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 >>
FCC ID Certification Compliance Certificate FCC ID Certification Compliance Certificate
04 .30.2025
FCC ID certifies RF products meet U.S. standards for safety and interference. JJR Lab provides testi...
How many types of FCC certifications are there? How many types of FCC certifications are there?
04 .30.2025
FCC certification includes SDoC and FCC ID for electronic and wireless devices. JJR Lab provides tes...
Australia RCM LOGO Certification Australia RCM LOGO Certification
04 .30.2025
RCM certification combines safety & EMC for AU/NZ market access. JJR Lab provides testing to hel...
ANATEL Certification Process in Brazil ANATEL Certification Process in Brazil
04 .30.2025
ANATEL certification is required for telecom products entering Brazil. JJR Lab provides testing to e...
Faucet European Standard EN 817 Testing Faucet European Standard EN 817 Testing
04 .30.2025
JJR Lab provides faucet testing and certification according to European standards EN 817, EN 200, EN...
ISO 17025 Laboratory Test Report ISO 17025 Laboratory Test Report
04 .30.2025
Amazon product removals may occur due to missing ILAC ISO17025 reports or label issues. JJR Lab prov...
Temu Requires UN 38.3 Certification Temu Requires UN 38.3 Certification
04 .30.2025
TEMU requires UN 38.3 certification for battery transport. JJR Testing Laboratory offers professiona...
What is the Amazon ASTM F2057 Test Report? What is the Amazon ASTM F2057 Test Report?
04 .30.2025
The ASTM F2057-23 standard ensures safety for clothing storage units, focusing on stability, flammab...

Leave Your Message