FCC Part 15 — Radio Frequency Devices / Equipment Authorization (47 CFR Part 15)

FCC Part 15 — Radio Frequency Devices / Equipment Authorization (47 CFR Part 15)

Issuing body / enforcer: U.S. Federal Communications Commission (FCC), Office of Engineering and Technology (OET). Jurisdiction: United States — any RF device marketed, imported, or operated in the U.S. "Marketing" includes offering for sale, advertising, and even displaying a non-compliant device; importers, manufacturers, and (increasingly) online marketplaces are in scope.

1. What it is

FCC Part 15 is the rulebook for unlicensed radio-frequency devices — everything that intentionally or unintentionally emits RF energy without an individual FCC station license. It sets technical limits (emissions, power, frequency stability) and the equipment authorization procedures that prove compliance before a device can be legally sold. Authorization runs through the FCC's Equipment Authorization database; most intentional radiators are certified by private Telecommunications Certification Bodies (TCBs) acting under FCC oversight.

2. Scope, triggers, thresholds

Part 15 is organized by subpart; the two that matter most for electronics/computer products:

• Subpart B — Unintentional radiators (digital devices, computers, peripherals, LED drivers, switching power supplies): authorized via Supplier's Declaration of Conformity (SDoC) — the manufacturer tests (in an accredited lab) and self-declares, no FCC filing. Class A (commercial/industrial) has looser limits than Class B (residential). SDoC replaced the old "Verification" and "Declaration of Conformity" routes in 2017.
• Subpart C — Intentional radiators (Bluetooth, Wi-Fi, Zigbee, LoRa, 2.4 GHz remotes, etc.): require Certification — testing plus a formal grant issued through a TCB, with an FCC ID on the device. This is the heavyweight route.
• Subpart D (UPCS), Subpart E (U-NII / 5–6 GHz Wi-Fi), Subpart F (UWB), Subpart G/H (power-line / TV-band devices) cover specialized cases.
• Modular transmitters (KDB 996369): pre-certified radio modules that integrators can embed without re-certifying the radio — provided the integration follows the module grant's conditions. This is the route most IoT products take.
• Trigger: any device that emits RF energy above Part 15 thresholds must be authorized before marketing. Note that Part 15 does not authorize operation in licensed bands and does not excuse interference — operation remains subject to the "must accept interference / must not cause harmful interference" conditions (15.5, 15.105).

3. Key requirements and compliance obligations

1. Choose the authorization route correctly: SDoC for unintentional radiators; Certification for intentional radiators. Getting this wrong (self-declaring a transmitter) is a violation.
2. Test to the right standard: ANSI C63.10 for unlicensed intentional radiators; ANSI C63.4 for unintentional radiators; KDB publications (notably KDB 996369 for modules, KDB 178919 for permissive changes and software-defined radio) carry the detailed FCC policy — they are effectively mandatory reading.
3. Permissive changes (2.1043): the grantee may make defined classes of changes without a new filing; anything touching frequency-determining circuitry, power, or modulation generally needs a new grant. Third-party firmware that changes radio parameters on a non-SDR device is not a permissible change — the modifier becomes the responsible party (2.909(d)). This bites companies that re-flash certified radios.
4. Labeling and user information: FCC ID on certified devices, SDoC compliance statements in manuals, and the Part 15 interference statements (15.19, 15.105).
5. RF exposure: devices near the body must meet SAR/MPE limits (2.1091/2.1093) via KDB 447498, 248227 (Wi-Fi), etc.
6. Import conditions (2.1204): devices must be authorized before import; CBP can seize non-compliant shipments.
7. Marketing rules (2.803): no advertising or sale before authorization is complete, with narrow exceptions (e.g., sales to developers of evaluation kits, which may not be resold as finished products).

4. Penalties and consequences

• Forfeitures: the FCC's base forfeiture for marketing unauthorized RF devices is on the order of $7,000 per violation, with statutory maxima per violation per day in the six figures (inflation-adjusted — [Flag: confirm the current inflation-adjusted statutory maximum; it moves annually]). Each unit marketed can count separately.
• Enforcement tools: Notices of Apparent Liability, consent decrees, equipment seizure at import, and — increasingly — pressure on marketplaces.
• Non-monetary consequences: TCBs can have recognition pulled; grantees can lose grant authority; products get delisted from retail channels once an enforcement action lands.

5. Live changes (verified against current sources, 2026-09-30)

The equipment-authorization program is being reshaped by a national-security supply-chain campaign. Engineers shipping connected hardware must track this, not just the emissions limits:

• October 2025 — Second Report & Order: clarified that the prohibition on authorizing "covered equipment" (equipment from entities on the FCC's Covered List under the Secure and Trusted Communications Networks Act) applies to modular transmitters — authorizing a host product containing a covered module effectively authorizes the module, so it is barred. Also created a procedure for OET to restrict marketing of previously authorized covered equipment (without revoking the underlying grants).
• December 2025 / January 2026 — Covered List expansions: foreign-produced drones (UAS) and key components added regardless of manufacturer; DJI, Autel Robotics and affiliates named. (A limited carve-out runs to January 1, 2027 for Blue UAS-listed / Buy-American-compliant items.)
• July 22, 2026 — Third Report & Order: expanded the ban to end products containing "logic-bearing hardware components" produced by Covered List entities — this reaches far beyond finished radios into subassemblies and chips — and extended marketing-rule liability to online marketplaces offering fulfillment/warehousing/billing. Covered List entities must now fully recertify (no permissive changes) before modifying any equipment.
• August 7, 2026 — Third FNPRM: proposes reorganizing the Covered List around a production-location approach, new white-labeling rules (branding someone else's certified equipment under your own name), and a requirement that every certification applicant designate a U.S.-based liable party. Comments were due September 8, 2026 — [Flag: outcome not yet known as of 2026-09-30; check the docket before advising.]
• March 2026: foreign-produced consumer routers added to the Covered List posture, blocking authorization of new models without conditional approval — directly relevant to Wi-Fi product roadmaps (this is why several vendors' "Wi-Fi 8" launches face U.S. uncertainty).
• KDB updates: KDB 940660 (CBRS/LTE Band 48) updated December 2025, removing equipment class CBC and adding repeater guidance — [Flag: verify the current KDB 940660 text for CBRS products.]

6. Related certifications

• iNARTE EMC Engineer (Telecom/RF flagship): directly tests EMC/EMI competence including FCC Part 15 emissions, test methods, and mitigation — the closest certification to this regulation.
• FCC GROL (General Radiotelephone Operator License): covers FCC rules and radio law broadly; relevant to engineers working with licensed services alongside Part 15 devices.
• BICSI RCDD (Computer/Telecom): touches structured-cabling emissions and installation practices that interact with Part 15 compliance at the system level.
• Note: there is no "FCC Part 15 engineer" license; competence is demonstrated through accredited-lab test experience and TCB-grant history.

7. Practical notes

• Budget the authorization path at design kickoff: Certification through a TCB takes weeks and real money; discovering at EVT that your "module" integration violates the grant conditions is a schedule-killer.
• Keep the grant conditions document for every module you integrate — antenna types, host integration rules, and RF-exposure conditions are where most integrators fail.
• If your product contains any component from a Covered List entity, the 2025–2026 rules may now block authorization entirely — screen the bill of materials for Covered List exposure, not just the finished radio.

Original ETS reference writing, verified against public sources on 2026-09-30. Thin sourcing is flagged inline. Not legal advice — confirm current editions with the issuing body.