New to wireless? Understand FCC certification for IoT products

July 02, 2015


New to wireless? Understand FCC certification for IoT products

To succeed in this new IoT world, the question isn't simply, "How do we design a wireless product?" but more appropriately, "How do we successfully ge...

  • To succeed in this new IoT world, the question isn’t simply, “How do we design a wireless product?” but more appropriately, “How do we successfully get our wireless product to market?” Literally thousands of established companies that have never had to consider Federal Communications Commission (FCC) certification and compliance testing for a product that contains an “intentional radiator” will now have to account for this additional requirement in their product development process to gain market entry.

    While the estimated figures may vary depending on the source, one thing is certain – the Internet of Things revolution has begun, and it’s going to be big. The reality is that in order to reach those estimated billions of Internet-connected devices as soon as 2020, a lot of products that historically were not wireless in nature are going to be re-engineered to become “smart.” That means engineering teams that have deep technical disciplines in areas vital to their product and industry will have another competency to account for: RF design.

    To succeed in this new IoT world, the question isn’t simply, “How do we design a wireless product?” but more appropriately, “How do we successfully get our wireless product to market?” Literally thousands of established companies that have never had to consider Federal Communications Commission (FCC) certification and compliance testing for a product that contains an “intentional radiator” will now have to account for this additional requirement in their product development process to gain market entry.

    Simply put, without the proper FCC certification in place, your wireless product cannot be sold and marketed in the U.S. So for those product developers who have a wireless-enabled solution on their company’s product roadmap, let’s discuss some of the key considerations of EMC testing and FCC certification:

    1. You must understand the certification requirements of all of the countries into which you wish to sell your product.

    Unfortunately, there is no global certification body in place with universal standards you can test your product against. In the United States, the FCC is the certifying body; in Canada, it’s Industry Canada (IC); in the European Union, testing is performed against the European Telecommunications Standards Institute (ETSI) requirements for CE approval. Each country you wish to sell into will have similar, but also very different, certification and testing requirements. Identifying all the vital certifications that are needed is critical for your commercial teams to successfully launch your product. For the sake of clarity in this article, we will focus on the FCC requirements for the U.S.

    2. Depending on your product design there are different levels of requirements for FCC certification.

    Perhaps the largest question lingering in your mind as you look to bring a wirelessly enabled product to market is simply, “What are the FCC’s testing requirements for my product?” FCC Part 15 regulates unlicensed radio frequency transmissions, both intentional (like a Bluetooth Smart data transmission) and unintentional (like the EM noise that a motor emits).

    The FCC has defined three categories of equipment approval for Part 15 devices. One of those categories, Product Certification, is the most detailed and formal process imposed by the FCC. Any product that is utilizing a wireless technology such as Wi-Fi, Bluetooth, or Zigbee will fall under this category. For Product Certification, the testing required must be performed by an accredited laboratory and documentation is then supplied for review by a Telecommunication Certification Body (TCB), or, in some cases, the FCC itself.

    FCC testing for Product Certification can be broken into two parts: General Emissions testing and Intentional Radiation testing. Virtually every electronic product needs to undergo General Emissions testing. These tests typically can be completed at a cost of $1,000 to $5,000 when performed by an accredited laboratory. For Intentional Radiation testing there are additional tests required to specifically evaluate a product’s wireless technology, and as a result it is generally more involved and complex than General Emissions testing. Depending on the technology and the frequency or frequencies the product operates at (2.4 GHz, e.g.), this testing typically costs on the order of $9,000 to $15,000.

    The good news is that there’s a way to minimize not only the cost of these Product Certification requirements, but also to minimize both your total design time and the risk of designing a product that fails FCC testing. A product that utilizes a certified RF module, such as the SaBLE-x Bluetooth Smart module from LSR, as opposed to a discrete circuit design can leverage the certification of the off-the-shelf module and avoid the Intentional Radiation testing portion of the FCC certification process (Figure 1). For many companies, the time to market, risk mitigation, and lower non-recurring engineering (NRE) costs of their product development efforts makes the use of a certified RF module the optimal strategy.



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    3. Depending on the wireless technology you are employing, there may be additional certifications required beyond the FCC.

    For example, let’s suppose your product application utilizes Bluetooth or Bluetooth Smart technologies. In addition to the regulatory requirements of the FCC to allow the sale of your product in the US, there is another regulatory body that also must be addressed: the Bluetooth Special Interest Group (Bluetooth SIG).

    In February of 2014, the Bluetooth SIG implemented some significant changes to its requirements regarding the membership and associated fees to be able to release an official Bluetooth product, and only manufacturers who follow these new regulations have the legal right to market their product using the Bluetooth name and logo, amongst other things. So before you finalize your product and slap a “Bluetooth” or “Wi-Fi” logo on the packaging, you must understand their requirements and pay the appropriate membership fees.

    4. Understand what’s on the horizon for regulatory testing and certification of IoT products.

    As a product developer, you must also have an eye on upcoming changes and trends in certification requirements for wireless products. There are two particular changes worth mentioning.

    First of all, in January 2015 the FCC announced a significant change in who is able to administer the testing for Product Certification. While in the past what was referred to as a “listed” EMC testing facility was able to provide such services, this will no longer be the case as early as 2016. At that point, only FCC-recognized laboratories will be allowed to administer such tests and submit the test data for FCC Product Certification. This will have big implications for companies who tend to utilize test laboratories that are located in countries that do not have mutual recognition agreements (MRAs) in place with the U.S., such as labs in China, as these labs are currently not recognized by the FCC.

    Another current trend could have a significant impact on one of the highest growth verticals of the IoT space: wearables. Industry Canada, the regulatory body that certifies wireless products in Canada, has revised the exemption limits and requirements for specific absorption rate (SAR) testing. As a result, some products and technologies that were previously exempt from SAR testing will now require SAR testing in order to obtain IC certification. SAR testing is the test methodology used to quantify the rate or amount of RF energy absorbed by the human body. The corresponding limits or thresholds are measured in W/kg. As you can imagine, wearable technologies that are placed directly in contact with the human body fall right in the crosshairs of these types of tests. Currently the requirements in the U.S. and Canada are different, but the FCC continues to adjust and provide guidance on the SAR requirements. Product separation from the human body, output power of the device, and frequency of operation are major factors in determining if SAR testing is required.

    5. If this is our first wireless development project, how do we begin?

    The best advice is to seek out an accredited EMC testing laboratory that is willing to partner with you and provide guidance throughout your development timeline. Companies tend to struggle to meet FCC certification requirements with their new products because they view it as a check-the-box activity to worry about once the product design is near completion. The reality is that addressing FCC compliance considerations from the very early stages of development is a huge predictor of successful certification testing. For example, designing with certified RF modules or planning to perform “pre-scan” tests of your product’s electronics after each board spin are both prudent strategies to ensure no surprises occur during final testing that end up costing your project significant re-design time and expenses.

    The technology of IoT is opening up innovative ways your products can even better solve your customer’s challenges. Understanding not just how to design a wireless-enabled product, but designing it to ensure it will meet FCC requirements so it can be sold in the U.S. is key to your company’s ability to capitalize on the vast opportunities the IoT is creating in your market. These key considerations are a good start to creating a plan for a successful design.

    To review the detailed certification requirements of the FCC and IC, download the “FCC/IC Handbook” from LSR. LSR is a manufacturer of certified RF products, as well as an ISO 17025 accredited EMC and RF testing laboratory.

    Tom Smith is Vice President of EMC Test Services for LSR, a global leader in wireless product development services and products. He has over 15 years of experience in EMC/RF testing on a variety of products in the industrial, commercial, and medical industries. Tom has managed or assisted in over 200 FCC/Industry Canada filings and has an in-depth understanding of the self-declaration process for the European Union (EU). Tom received a Bachelor of Science in Biomedical Engineering from the Milwaukee School of Engineering (MSOE), and is an active member of and contributor to the IEEE. You can learn more about LSR’s EMC test services at

    Dave Burleton is Vice President at LSR. With over 12 years of experience in product management, strategic marketing, field sales, and sales operations, he approaches new product development from a broad array of perspectives, while maintaining a singular focus on demonstrating value to the customer. He holds a Bachelor of Science degree in Electrical Engineering and Mathematics from the University of Wisconsin – Madison. You can learn more about LSR’s certified modules at and LSR’s end-to-end IoT Platform solution at






Tom Smith, LSR
Figure 1: Off-the-shelf wireless platforms such as the SaBLE-x Bluetooth Smart module can be leveraged in connected systems to circumvent the costs associated with Intentional Radiation testing.
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