Information to clients about the FCC Labeling requirements of Intentional and unintentional radiators:
An approved transmitter certified as a module, must be labeled with its FCC ID directly on it. For finished products that use an approved transmitter in their product, i.e.… Wi-Fi or Bluetooth Module, the finished product must display the FCC ID of the approved transmitter as explained in the FCC rules in 15.212(a)(1)(vi)(A).
If a finished product uses an un-approved transmitter and the certification is performed on the finished product, then the Grant of equipment authorization will be issued for the finished product. In this case, the finished product will need to be labeled with the FCC ID on the exterior¹ of the product.
One of the big mis-understandings that manufacturers have is that if their product is small enough then they can put the labels in their manual instead of on the product. This is not true for the certification number (FCC ID) label. The FCC ID must be on the product. It can be a label, etched in on the exterior of the product, or be capable of being electronically displayed, but it must be visible and in a font that is reasonably visible without magnification.
The two-part warning label described in FCC 15.19(a)(3), “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.” Must be placed on the exterior of the product, however may be placed in the manual or on the exterior of the packaging if the product is smaller than 4”x4”, or roughly the size of the palm of your hand. This label is required for all products¹.
Another large miss-understanding is the use of the FCC symbol. Note that the FCC symbol has been incorrectly applied to numerous products for many years. Never use an existing product for verification of applicable labelling requirements; always seek the applicable rules first. The FCC requires that proper labelling be evaluated and affixed. In order to be able to use the FCC symbol shown in FCC 15.19(b), the equipment must qualify for DoC in accordance with 15.101. Devices not qualifying for DoC are not permitted to apply the FCC symbol. The authorization type for a given product is separated into two categories, Intentional Radiator and Unintentional radiator. Further information on equipment labeling can be found in the FCC’s KDB 784748 on equipment labelling .
-If a product requires only verification, then the required label is the 2-part warning label.
-If a product requires Certification, then the required label is the 2-part warning label AND the FCC ID.
-If a product is subject to DoC, then the required label is the FCC Symbol.
For devices subject to both Certification and DoC, they receive two marks of conformity, the FCC Symbol AND the Certification number. For devices subject to Certification _OR_ DoC, they get only one mark of conformity as selected by the responsible party (manufacturer). For example, if a product is subject to a DoC and a Certification, then that product would be required to display the FCC symbol and the FCC ID. If the product is subject to DoC_OR_ Certification, then it would only display the corresponding Mark of Conformity.
Information about products that are battery powered and use an approved AC/DC Power Supply.
Many manufacturers believe that if their product uses an AC/DC power supply that has been previously approved and has the compliance marks, then they do not need to test their product with the AC/DC power supply or perform Conducted Emissions test. This is not correct. The FCC CFR 47 Part 15.107(d) and 15.207(c) state the following:
“Devices that include, or make provision for, the use of battery chargers which permit operating while charging, AC adaptors or battery eliminators or that connect to the AC power lines indirectly, obtaining their power through another device which is connected to the AC power lines, shall be tested to demonstrate compliance with the conducted limits.”
This applies to all products that do not require the battery to be removed in order to charge it. Another point that gets missed by manufacturers and even some test labs, is that if a product only has a USB cable and can only receive its power from another device (e.g. a laptop or desktop computer), then the AC Mains Conducted Emissions test must be performed on the AC mains other device. The Host device tested should be that equipment which is sold with or specified for use with the product. If no such host is provided or specified, then a host must be selected which is representative of typical usage for the product; such as a laptop or a generic USB charger.
ANSI C63.4 is a measurement procedure for performing tests in the FCC rules. ANSI C63.4 states the following:
“If the EUT normally receives power from another device that in turn connects to the public-utility ac power lines, measurements shall be made on that device with the EUT in operation to ensure that the device continues to comply with the appropriate limits while providing the EUT with power. If the EUT is
operated only from internal or dedicated batteries, with no provisions for connection to the public utility ac power lines (600 VAC or less) to operate the EUT (such as an adapter), then ac power-line conducted
measurements are not required. Where required, dc power conducted emissions tests shall be performed the same way as that for ac power conducted tests.”
In summary, it is clear what these requirements are from the FCC Rules. Manufacturers should be made aware of these rules and requirements as there can be hefty fines and penalties for improper labeling, and marketing a product that does not meet the requirements of the rules. Do not be misled by anyone who does not understand the rules and regulations, and do not make the mistake of thinking your product does not need tested with the AC/DC power supply or adapter just because it has already been tested on its own.