FCC-ID Certification in the USA: Is Separate Certification Required for Complete Products if the Internal Bluetooth Module is Certified?

The module is certified

Is separate certification required for the complete product?

Current product: Smart Bluetooth Door Lock

Event Background

The client manufactures electronic door locks, and the Bluetooth module inside is purchased from a supplier that has already certified the Bluetooth module with an FCC-ID certificate. Now, the client wants to export the complete product, the Bluetooth electronic lock, to the United States. Is it necessary to apply for a separate FCC-ID certificate?

1. Core Requirements of FCC Certification

Based on the client’s description, whether the Bluetooth electronic lock requires a separate FCC-ID certification for export to the United States must be judged comprehensively according to the FCC’s rules for modular device certification. The following is a specific analysis:

1. Scope of FCC-ID Application

Any electronic device with wireless transmission capabilities (such as Bluetooth, WiFi, ZigBee, etc.) sold in the U.S. market must apply for FCC-ID certification, and the complete product must display a unique FCC identifier.

2. Special Rules for Modular Devices:

If the Bluetooth module has passed FCC-ID certification and meets the conditions for FCC modular approval, the complete product may not require re-certification;

If the module certification does not meet the “modular approval” requirements, or if the design of the complete product affects RF performance, a new FCC-ID application for the complete product is required.

2. Key Judgement Conditions

Condition 1:Does the Bluetooth module meet the FCC modular approval requirements?

According to the FCC KDB 996369 guidelines, the module must meet all of the following conditions to be integrated into the complete product without additional certification:

1. The module must have an independent RF shielding layer to prevent interference from external circuits;

2. The module must be equipped with a fixed antenna or standardized antenna interface (such as U.FL/IPEX), and the complete product must not change the antenna parameters;

3. The module’s power supply circuit must have a voltage regulation design to avoid voltage fluctuations affecting RF performance;

4. The module must pass all FCC tests (including transmission power, frequency deviation, spurious emissions, etc.);

5. At the time of module certification, it must be declared to support “modular approval” (the grantee must sign a “Modular Approval Declaration”).

If the Bluetooth module provided by the supplier does not fully meet the above conditions, the complete product must reapply for FCC-ID certification.

Condition 2: Does the design of the complete product change the RF parameters of the module?

Even if the module has passed modular certification, the following situations may still require re-certification of the complete product:

1. Antenna changes: Changing the type of antenna, adjusting the antenna routing or gain;

2. Circuit interference: Other circuits in the complete product (such as motors, displays) generate electromagnetic interference that affects the Bluetooth frequency band;

3. Structural obstruction: A metal shell or internal layout causes RF signal attenuation beyond the original certification range of the module.

3. Specific Operational Recommendations

Scenario 1

The module meets the FCC modular approval requirements, and the design of the complete product has not changed the RF parameters

No need to apply for complete product FCC-ID:

You can directly use the module’s FCC-ID, but must meet:

1. The complete product label must indicate the module’s FCC-ID (format: FCC ID: XXXXXXXXX);

2. The user manual must state: “This device contains a compliant RF module with FCC ID: XXXXXXXXX”;

3. The complete product must pass FCC Part 15B testing (EMC testing) and apply for FCC SDoC certification (compliance declaration for non-wireless parts).

Scenario 2

The module does not meet the modular approval requirements, or the design of the complete product affects RF performance

Must apply for complete product FCC-ID:

Re-test the Bluetooth RF parameters (Part 15C) and EMC (Part 15B) for the complete product, the process is as follows:

1. Submit an application to a TCB (Telecommunication Certification Body) in the U.S.;

2. Provide the original FCC-ID certificate and test report of the module (to reduce some testing items);

3. Complete RF and EMC testing for the complete product;

4. Obtain a dedicated FCC-ID for the complete product and label it on the product.

4. Compliance Risk Alerts

Alert 1

Risk of Incorrectly Referencing Module FCC-ID:

If the complete product does not meet the modular approval conditions and directly uses the module’s FCC-ID, it may be detained by customs or face FCC penalties (up to $21,928 per day).

Alert 2

Label and Documentation Requirements:

Even if exempt from complete product FCC-ID certification, ensure that labels and manuals comply with FCC rules, otherwise it may be deemed non-compliant.

Key Factors	Does the complete product need FCC-ID?	Operational Requirements
The module meets FCC modular approval requirements	No	Label the module FCC-ID + apply for FCC SDoC (Part 15B)
The module does not meet modular approval requirements	Yes	Re-test the complete product (Part 15B+15C) and apply for a dedicated FCC-ID
The design of the complete product affects RF performance	Yes	Re-test the complete product (Part 15B+15C) and apply for a dedicated FCC-ID

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• Detection Certification Scope
  
  China: CCC, CQC, SRRC, E-commerce quality inspection report;
  Europe: CE (LVD, EMC, RED), GS, TUV, CB, E/e-Mark certifications;
  North America: UL, CUL, ETL, CETL, FCC, CSA, FDA, EPA, IC certifications;
  Batteries: UN38.3, EN/IEC62133, MSDS, etc.;
  Taiwan: BSMI certification, NCC certification, etc.;
  Asia: PSE mark, MIC, VCCI, KC mark;
  Australia: RCM mark & C-tick, SAA, GEMS energy efficiency certification;
  Middle East: Saudi SASO certification, Kuwait KUCAS certification, Kenya PVOC certification,
             Nigeria SONCAP certification, etc. COC customs clearance certification.
  
  Contact Information
  
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