRC |
|---|---|---|
| Identifier to display | FCC ID | CMIIT ID |
| Language | English | Simplified Chinese |
| Electronic labelling | e-labelling allowed | More restrictive frame, physical support expected |
| Associated safety mark | No federal mark | 3C logo (if CCC applies) |
| Regulatory statement | "Complies with Part 15..." | Regulatory text in Chinese |
Frequency plans and power limits
Section titled “Frequency plans and power limits”Both countries publish distinct plans. The table summarises the main gaps for an IoT product.
| Band | US (FCC) | China (MIIT) |
|---|---|---|
| 2.4 GHz ISM | Part 15.247, up to 1 W conducted | Aligned, limits close, dedicated MIIT notification |
| 5 GHz (U-NII-1) | 5150-5350 MHz open | 5150-5350 MHz, indoor-only on the lower band |
| 5 GHz (U-NII-2) | 5470-5725 MHz under DFS | Historical restrictions, partial opening per notification |
| 5 GHz (U-NII-3) | 5725-5850 MHz | 5725-5850 MHz typically open |
| Sub-GHz SRD | 902-928 MHz (Part 15.247) | 902-928 MHz unavailable, sub-bands 470-510, 779-787, 920-925 MHz |
| 5G n78 (3.5 GHz) | Close to CBRS | Widely deployed, assigned to national operators |
| 5G n79 (4.9 GHz) | Limited use | China-specific deployment |
| 5G mmWave | 24, 28, 37, 39 GHz | Different deployment, sub-6 GHz priority |
The most differentiating point for a sub-GHz product is the 902-928 MHz band, available in the US but not identically in China. An LPWA application designed for 902-928 MHz (LoRaWAN US915) has to be reworked for the Chinese market on the 470-510, 779-787 or 920-925 MHz sub-bands, depending on permitted power and duty cycle. A mere firmware region switch will not pass SRRC: the RF chain (filter, antenna, power stage) has to be adapted to the band actually used. The European 868 MHz band, for its part, is available neither in the US nor in China. See licence-free SRD bands for the detail of the plans.
For cellular, the Chinese allocations to the three national operators do not match the US allocations. A global multi-band 4G or 5G module needs an adapted variant or firmware compatible with the bands actually used on the target network.
Test location and report recognition
Section titled “Test location and report recognition”This is the axis where the FCC's flexibility contrasts most with SRRC's rigidity.
FCC side: testing possible outside the US
Section titled “FCC side: testing possible outside the US”Through the mutual recognition agreement (MRA), an ILAC-accredited laboratory recognised by the FCC can run the tests outside the United States. A TCB then issues the grant on the basis of that report. A European manufacturer can therefore have its product tested in Europe and obtain an FCC ID without shipping the product to the US.
SRRC side: testing in mainland China
Section titled “SRRC side: testing in mainland China”SRRC relies on a network of accredited laboratories established in mainland China. SRRC filings are always supported by a report from a Chinese accredited laboratory. Recognition of foreign reports remains limited:
- for some categories, a foreign report can feed into the dossier in support, but does not replace the Chinese report;
- for the critical tests (spectral occupancy, power, harmonics on the Chinese bands), a fresh test cycle runs in China;
- the EMC portion under CCC is tested locally against the applicable GB standards.
| Criterion | FCC | SRRC |
|---|---|---|
| Testing out of country | Yes, ILAC lab recognised by the FCC (MRA) | No, Chinese accredited lab required |
| Reuse of a foreign report | Broad (across recognised labs) | Near zero, tests redone in China |
| Body that validates | TCB | MIIT |
| Product shipment | Not needed to the US | Samples shipped to China |
In practice, a manufacturer plans an SRRC test cycle distinct from the FCC cycle. The FCC report remains useful internally to frame the Chinese tests and identify likely deltas, but it does not substitute for the SRRC report at filing. See certification timeline for cross-cutting orders of magnitude.
Step-by-step procedure, on both sides
Section titled “Step-by-step procedure, on both sides”The typical sequence differs in structure: one bundled path on the FCC side, several parallel paths on the China side.
FCC path
Section titled “FCC path”- Freeze the product specification (hardware, firmware, antenna, accessories).
- Identify the route: Certification via TCB for the intentional radio, or SDoC if the equipment is eligible.
- Obtain the Grantee Code from the FCC if the holder does not have one.
- Run the tests in an accredited laboratory (in or outside the US via MRA): Part 15 B for the unintentional side, Part 15 C or Parts 22/24/27 for the radio.
- File with a TCB, which examines and issues the grant and the FCC ID.
- Apply the FCC ID and the 15.19 statement on the product (or e-labelling).
China path
Section titled “China path”- Designate a local representative resident in China, registered with MIIT (mandatory before any filing).
- Identify the applicable MIIT notifications for the bands used and adapt the firmware to the Chinese plan (region lock, masking of unauthorised channels, removal of 868 MHz).
- Select a Chinese accredited laboratory and run the radio tests in China.
- Compile the dossier in Simplified Chinese or bilingual (schematics, BOM, antenna plan, band declaration).
- File the SRRC dossier through the representative, respond to MIIT requests, receive the CMIIT ID.
- In parallel, run the CCC for safety and EMC, and the operator qualifications for a cellular module.
Common pitfalls
Section titled “Common pitfalls”| Pitfall | Consequence |
|---|---|
| Believing an FCC ID brings you closer to Chinese approval | Product treated as not certified in China, full SRRC and CCC dossiers to do |
| Keeping a 902-928 MHz RF chain for China | SRRC rejection, band unavailable, RF redesign needed |
| English-only labelling on a Chinese consumer product | Rejection in market surveillance, commercial withdrawal |
| Conflating SRRC and CCC, filing only one of them | Product not placeable on the market, radio or mains side uncovered |
| Designating the Chinese representative late in the project | Filing blocked, industrialisation delayed |
| Forgetting operator qualification for a cellular module | Module approved but unusable on the target networks |
| Assuming SRRC tests can be run outside China | Test cycle invalid, dossier to redo in a Chinese lab |
| Neglecting the FCC agent for a foreign manufacturer | FCC notifications not received, regulatory exposure |
| Copying the US 5 GHz channel plan as-is into China | Band declaration inconsistent with the MIIT notifications, rejection |
| Modifying the RF chain after certification without refiling | FCC ID or CMIIT ID invalidated, exposure to recall and sanctions |
Which one do you need?
Section titled “Which one do you need?”The choice is not an "either/or" but a "which schemes for which markets".
US market targeted
Section titled “US market targeted”You need an FCC ID (Certification via TCB for the intentional radio) or an SDoC for eligible equipment. Tests may be run outside the US in a laboratory recognised by the FCC. Electrical safety goes separately through an NRTL. Cellular network access needs an operator qualification (see PTCRB).
Chinese market targeted
Section titled “Chinese market targeted”You need a CMIIT ID via SRRC for the radio, almost always a CCC (3C) for safety and EMC, and an operator qualification for a cellular module. The radio tests are run in China, through a local representative registered with MIIT. None of these elements transfers from the FCC dossier.
Both markets
Section titled “Both markets”Plan for two distinct test cycles and a schedule where the Chinese cycle (representative, local lab, MIIT plans) starts early, since it is less flexible than the FCC cycle. The FCC report serves as an internal baseline to anticipate the Chinese deltas, with no substitution value at the SRRC filing. See parallel EU and US certification for the mutualisation logic on the Western side.
Further reading
Section titled “Further reading”- SRRC / CMIIT, mainland China radio: the full SRRC procedure and the CMIIT ID format
- CCC / 3C, China product safety: the parallel scheme required for safety and EMC
- FCC, equipment authorization: the US scheme, FCC ID, TCB, SDoC
- PTCRB, North American cellular qualification: the conceptual analogue of the Chinese operator programmes
- Licence-free SRD bands: the detail of frequency plans by region
- Certification timeline: cross-cutting orders of magnitude for the phases
Sources and references
Section titled “Sources and references”Sources & references
- 47 CFR Part 2 Subpart J: Equipment Authorization Procedures , FCC www.ecfr.gov/current/title-47/chapter-I/subchapter-A/part-2/subpart-J
- 47 CFR Part 15: Radio frequency devices , FCC www.ecfr.gov/current/title-47/chapter-I/subchapter-A/part-15
- FCC Equipment Authorization (OET) and FCC ID database , FCC www.fcc.gov/oet/ea/fccid
- MIIT, Ministry of Industry and Information Technology (official portal) , MIIT www.miit.gov.cn/index.html
- SRRC certificate search (CMIIT ID lookup) , SRRC / MIIT srrcccc.miit.gov.cn/
- CQC, China Quality Certification Centre (CCC / 3C authority) , CQC www.cqc.com.cn/www/english/
- ITU, Radio Regulations (international context, Region 3) , ITU www.itu.int/pub/R-REG-RR