The Federal Communications Commission regulates the radio frequency spectrum, and also the electronic equipment that might interfere with radio services. Any product entering the US market that uses RF, or is judged capable of causing interference, has to clear this gate. The rules sit in Title 47 of the Code of Federal Regulations, with Part 2 and Part 15 the ones most often applied.
It is not the same thing as a domestic mandatory certification. The FCC does not hand over a certificate to hang on the wall. What it grants is authorisation: some routes issue an identifier, others rely on the manufacturer's own declaration. Telling those two apart is the first step.
Products with active RF transmission - Bluetooth, Wi-Fi, cellular modules, remote control transmitters - generally take the certification route. Once testing is done, the package goes to a Telecommunications Certification Body for review, and passing yields an FCC ID. The TCB does not re-run the tests; it reviews the material: product classification, declared frequency bands, whether the report covers the applicable requirements, and whether labels and warning statements are complete.
There are exceptions. Under Section 15.201, carrier current systems, tunnel radio systems and cable locating equipment, along with equipment operating in the 525 to 1705 kHz range and below 490 kHz, are intentional radiators that do not require certification and go by declaration instead. The list is short, but it is worth being able to answer when a customer asks.
Digital devices that do not actively transmit - monitors, power supplies, data processing equipment - take the supplier's declaration route, known as SDoC. The manufacturer tests against the applicable standards and signs its own declaration of conformity, with no third-party certification involved.
The dividing line is simple. The product either actively transmits RF or it does not. If it does, it takes the certification route; if it does not, it takes the declaration route. Where wireless is only an ancillary function, the product is still handled on the transmit route. That single question is the only one BlueAsia uses to fix the route.
Part 15B covers unintentional radiators, meaning the electromagnetic disturbance produced when digital circuits operate. The definition of a digital device sits in Section 15.3: equipment using timing signals or pulses at more than 9000 per second, and employing digital techniques. The reach is not blanket, though, since Section 15.103 exempts a set of devices: those with an upper frequency limit below 1.705 MHz that are not connected to the AC mains, those drawing no more than 6 nW, and circuits dedicated to use inside appliances. Those are subject only to the general conditions in Section 15.5 and Section 15.29.
Part 15C covers intentional radiators. Bluetooth, Wi-Fi and remote control devices are worked through item by item for transmit power, spectrum mask, spurious emissions and sidebands, with 5 GHz adding radar avoidance work on top.
Testing for an FCC ID has to be carried out by an FCC-recognised laboratory, and that is a hard requirement. The declaration route carries no such condition - the 2017 rule change removed the accreditation requirement for low-interference-risk devices. The laboratory still has to keep measurement facilities and test records under Part 2.
Applying that requirement across the board makes products that should go by declaration take a pointless detour. On US projects the first step is always to fix the route, and only then to talk about laboratories.
A non-US applicant on the certification route has to designate a US agent, who handles service of legal documents and regulatory correspondence. This is a procedural role and does not carry product compliance responsibility.
On the declaration route, the responsible party itself has to be located in the United States, whether that is a US importer or a local company, and the name and address have to appear in the manual and in the compliance information. That is a different role from the agent above, and merging the two in writing leaves readers thinking SDoC also needs a US agent.
Then there is a proposal that has not landed. On 7 August 2026 the FCC published a third notice of proposed rulemaking in the Federal Register, one item of which would require overseas certification holders to appoint a separate US-based liable party, distinct from the existing US agent. For now it is only a proposal: comments ran to early September and reply comments to late September, and whether it proceeds, and in what form, is undecided. It is worth tracking in long-term planning, but there is nothing to act on today.
An FCC ID is generally affixed permanently to the surface of the device, or inside a non-removable compartment the user can open, such as a battery bay. Where the device is too small to carry 4-point type and has no screen for an electronic label, there is a fallback: the identifier goes into the user manual and also onto the packaging or a removable label, and that label has to survive shipping and be removed by the customer after purchase. The compliance statements and warning wording in the manual cannot be drafted freely.
Two record retention periods need keeping apart. For products on the certification route, records are kept for one year after marketing has been permanently discontinued; for other records the figure is two years. These two numbers are frequently written the wrong way round. Where an investigation notice arrives, records stay until the proceeding closes.
Assuming there is nothing to do without a wireless function is the first. Digital circuits generate unintentional emissions on their own, so a purely wired product still has to meet Part 15B. The reverse assumption fails too: holding an FCC report does not entitle a product to another country's certificate, because national systems are not mutually recognised.
Contact: King Email: king.guo@cblueasia.comAddress: Building C, Hongjingda Industrial Park, No. 107 Beihuan Road, Shiyan Street, Bao'an District, Shenzhen, China BlueAsia delivers more than service!
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