SRRC vs FCC: China and US radio approval

Hugues Orgitelloupdated 7 Oct 202612 min read

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

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 Order 57, 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, 12 characters (year + device type + region + applicant codes)
Conformity route	Certification via TCB, or SDoC for some equipment	Systematic MIIT examination, no radio self-declaration
Who tests	Lab chosen by the applicant, outside the US allowed if FCC-recognised (47 CFR 2.948)	Organised by the radio administration, free of charge (Order 57 art. 10); own reports for qualifying applicants (art. 11)
Foreign applicant	Yes, with a US agent for service of process	Yes, in its own name (Order 57 art. 8, region code 99)
Marking	FCC ID and 15.19 statement, e-labelling allowed	CMIIT ID on the device or shown electronically (Order 57 art. 15)
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

The two regimes rest on distinct institutional logics.

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

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; the type approval procedure is set by MIIT Order 57 (Radio Transmitting Equipment Management Provisions), in force since 1 July 2023, and 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

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

This is the most structural axis and the most common source of error.

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

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

Both regimes materialise the approval through an identifier carried on the product, of close logic but distinct format.

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

Since 1 December 2023 the CMIIT ID has twelve characters, CMIIT ID: AABCCDDDEEEE: the last two digits of the year of application (AA), a device type letter (B, for example J for wireless access equipment such as Wi-Fi and Bluetooth), the region where the applicant is registered (CC, with 99 for other countries and regions), an applicant code generated by the system on first application (DDD) and a code chosen by the applicant (EEEE). Older approvals carry the previous ten-character format, such as CMIIT ID: 2013DJ9946. Under article 15 of MIIT Order 57, the code goes on the device or is shown electronically. It is verifiable in the srrcccc.miit.gov.cn database.

Criterion	FCC ID	CMIIT ID
Structure	Grantee Code + Product Code	Year + device type + region + applicant code + applicant's own code
Assignment	FCC (Grantee Code) + applicant (Product Code)	Composed by the applicant under the MIIT coding rules; MIIT corrects or returns codes that break them
Public database	fcc.gov/oet/ea/fccid	srrcccc.miit.gov.cn
Display	Label, or e-labelling	On the device or shown electronically (Order 57 art. 15)
Modular approach	Modular approval provided for	Possible but framed by notification

Marking and labelling

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

Under article 15 of MIIT Order 57, the CMIIT ID goes on the device or is shown electronically, and on the packaging or manual only when the device is too small to carry it. For products subject to CCC, the 3C logo is added, separate from the CMIIT ID.

Criterion	FCC	SRRC
Identifier to display	FCC ID	CMIIT ID
Electronic labelling	e-labelling allowed	Allowed: code shown electronically (art. 15)
Associated safety mark	No federal mark	3C logo (if CCC applies)
Regulatory statement	"Complies with Part 15"	None set by Order 57, the code itself

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	2400-2483.5 MHz, 20 dBm EIRP (27 dBm with a combined antenna gain of 10 dBi or more), notice 129
5 GHz (U-NII-1)	5150-5350 MHz open	5150-5350 MHz, 23 dBm EIRP, indoor only, DFS and TPC in 5250-5350 MHz
5 GHz (U-NII-2)	5470-5725 MHz under DFS	Not in notice 129
5 GHz (U-NII-3)	5725-5850 MHz	5725-5850 MHz, 33 dBm EIRP
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

This is the axis where the two regimes differ most: on the FCC side the applicant picks the laboratory, on the SRRC side the administration organises the tests.

FCC side: testing possible outside the US

A laboratory outside the United States can run the tests if the FCC recognises it (47 CFR 2.948): it must be designated under a government-to-government mutual recognition agreement (MRA) or accredited by a body the FCC recognises under 47 CFR 2.949. Being accredited by an ILAC or Global ACI signatory is not enough on its own. 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: tests organised by the radio administration

Under article 10 of MIIT Order 57, type approval testing is organised by the radio administration, which may delegate it to provincial radio administrations that select test bodies by government procurement. The administration may not charge for that testing, and the testing time is not counted in the 15 working days MIIT has to decide. Article 11 allows applicants with good quality management and credit to submit their own test reports instead, except for special items such as network security. The EMC portion under CCC is a separate scheme, against the applicable GB standards.

Criterion	FCC	SRRC
Who tests	Lab chosen by the applicant, outside the US allowed (MRA)	Test body selected by the radio administration, free of charge (art. 10)
Own reports	Yes, from a recognised lab	Only for applicants with good quality management and credit (art. 11)
Body that validates	TCB	MIIT, within 15 working days of acceptance
Product shipment	Not needed to the US	Samples for the test body

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

The typical sequence differs in structure: one bundled path on the FCC side, several parallel paths on the China side.

FCC path

1. Freeze the product specification (hardware, firmware, antenna, accessories).
2. Identify the route: Certification via TCB for the intentional radio, or SDoC if the equipment is eligible.
3. Obtain the Grantee Code from the FCC if the holder does not have one.
4. 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.
5. File with a TCB, which examines and issues the grant and the FCC ID.
6. Apply the FCC ID and the 15.19 statement on the product (or e-labelling).

China path

1. Decide who applies: a foreign manufacturer can apply in its own name (Order 57 art. 8, region code 99), with or without a Chinese agent for language and logistics.
2. 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).
3. Compile the article 8 file: application and undertaking, organisation certificate for overseas applicants, quality description, manual, photos, RF schematics, block diagram, key RF component list.
4. File with MIIT and test: tests organised by the radio administration, or own reports if the applicant qualifies under article 11.
5. Receive the CMIIT ID: MIIT decides within 15 working days of acceptance, testing time excluded.
6. In parallel, run the CCC for safety and EMC, and the operator qualifications for a cellular module.

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
Conflating SRRC and CCC, filing only one of them	Product not placeable on the market, radio or mains side uncovered
Assuming a resident Chinese representative is mandatory	Unneeded dependency; Order 57 art. 8 provides for overseas applicants
Forgetting operator qualification for a cellular module	Module approved but unusable on the target networks
Planning to pick and pay a Chinese lab for type approval	Order 57 art. 10: the radio administration organises the tests, free of charge; own reports only under article 11
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?

The choice is not an "either/or" but a "which schemes for which markets".

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

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 organised by the radio administration, and a foreign manufacturer can apply in its own name. None of these elements transfers from the FCC dossier.

Both markets

Plan for two distinct test cycles and a schedule where the Chinese cycle (China firmware build, sample logistics, the test queue of the radio administration) 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

• 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

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Sources and references

Sources & references

1. 47 CFR Part 2 Subpart J: Equipment Authorization Procedures, FCC www.ecfr.gov/current/title-47/chapter-I/subchapter-A/part-2/subpart-J
2. 47 CFR Part 15: Radio frequency devices, FCC www.ecfr.gov/current/title-47/chapter-I/subchapter-A/part-15
3. FCC Equipment Authorization (OET) and FCC ID database, FCC www.fcc.gov/oet/ea/fccid
4. MIIT Order 57, Radio Transmitting Equipment Management Provisions (无线电发射设备管理规定), in force 1 July 2023, State Council Gazette www.gov.cn/gongbao/content/2023/content_5745288.htm
5. Type approval code coding rules (无线电发射设备型号核准代码编码规则), applicable from 1 December 2023, Ningxia Radio Administration (republication of the MIIT rules) nxww.nx.gov.cn/xxgk/xxgknr/gfxwj/202403/W020240326628202020637.pdf
6. MIIT notice 129 of 2021 on the 2400, 5100 and 5800 MHz bands (工信部无〔2021〕129号), MIIT www.miit.gov.cn/jgsj/wgj/wjfb/art/2021/art_58b24430cb93476fb18a51fe7a350b61.html
7. MIIT, Ministry of Industry and Information Technology (official portal), MIIT www.miit.gov.cn/index.html
8. SRRC certificate search (CMIIT ID lookup), SRRC / MIIT srrcccc.miit.gov.cn/
9. CQC, China Quality Certification Centre (CCC / 3C authority), CQC www.cqc.com.cn/
10. ITU, Radio Regulations (international context, Region 3), ITU www.itu.int/pub/R-REG-RR