FCC Certification for Radio Devices: Do You Need It?
Key takeaways
As of November 2026, products with Wi-Fi or Bluetooth transmitters generally need FCC certification from a TCB before import or sale. Digital-only products usually use SDoC, which needs a responsible party in the US, often the importer of record.
Which FCC authorization your product needs, and who has to hold it
Brands selling electronics in the US often ask us:
"Our device has Bluetooth. Do we need FCC approval before we ship?"
"Our factory has an FCC grant. Is that enough for us as the importer?"
"Can we send samples to buyers before the approval is done?"
The short answer: an RF device must be authorized before it is marketed, imported or used in the United States (FCC). Which authorization you need depends on what is inside the product.
1. Three device types decide the FCC path
The FCC sorts devices by how they emit radio frequency (RF) energy (FCC):
- An intentional radiator emits RF on purpose, such as a Wi-Fi or Bluetooth device. It uses Certification.
- An unintentional radiator has digital circuitry but does not transmit by design. It uses the Supplier's Declaration of Conformity (SDoC).
- An incidental radiator, such as an AC or DC motor or a mechanical light switch, needs no equipment authorization (FCC).
| FCC certification | SDoC | Incidental radiator | |
|---|---|---|---|
| Typical product | Wi-Fi or Bluetooth device | Digital-only device | Motor, mechanical switch |
| Testing | FCC-recognized accredited lab | Responsible party ensures compliance | |
| Who authorizes | TCB issues a grant | No filing with the FCC or a TCB | No authorization needed |
| FCC ID | Yes | No | No |
| Who is responsible | Grantee named on the grant | Responsible party located in the US |
Sources: FCC procedures, 47 CFR 2.909, 47 CFR 2.926, 47 CFR 2.1077.
Some guides still list Verification. Its transition ended November 2, 2018 (FCC).
Look at the circuit, not the product category.
2. How FCC certification works: lab, TCB, grant and FCC ID
FCC certification is a grant from an FCC-recognized Telecommunication Certification Body (TCB), after an FCC-recognized accredited lab tests the device (FCC).
The FCC ID has two parts: a grantee code the FCC assigns permanently to the company, and a product code the grantee assigns (47 CFR 2.926). The grantee "is responsible for the compliance of the equipment" (47 CFR 2.909).
A foreign factory can hold the grant. The importer "can rely on the foreign manufacturer for obtaining a certificate" (FCC).
Since February 6, 2023, every applicant, domestic or foreign, must name an agent located in the US to accept service of process (47 CFR 2.911). The agent stays at least one year after US marketing and importing end, or after any related administrative or judicial proceeding involving the equipment, whichever is later.
If your factory holds the grant, ask for the FCC ID and confirm it named a US agent.
3. SDoC needs a responsible party in the US
SDoC is a self-declaration with no filing to the FCC or a TCB (FCC). The responsible party "must be located within the United States" (47 CFR 2.1077). For an SDoC product made abroad, the FCC FAQ names the importer of record as the responsible party. It must give its name, address and telephone number or internet contact (FCC). Our US customs clearance guide explains the role.
For a digital-only product, the US importer usually carries the FCC responsibility, not the Korean factory.
4. Importing before authorization: the 11 conditions and sample limits
The FCC dropped its import form, Form 740, on November 2, 2017 (FCC). The rule stayed. An RF device may be imported only if it meets one or more of 11 conditions in 47 CFR 2.1204. Three of them let you import units before the grant:
| Condition | Unit limit | Can the units be sold? |
|---|---|---|
| Testing and evaluation, 2.1204(a)(3) | 4,000 or fewer | No sale or marketing |
| Trade-show demonstration, 2.1204(a)(4) | 400 or fewer | No sale or marketing |
| Pre-sale activity, 2.1204(a)(11) | 12,000 or fewer per FCC ID | Not delivered to end users before the grant |
Pre-sale imports are for Certification products only, after an accredited lab finishes testing and the application goes to a TCB. Each unit carries a temporary label saying it "cannot be delivered to end users, displayed, or operated" until certification. Recipient records are kept for 60 months (47 CFR 2.1204).
In FCC rules, "marketing" includes advertising for sale (47 CFR 2.803). An import that meets no condition "may result in refused entry" and other remedies (47 CFR 2.1203).
The HTS code does not settle it either: "there is no mapping between harmonization codes and FCC requirements" (FCC). Our HTS code guide covers what the code decides.
Under conditions 3, 4 and 11, units cannot be sold or marketed before the grant.
5. FCC ID and Part 15 labels
On the device, "FCC ID" in capital letters precedes the number on one line, in a type size "legible without the aid of magnification" (47 CFR 2.925). A device with a built-in display may show it there, but the device or its packaging still needs a label that identifies it (47 CFR 2.935).
Most Part 15 certification and SDoC devices also carry this statement (47 CFR 15.19):
"This device complies with part 15 of the FCC Rules. Operation is subject to the following two conditions: (1) This device may not cause harmful interference, and (2) this device must accept any interference received, including interference that may cause undesired operation."
If a device is too small to label in 4-point type and has no display, the statement goes in the manual and also on the packaging or a removable label (47 CFR 15.19). The manual alone is not enough.
Our US label requirements guide covers the other labels on the box.
6. What Amazon asks for
Amazon says "RF devices offered for sale on Amazon must be authorized using the appropriate FCC equipment authorization procedure" (Amazon).
On the listing, Amazon asks for a compliance status: an FCC ID, an SDoC, not capable of emitting RF energy, or incidental radiator (Amazon). Pick the one that matches your path in section 1.
7. The Covered List and the 2025 and 2026 lab rules
Equipment on the FCC Covered List "is prohibited from obtaining an equipment authorization" (47 CFR 2.903). Some entries have exceptions, such as conditional approvals. Check the Covered List for your module maker.
FCC 25-27, adopted May 22, 2025, aims to keep "untrustworthy actors" out of the equipment authorization program, including labs and TCBs (FCC). FCC 26-28 took effect June 15, 2026, with some sections delayed (Federal Register).
Confirm your lab and TCB are recognized before you book testing.
Four checks before your first electronics shipment
1. Does the product contain a transmitter, digital circuitry only, or neither?
2. Who holds the grant or acts as the US responsible party?
3. Do the FCC ID and the Part 15 statement appear where the rules require?
4. If you ship before the grant, which 2.1204 condition applies, and how many units?
Our UL certification guide covers product safety testing.
Wrap-up
FCC certification starts with one question: does the product transmit?
LinkONE runs Korea to USA freight as an FMC-registered NVOCC and offers import compliance consulting through import requirements and document review, from its Fullerton, California warehouse.
Know your FCC path and your responsible party before the product leaves Korea.
Frequently Asked Questions
Does a Bluetooth or Wi-Fi product need FCC certification?
Generally yes. The FCC treats Wi-Fi and Bluetooth devices as intentional radiators, and intentional radiators use the Certification procedure unless a rule says otherwise (FCC devices, FCC procedures).
What is the difference between FCC certification and SDoC?
Certification needs testing by an FCC-recognized accredited lab and a grant from a TCB, and it gives an FCC ID. SDoC needs no filing with the FCC or a TCB, but the responsible party must be located in the US (47 CFR 2.1077).
Can a Korean factory hold the FCC grant?
Yes. The importer can rely on the foreign manufacturer's grant (FCC). Since February 6, 2023, each applicant must name an agent located in the US for service of process (47 CFR 2.911).
Can I ship samples before FCC certification?
Yes, under set conditions. Testing and evaluation allows 4,000 or fewer units, and trade-show demos allow 400 or fewer, with no sale or marketing. Pre-sale imports allow 12,000 or fewer units per FCC ID after lab testing and a TCB application (47 CFR 2.1204).
Is FCC Part 15 certification a separate authorization?
Part 15 is a set of FCC rules, not a third authorization path. A Part 15 device subject to Certification or SDoC must carry the Part 15 compliance statement (47 CFR 15.19).
Sources
- FCC, Equipment Authorization: RF Device
- FCC, Equipment Authorization Procedures
- FCC, Equipment Authorization: Importation
- eCFR, 47 CFR 2.1204, Import conditions
Rules in this post are as of November 2026.
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