47 CFR Part 15 covers electronic and electrical devices sold, imported, or manufactured in the United States. In this guide, we explain what you must know about device types, labeling requirements, documentation, testing, and more.
We also compare how the requirements and processes differ for intentional and unintentional radiators.
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Product Scope and Devices Classification
47 CFR Part 15 regulates electronic and electrical devices that can emit radiofrequency energy, and that might cause interference to devices that operate in the radio frequency range of 9 kHz to 3,000 GHz.
It classifies devices into three different categories:
- Unintentional radiators
- Intentional radiators
- Incidental radiators
What is an Intentional Radiator?
An intentional radiator is defined as a device that generates and emits radio frequency energy by radiation or induction. This includes most Wi-Fi, 3G, 4G, 5G, Bluetooth, LTE, or active RFID devices.
Most intentional radiators must be authorized according to the Certification procedure.
Examples of Intentional Radiators
What is an Unintentional Radiator?
An unintentional radiator is defined as a device that intentionally generates radiofrequency energy for use within the devices, or sends signals via connecting wiring, but is not designed to emit radiofrequency energy by radiation or induction.
Most unintentional radiators must be authorized according to the Supplier’s Declaration of Conformity (SDoC) procedure.
Examples of Unintentional Radiators
What is an Incidental Radiator?
An incidental radiator generates or emits radiofrequency energy, even if it is not intentionally designed for it. They are often components that are integrated into devices that are classified as either unintentional or intentional radiators.
Incidental radiators do not require equipment authorization. However, they must still comply with the general operating conditions set in 47 CFR Part 15.
This means, for example, that you must still lessen the risk of possible harmful interference by using good engineering practices.
Examples of Incidental Radiators
- Electrical motors
- Mechanical light switches
47 CFR Part 15 exempts a few types of devices from equipment authorization.
According to 47 CFR Part 15.23, devices do not require equipment authorization if they are:
- Not marketed
- Not constructed from a kit
- Built-in quantities not exceeding five for personal use
Individuals who build home-built equipment may not be able to fully assess whether the equipment complies with the FCC’s requirements. As such, that individual should exercise good engineering practices to ensure that the equipment complies with relevant requirements as much as possible.
Power line carrier systems
Power line carrier systems are exempt from equipment authorization.
However, according to 47 CFR Part 15.113, they are still subject to several requirements, such as the following:
a. Signals of its operating parameters should remain within the frequency band 9 kHz to 490 kHz.
b. Systems should operate on an “unprotected, non-interference basis”.
c. System apparatus should be operated with as minimal power as possible.
Other exempted devices
47 CFR Part 15.103 lists several more devices exempted from authorization, such as:
a. Digital devices used exclusively in appliances (e.g., clothes dryers).
b. Specialized medical digital devices.
c. Joystick controllers or similar devices that do not contain digital circuitry.
d. Digital devices that feature a power consumption of less than 6 nW.
Digital Device Classes
Before importers and manufacturers search for applicable technical requirements for their unintentional radiators, they should determine whether their devices are categorized as Class A or Class B, per the definitions below. The reason is that the requirements might differ, according to the class.
Class A digital devices
47 CFR Part 15.3(h) defines a Class A digital device as a device marketed for use in the following environments:
Class A digital devices do not include those marketed for use by the general public or in homes.
Class B digital devices
47 CFR Part 15.3(i) defines a Class B digital device as a device marketed for usage in the following environments:
These devices include but are not limited to personal computers and calculators.
47 CFR Part 15 provides general technical requirements such as conducted limits, radiated emission limits, and antenna power conduction limits for both unintentional and intentional radiators.
You can search for specific technical requirements based on the operation band of the device. For each range of the relevant frequency band, the regulation sets limits for the following:
- Input power
- Transmission line
- Field strength
- Frequency tolerance
Examples (unintentional radiators)
For example, devices with a frequency of emission (MHz) between 0.5-5, should not exceed 56 dBμV of the conducted limit in Quasi-peak. Also, the field strength should not exceed 100 microvolts/meter if the frequency of emission (MHz) is between 30-88.
For some specific categories of products, such as TV broadcast receivers and scanning receivers, the regulations provide specific requirements.
Examples (intentional radiators)
For devices that work with a frequency (MHz) between 1.705-30, the field strength should not exceed 30 microvolts/meter), and the measurement distance should not exceed 30 meters.
Also, in this case, there are specific requirements for some categories of products, for instance, wireless microphones.
47 CFR Parts 15.31 incorporates by reference several ANSI standards that outline the measurement procedures used to assess compliance with the technical requirements. Below, we briefly describe some of the standards.
ANSI C63.4 – Measurement of Radio-Noise Emissions from Low-Voltage Electrical and Electronic Equipment in the Range of 9 kHz to 40 GHz
This standard sets guidelines for measuring radiofrequency signals and noise emitted by unintentional radiators, which includes electrical and electronic devices operating within a 9 kHz to 40 GHz bandwidth.
The standard’s specifications are harmonized with other national and international standards where possible.
ANSI C63.10 – Compliance testing of unlicensed wireless devices
This standard covers testing procedures for various types of intentional radiators, such as the following:
- Cordless telephones
- Medical unlicensed wireless devices
- Intrusion detectors
This standard doesn’t contain test methods for unlicensed wireless devices that other published standards have already covered.
ANSI C63.17 – American National Standard Methods Of Measurement Of The Electromagnetic And Operational Compatibility Of Unlicensed Personal Communications Services (UPCS) Devices
This standard covers test methods for verifying the electromagnetic and operational compatibility of some types of intentional radiators, such as the following:
- Wideband voice devices
- Data devices
The standard also includes relevant requirements regarding radio-frequency emission levels and spectrum access procedures.
47 CFR Part 15.38 lists additional standards that are incorporated by reference in the regulation. We list some of them below.
ANSI/SCTE 54 – Digital Video Service Multiplex And Transport System Standard For Cable Television
This standard applies to unintentional radiators and describes normative specifications and transport layer characteristics of the in-band Service Multiplex and Transport System Standards for Cable Television.
The transport format and protocol is a “compatible subset” of the Moving Picture Experts Group 2(MPEG-2) Systems specification defined in ISO/IEC 13818-1.
It is based on a fixed-length packet transport stream approach.
ANSI/SCTE 65 – Service Information Delivered Out-of-Band for Digital Cable Television
This standard covers unintentional radiators and defines Service Information (SI) tables that are delivered via an out-of-band path to support the following:
- Digital cable set-top boxes
- Other “digital cable-ready” devices
The SI tables are formatted according to PSI data structures in MPEG-2 systems.
ETSI EN 300 422-1 – Electromagnetic compatibility and Radio spectrum Matters (ERM); Wireless microphones in the 25 MHz to 3 GHz frequency range
This standard covers unwanted emissions, bandwidth limits, and other specifications for wireless microphones (which are classified as intentional radiators) in the 25 MHz to 3 GHz frequency range.
The FCC requires most electronic devices to undergo one of two authorization procedures – the SDoC procedure, or the certification procedure.
Generally speaking, the SDoC procedure applies to unintentional radiators, while the certification procedure applies to intentional radiators. Some devices may contain both types of radiators, so importers and manufacturers of such devices may need to have them undergo both procedures.
Supplier’s Declaration of Conformity (SDoC) procedure
The FCC requires importers and manufacturers of unintentional radiators to authorize their devices via the SDoC procedure before placing them on the market. This procedure is considerably less strict than the certification procedure.
The SDoC procedure generally applies to unintentional radiators such as the following:
- Coffee machines
- LED lighting
- Power banks
This procedure also applies to some intentional radiators exempted from the certification procedure, for instance:
- Cable locating equipment
- Devices operating as carrier current systems
- Devices operating below 490 kHz
The responsible party (e.g. the importer or manufacturer) following the SDoC procedure should:
1. Have their products tested against relevant technical requirements, though not necessarily by an FCC-recognized test lab.
2. Draft an SDoC compliance information statement affirming that their products comply with relevant FCC requirements.
3. Label the product and provide information to the customer (e.g., instruction manual).
The responsible party must:
1. Ensure products comply with relevant technical standards.
2. Provide a test report to the FCC upon request.
3. Provide relevant compliance information (e.g., SDoC, labeling, instructions).
Importers and manufacturers of intentional radiators must have their devices undergo the certification procedure. This procedure is the most rigorous, as devices must be authorized by an FCC-recognized Telecommunication Certification Body (TCB). The reason is that devices subjected to it are deemed to pose the most harm to radio services.
The certification procedure applies to intentional radiators such as the following:
- Bluetooth radio devices
- Cordless telephones
- Wireless microphones
Some types of unintentional radiators also require authorization via the certification procedure:
- Access broadband over power line (Access BPL)
- Radar detectors
- Scanning receivers
The responsible party following the certification procedure should:
1. Have an FCC-recognized accredited testing lab perform product testing against relevant technical requirements.
2. Obtain a 10-digit FCC Registration Number (FRN).
3. Obtain a Grantee Code, upon application, on the Grantee Registration website.
4. Apply with a TCB (per 47 CFR Part 2.1033) for a grant of certification.
The TCB’s next course of action is to:
1. Review the submitted information to determine the product’s compliance with FCC’s requirements.
2. Upload said information to the FCC Equipment Authorization Electronic System (EAS) Database if the product is deemed to be compliant with the requirements.
3. Issue a grant of certification on the database.
The FCC mandates importers and manufacturers of intentional radiators to ensure their products comply with the following requirements:
1. Adhere to relevant standards (e.g., ANSI C63.10) and other relevant technical requirements (e.g., good engineering practice per 47 CFR Part 15.15).
2. Create a technical report per 47 CFR Part 2.1033.
3. Obtain a grant of certification from a TCB.
4. Label the device with an FCC ID and a compliance statement.
In this section, we cover the documentation requirements that are necessary to comply with the regulation.
The user manual should instruct users on how to use the device properly. Although the regulation doesn’t specify the requirements, a user manual typically should include information such as:
- Product installation
- Power charging instructions
- Product component details
- How to correctly dispose of the devices
- Safety instructions, and potential hazards
Additionally, 47 CFR Part 15.105 requires importers or manufacturers to include a note in the user manual that provides information concerning:
- The class of device (A or B)
- Compliance statement
- Risks related to radiations or interferences
Finally, the SDoC Compliance Information Statement should also be included in the user manual.
The responsible party adhering to the certification procedure must draft a technical report, which requires items such as the following:
a. Applicant’s and agent’s name and contact details.
b. A signed statement certifying that the product is not prohibited from equipment authorization.
c. FCC identifier.
d. A copy of the device’s installation and operation instructions.
e. A report of measurements with evidence of compliance with FCC’s requirements.
f. Photographs of the product’s exterior appearance, construction, component placement on the chassis, and chassis assembly.
When your product passes lab testing, you receive a test report that proves your product’s compliance with FCC requirements.
Both the SDoC and certification procedures require responsible parties to provide a test report as part of their documentation.
However, only the certification procedure mandates that an FCC-recognized accredited test lab perform product testing.
SDoC Compliance Information Statement
According to 47 CFR Part 2.1077, responsible parties complying with the SDoC procedure must supply the users with a compliance information statement with their products. The statement should include the following information:
a. Identification of the product (e.g., name and model number).
b. Compliance statement.
c. Responsible party information.
Note: If a product is assembled from modular components (e.g. enclosures) then you should also add the information necessary to identify such as components.
While some labeling requirements apply to all covered devices, other requirements are specific to the relevant authorization procedure.
47 CFR Part 15.19 requires importers and manufacturers to ensure that their devices carry a compliance statement. The statement should generally read as follows:
“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.”
Some specific devices, such as receivers or selector switches, may require slightly different compliance information statements.
Receivers should bear the following compliance statement:
“This device complies with part 15 of the FCC Rules. Operation is subject to the condition that this device does not cause harmful interference.”
Stand-alone cable input selector switches should generally carry this statement:
“This device complies with part 15 of the FCC Rules for use with cable television service.”
Product identification label (only for devices subject to SDoC)
The FCC requires devices subject to the SDoC procedure to be uniquely identifiable, using a label that should include items such as the following:
- Trade name
- Type, model or serial number
FCC Logo (only for devices subject to SDoC)
Responsible parties have the option to use the FCC logo for SDoC-authorized devices.
They may only place an FCC logo on a product if the product has been tested and found to be compliant with the SDoC procedure.
FCC ID (only for devices subject to Certification)
47 CFR Part 2.925 requires importers and manufacturers to ensure that their certification-authorized devices carry an FCC identifier (FCC ID), which should contain:
a. The term “FCC ID”.
b. Grantee code – representing the applicant.
c. A product code – representing the product, assigned by the grantee.
The FCC ID should be clear, readable, and have a size consistent with the product’s dimensions.
Importers and manufacturers should generally affix the label information on their products.
If the product has an electronic screen, they can place the label information there. In this case, they should also provide the label information via:
- User instructions
- Packaging inserts
- Product packaging
If the product is too small and does not have an integrated screen, importers and manufacturers should place the label information:
- In the user instructions, and
- On the device packaging, or
- On a removable label attached to the device
Lab Testing Requirements
Both the SDoC and certification procedures require the responsible parties to have their products tested to prove that their devices comply with relevant requirements. When the product passes lab testing, the responsible party receives a test report that proves the product’s compliance with FCC’s requirements.
Tests relevant to FCC Part 15
Here, we list some examples of requirements that might require testing under 47 CFR Part 15:
- Occupied bandwidth
- Radiated fundamental emissions
- Radiated spurious emissions
Also, here are two examples of testing standards relevant to 47 CFR Part 15:
- ANSI C63.4 – for unintentional radiators
- ANSI C63.10 – for intentional radiators
FCC-accredited lab testing companies
Responsible parties that must authorize their product via the certification procedure must have their products tested by an FCC-recognized accredited lab. We list a few such labs in the US below:
- Bureau Veritas Consumer Products Services, Inc.
- Eurofins Electrical And Electronic Testing NA, Inc.
- Intertek Testing Services NA, Inc.
- TUV Rheinland of North America Inc.
- UL Verification Services Inc.
You can find more FCC-accredited test labs on this page.
We summarize, in the table below, the requirements for unintentional and intentional radiators.
|Unintentional radiators||Intentional radiators|
|Procedure||Supplier’s Declaration of Conformity (SDoC)||Certification|
|SDoC||Required (excluding some exceptions)||Not required (excluding some exceptions)|
|Certification||Not required (excluding some exceptions)||Required (excluding some exceptions)|
|Product identification label||Required||Not required|
|FCC logo||Optional||Not required|
|FCC ID||Not required||Required|
|Lab testing||Required||Required (from an FCC-recognized accredited testing lab)|