IllustrationFCC certification is the equipment authorization a radio transmitter needs before it can be marketed in the US. An accredited lab tests the device, and a Telecommunication Certification Body issues a grant tied to an FCC ID. A device with digital circuits and no transmitter can use the lighter Supplier's Declaration of Conformity instead.
Any product with a processor or an unlicensed radio such as Bluetooth or Wi-Fi falls under FCC Part 15, even when it is exempt from some of the technical standards. Cellular radios fall under the licensed service rules in Parts 22, 24 and 27 instead. The first question a hardware team has to answer is which approval path the device takes. This guide covers the two paths, who grants approval, the label, and what you can do before the grant. Rules are from 47 CFR Parts 2 and 15, plus the cellular service rules, as of November 2026.
This is an engineering summary and not legal advice. Module rules and the Part 15B and 15C split have their own articles, linked below.
What is FCC certification?
The FCC calls the approval process equipment authorization. Part 2 says the service rules require either a Supplier's Declaration of Conformity (SDoC) or a grant of certification from a Telecommunication Certification Body (47 CFR 2.901, as of November 2026). People often say "FCC certification" for both. In the rules they are two different procedures.
Certification
A TCB issues the grant, or the FCC approves it, based on the applicant's test data from an accredited lab (47 CFR 2.907). The grant covers every later unit identical to the tested sample.
Supplier's Declaration of Conformity
The responsible party measures the device and declares that it complies. Nothing goes to the FCC unless it asks (47 CFR 2.906). A party may choose Certification instead.
| Point | Certification | SDoC | Rule (47 CFR) |
|---|---|---|---|
| Who approves it | A Telecommunication Certification Body (TCB) issues the grant, or the FCC approves it directly. | The responsible party declares compliance itself. Nothing is filed unless the FCC asks for a sample or data. | 2.907(a), 2.906(a) |
| Who tests it | An accredited lab that the FCC recognizes. Accreditation is based on ISO/IEC 17025. | The responsible party arranges the measurements. The test site cannot be controlled by a prohibited entity. | 2.948(a) and (e), 2.906(a) |
| What the device carries | An FCC ID, preceded by the words "FCC ID" in capitals, plus the Part 15 statement. | A unique identifier that cannot look like an FCC ID, plus the Part 15 statement. The FCC logo is voluntary. | 2.925, 2.1074, 15.19 |
| Statement supplied with the product | The 2.1077 statement rule is written for SDoC. | A compliance information statement in the manual or on a separate sheet, naming the product and a US responsible party. | 2.1077 |
| Who is responsible | The grantee. A party that modifies the device without the grantee's authority takes over that responsibility. | A party located in the United States: the manufacturer, the assembler, or the importer. | 2.909 |
Source: 47 CFR Part 2, Subpart J, as of November 2026.
When is FCC certification required for electronics?
The path depends on how the device emits radio energy. Part 15 sorts devices into three kinds (47 CFR 15.3, as of November 2026):
- Intentional radiator. A device that generates and emits radio energy on purpose, by radiation or induction. Bluetooth, Wi-Fi and NFC transmitters are in this group.
- Unintentional radiator. A device that generates radio energy for use inside itself, and is not meant to emit it. A digital device is one of these when it uses timing signals above 9,000 pulses per second.
- Incidental radiator. A device that produces radio energy only as a side effect, such as a DC motor or a mechanical switch.
Most intentional radiators under Part 15 must be certified by a TCB before marketing (47 CFR 15.201(b)). Carrier-current systems and a few listed device types, such as some devices below 490 kHz with very low emissions, can use SDoC instead. A digital device, such as a board with a microcontroller clocked above 9 kHz, can use SDoC or Certification (47 CFR 15.101).
Cellular radios such as LTE-M and Cat-1bis are not Part 15 devices. Their transmitters must be certified under the licensed service rules (47 CFR 22.377, 24.51, 27.51, as of November 2026).
A product with a radio usually needs both. The radio needs Certification, and the rest of the board needs its own authorization as a digital device. The exception is a digital circuit that only runs the radio and controls nothing else (15.3(k)). That split is the subject of our article on FCC Part 15B vs 15C for a BLE wearable.
Which path fits your device?
| Device | Radiator class | Usual authorization path |
|---|---|---|
| BLE or Wi-Fi wearable, voice pendant, smart ring | Intentional radiator (the radio) plus an unintentional radiator (the digital circuits) | Certification for the radio, often through a certified module. The finished device also needs SDoC or Certification for its digital circuits when they do more than run the radio. |
| LTE-M or Cat-1bis tracker | Licensed cellular transmitter (not Part 15) plus digital circuits | Certification for the cellular radio under the service rules in Parts 22, 24 or 27, usually through a certified cellular module, plus SDoC or Certification for the digital circuits. |
| Device with a processor and no radio, clock above 9 kHz | Unintentional radiator (a digital device) | SDoC or Certification, at your choice, under 15.101. |
| Battery device whose highest frequency is below 1.705 MHz and that never runs from AC power | Exempt digital device | Exempt from the technical standards under 15.103(h). A device that runs while charging does not qualify. |
Sources: 15.3, 15.101, 15.103, 15.201 and 24.51, as of November 2026. Rows are typical cases. Your lab confirms the path for your design.
Reusing a certified radio module comes with its own conditions. Our guide to pre-certified LTE modules and FCC certification covers what a module grant does and does not carry over. If the device will also ship in the EU, see FCC and CE certification for radio devices.
The Covered List changes the answer
Equipment produced by an entity on the FCC Covered List cannot use SDoC or the exemptions. It must go through Certification (2.906(d), 2.907(c), 15.103(j)). A final rule effective October 13, 2026, also bars authorization of devices that contain logic-bearing components from a Covered List entity, in cases where the device would be barred if that entity made the whole product (Federal Register 2026-18535, as of November 2026). Check your parts list against it early.
Who grants FCC certification, and who tests?
Two kinds of organization take part.
- Test labs run the measurements. For Certification, the lab must be accredited to ISO/IEC 17025 by an accrediting body the FCC recognizes, with reassessment at least every two years (47 CFR 2.948, as of November 2026). A lab outside the US qualifies only under a mutual recognition agreement or an FCC-recognized accreditation body.
- TCBs review the application and issue the grant. In the US, NIST accredits and designates TCBs, based on ISO/IEC 17065. A TCB outside the US must be designated under a mutual recognition agreement. Each TCB can certify only the equipment groups in its accreditation scope (47 CFR 2.960).
A TCB must also be able to test the equipment it certifies and be accredited to ISO/IEC 17025 (2.960(a)(6)). Ask which role each party plays on your project.
Who is responsible after the grant?
The grantee answers for a certified device. For SDoC, the responsible party must be in the United States, and for imported equipment it is the importer (47 CFR 2.909, as of November 2026). A US company that imports a device built abroad should expect to hold that role.
Changes after the grant fall into permissive change classes (47 CFR 2.1043). A Class I change does not degrade the reported characteristics and needs no filing. A Class II change degrades them but still meets the rules, and needs a filing and FCC acknowledgment before you market it. Other changes to frequency-determining circuits or maximum power need a new grant.
What must the FCC ID and label show?
Plan the label space during enclosure design. The small-device options depend on whether the text fits in four-point type and whether the device has a display.
| Item | What the rule requires | Rule (47 CFR) |
|---|---|---|
| FCC ID format | A grantee code that the FCC assigns, followed by a product code you choose. The product code is at most 14 characters: numerals, capital letters and dashes. | 2.926 |
| How the FCC ID appears | Preceded by "FCC ID" in capital letters on one line. Permanently affixed and visible to the buyer at purchase. Type must be legible and need not exceed eight-point. | 2.925(a), (d), (f) |
| Part 15 statement | Most devices state that they comply with Part 15 and that operation is subject to two conditions: no harmful interference, and acceptance of interference received. | 15.19(a)(3) |
| Device too small to label | If the statement will not fit in four-point type and there is no display, put it in the user manual and on the packaging or a removable label. | 15.19(a)(5), 2.925(f) |
| Electronic label | Allowed for a device with a screen, or one that only works with a device that has a screen. At most three steps from the settings menu, with no special codes. | 2.935 |
| SDoC identification | A unique identifier in a format that cannot be confused with an FCC ID, plus records that make each unit traceable. The FCC logo is optional. | 2.1074 |
Sources: 2.925, 2.926, 2.935, 2.1074, 2.1077 and 15.19, as of November 2026. We do not reproduce the full statement text here. Copy it from the rule itself.
Small wearables need a decision early. A ring or a pendant with no screen may have no room for four-point type. In that case the rules move the statement to the manual, plus either the packaging or a removable label. A device that can operate only with a paired phone may qualify for an electronic label, because 2.935 allows it for devices that only work with a device that has a screen. The device or its packaging must still carry the FCC ID or other identifying information (2.935(f)).
Can you market a device before FCC authorization?
The general rule is no. Section 2.803 bars marketing an RF device without a valid authorization, and marketing includes advertising and offers to sell (47 CFR 2.803, as of November 2026). The same section lists narrow exceptions.
| Activity | What the rule allows | Rule |
|---|---|---|
| Advertise, take orders or ship before authorization | Counts as marketing. The rule definition includes advertising, offers to sell, and importing or shipping for those purposes. | 2.803(a) |
| Conditional sales and preorders | Allowed with a prominent disclosure that delivery depends on completing authorization, plus your refund policy. No delivery to end users before authorization. Keep sales records for 60 months. | 2.803(d)(2)(i)(A), (F) |
| Moving certification devices into retail channels early | Allowed only after accredited lab testing and an application to a certification body. Each unit or package needs a temporary label saying it cannot be delivered, displayed or operated until certified. | 2.803(d)(2)(i)(C) |
| Moving SDoC devices early | Physical transfer to other entities before authorization is prohibited. | 2.803(d)(2)(i)(B) |
| Trade show display | Allowed with a conspicuous notice that the device has not been authorized and may not be sold or leased until it is. | 2.803(d)(2)(iii) |
| Listing on an online marketplace | For devices subject to Certification, marketplaces must show a valid FCC ID at the online point of sale. Compliance dates are March 1, 2027, and June 1, 2027, depending on the marketplace role. | 2.803(c) |
Source: 47 CFR 2.803, as of November 2026. Limited marketing applies only to devices that could be authorized under current rules, a waiver in effect, or adopted rules not yet in effect. Read the exact disclosure text in the rule before you publish a preorder page.
What to ask your hardware team about FCC certification
Take these to your engineering lead and your lab before the first board layout.
- Which parts of our device are intentional radiators, and which are only digital circuits?
- For each radio, are we reusing a module grant or applying for a new one?
- For the digital circuits, are we using SDoC or Certification, and who decided?
- Is any component or the finished device produced by an entity on the Covered List?
- Whose name goes on the grant, and who is the US responsible party for SDoC?
- Where does the label go: enclosure, manual and packaging, or a screen?
- What will we say on the preorder page and at trade shows before the grant?
- Which planned changes after the grant are permissive, and which need a new application?
At Duobay, FCC, lab and module rules are planned from Gate 0, before the first board. See how certification is planned from Gate 0.
Questions about FCC certification
Is FCC certification the same as an FCC ID?
They are linked. Certification is the approval process. The FCC ID is the identifier that a certified device carries. It combines a grantee code from the FCC with a product code the grantee chooses (47 CFR 2.926, as of November 2026). SDoC devices do not get an FCC ID.
Does a device with no radio need FCC approval?
Usually yes. A device with digital circuits clocked above 9 kHz is an unintentional radiator, and Part 15 lists SDoC or Certification for it (47 CFR 15.101). A few narrow cases are exempt under 15.103.
Can I take preorders before the grant?
Yes, under conditions. The rules allow conditional sales with a prominent disclosure that delivery depends on completing authorization, and you cannot deliver to end users before then (47 CFR 2.803, as of November 2026). This is an engineering summary and not legal advice.
Whose name should be on the grant?
Under the rules, the grantee is responsible for compliance of a certified device, and the grantee is the party named on the grant (47 CFR 2.909, as of November 2026). Decide whose name goes on it before the application, because that company carries the compliance duty.
How could Duobay help with FCC certification?
Duobay plans FCC, lab and module rules from Gate 0, before the first board. Certification and lab fees are paid by the client. We do not publish prices. Tell us about your device to start with a free initial call.
If you are planning a connected device and want the authorization path settled before design starts, tell us about your device.
Sources
All pages accessed November 5, 2026. Rules change, so check the current text before you decide.
- 47 CFR 2.803, Marketing of radio frequency devices: https://www.ecfr.gov/current/title-47/section-2.803
- 47 CFR 2.901, 2.906, 2.907, 2.909: https://www.ecfr.gov/current/title-47/section-2.901, https://www.ecfr.gov/current/title-47/section-2.906, https://www.ecfr.gov/current/title-47/section-2.907, https://www.ecfr.gov/current/title-47/section-2.909
- 47 CFR 2.925, 2.926, 2.935, Identification and electronic labeling: https://www.ecfr.gov/current/title-47/section-2.925, https://www.ecfr.gov/current/title-47/section-2.926, https://www.ecfr.gov/current/title-47/section-2.935
- 47 CFR 2.948, 2.960, Test labs and TCBs: https://www.ecfr.gov/current/title-47/section-2.948, https://www.ecfr.gov/current/title-47/section-2.960
- 47 CFR 2.1043, 2.1074, 2.1077: https://www.ecfr.gov/current/title-47/section-2.1043, https://www.ecfr.gov/current/title-47/section-2.1074, https://www.ecfr.gov/current/title-47/section-2.1077
- 47 CFR 22.377, 24.51, 27.51, Cellular transmitter certification: https://www.ecfr.gov/current/title-47/section-22.377, https://www.ecfr.gov/current/title-47/section-24.51, https://www.ecfr.gov/current/title-47/section-27.51
- 47 CFR 15.3, 15.19, 15.101, 15.103, 15.201: https://www.ecfr.gov/current/title-47/section-15.3, https://www.ecfr.gov/current/title-47/section-15.19, https://www.ecfr.gov/current/title-47/section-15.101, https://www.ecfr.gov/current/title-47/section-15.103, https://www.ecfr.gov/current/title-47/section-15.201
- Federal Register 2026-18535, Equipment Authorization Program final rule, effective October 13, 2026: https://www.federalregister.gov/documents/2026/09/11/2026-18535/protecting-against-national-security-threats-to-the-communications-supply-chain-through-the
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