EMC China Lab

FCC-ID: Still Needed if Module is Certified?

Views :
Update time : 2025-04-24

The client manufactures electronic door locks and uses a purchased Bluetooth module. The supplier has already obtained an FCC-ID certificate for the Bluetooth module. Now the client intends to export the complete product (Bluetooth smart lock) to the United States. Is it necessary to apply for a separate FCC-ID for the whole device?

 

FCC-ID: Still Needed if Module is Certified?(图1)


Core Requirements of FCC Certification

Whether the Bluetooth smart lock needs a separate FCC-ID certification depends on FCC rules for modular devices. Key points include:

 

1. Scope of FCC-ID:

- Any electronic device with wireless transmission (Bluetooth, WiFi, ZigBee, etc.) sold in the U.S. must obtain FCC-ID certification.

- The complete product must have a unique fcc identifier on its label.

 

2. Rules for Modular Devices:

- If the Bluetooth module is already FCC-ID certified and meets FCC Modular Approval conditions, the host device may not need new certification.

- If the module does not meet those conditions or the host device design affects RF performance, then full FCC-ID certification for the entire product is required.

 

Key Evaluation Criteria

Criterion 1: Does the module meet Modular Approval requirements?

According to FCC KDB 996369, the following must be met:

 

- The module must have RF shielding.

- It must have a fixed antenna or standardized connector (e.g., U.FL).

- Power supply must be voltage-regulated.

- It must pass all FCC tests (power, frequency, spurious emissions).

- The grantee must sign a Modular Approval Declaration.

 

If these are not fully met, full FCC-ID certification for the host device is required.

 

Criterion 2: Does the host device affect RF parameters?

Even if modular approval exists, changes may still require re-certification:

 

- Changing antenna type, layout, or gain.

- Host circuits (like motors or displays) cause RF interference.

- Metal casing or layout causes RF signal attenuation beyond certified levels.

 

Recommended Actions

Scenario 1:

Module meets Modular Approval conditions AND host device does not change RF performance

 

→ No need to apply for a new FCC-ID

 

Actions:

- Label the device with the module's FCC-ID (e.g., FCC ID: XXXXXXXX).

- User manual must state: "This device contains FCC ID: XXXXXXXX."

- Conduct fcc part 15B testing for EMC and apply for SDoC (Supplier’s Declaration of Conformity).

 

Scenario 2:

Module does not meet Modular Approval OR host design affects RF

 

→ FCC-ID certification for the complete device is REQUIRED

 

Steps:

- Submit application to a TCB (Telecommunication Certification Body).

- Provide the module's FCC-ID certificate and test report.

- Test the complete product for Part 15C (RF) and 15B (EMC).

- Obtain a new FCC-ID for the complete product and label it accordingly.

 

Compliance Risks

Warning 1: Improper FCC-ID use

If a host device does not meet Modular Approval criteria but uses the module’s FCC-ID, it may be detained at customs or fined by the FCC (up to $21,928 per day).

 

Warning 2: Labeling and documentation

Even if a new FCC-ID is not required, labeling and user documentation must comply with FCC regulations. Non-compliance can still result in penalties.

 

Summary of Key Factors:

- If the module meets Modular Approval:

→ No need for new FCC-ID; just label and SDoC (Part 15B)

 

- If the module does not meet Modular Approval:

→ Full deviCE certification (FCC Part 15B + FCC Part 15C) and new FCC-ID required

 

- If the host device affects RF parameters:

→ Full device certification (Part 15B + Part 15C) and new FCC-ID required


Email:hello@jjrlab.com


Leave Your Message


Write your message here and send it to us


Related News
Read More >>
What Are FCC-ID and IC-ID? What's the Difference? What Are FCC-ID and IC-ID? What's the Difference?
05 .24.2025
FCC-ID and IC-ID are radio certifications for the US and Canada. JJR Lab China provides expert testi...
What is ANSI/UL 4200A-2023 (16 CFR 1263) Testing? What is ANSI/UL 4200A-2023 (16 CFR 1263) Testing?
05 .24.2025
ANSI/UL 4200A-2023 tests coin cell safety to reduce child risk. China JJR Lab offers certified testi...
Radiated Emission Testing Services Radiated Emission Testing Services
05 .23.2025
China JJR Laboratory provides radiated emission (RE) testing for electromagnetic interference from 3...
Conducted Emission Testing Services Conducted Emission Testing Services
05 .23.2025
China JJR Laboratory offers conducted emission testing services to ensure compliance with global EMC...
Standards for Electrical and Small Household Appli Standards for Electrical and Small Household Appli
05 .23.2025
JJR Lab in China offers EMC testing for electrical and small household appliances, ensuring complian...
Household Appliance Testing Projects and Standards Household Appliance Testing Projects and Standards
05 .23.2025
CE and safety testing for household appliances, including EMC and LVD, provided by China JJR Lab to ...
What is the IEC 62321 Standard Test? What is the IEC 62321 Standard Test?
05 .23.2025
IEC 62321 testing ensures RoHS compliance by detecting hazardous substances in electronics. Provided...
UL4200A Certification Process for Button Cell Batt UL4200A Certification Process for Button Cell Batt
05 .23.2025
UL4200A testing, required for US sales of button battery products, ensures child safety. Certified a...

Leave Your Message