Leveraging Modular Approval to Slash FCC Certification Cost

The process of achieving FCC compliance can be complex, time-consuming, and expensive

The process of achieving FCC compliance can be complex, time-consuming, and expensive, particularly for modern devices that rely on wireless technologies like Wi-Fi, Bluetooth, or cellular connectivity. While traditional FCC Certification requires every single final product to undergo full testing, the Federal Communications Commission (FCC) offers a unique and highly beneficial pathway for manufacturers: Modular Approval.

This strategy is a game-changer for companies building Internet of Things (IoT) devices, allowing them to dramatically reduce their FCC testing requirements, control FCC certification cost, and accelerate their time to market.


What is Modular Approval?

Modular Approval applies to Intentional Radiators—the wireless components (often embedded circuit boards or modules) that intentionally emit radio frequency energy.

Instead of certifying the final host product (e.g., a smart refrigerator or a connected lightbulb) from scratch, a component manufacturer can certify just the tiny radio module in a standalone, controlled environment.

This certified module is granted its own FCC ID and can then be legally integrated into any number of host devices by original equipment manufacturers (OEMs).

3 Major Benefits of the Modular Strategy

Using a pre-certified radio module fundamentally changes the compliance burden for the OEM assembling the final product:

1. Massive Reduction in FCC Testing

  • The Module's Grant: The module's certification covers the most complex and failure-prone part of the device: the radio transmission characteristics (e.g., power output, occupied bandwidth, and spectral density).

  • The Host's Burden: When integrating a pre-certified module, the host product no longer needs to repeat the strenuous radio frequency testing. The final product only needs to undergo testing for its unintentional radiator functions (Part 15, Subpart B—which is typically less complex) and ensure the module is installed correctly and not causing new issues.

2. Significant Cut in FCC Certification Cost and Time

The costliest and longest part of the process is often the full RF testing of an intentional radiator. By using a pre-certified module, manufacturers bypass this major hurdle, leading to:

  • Lower Lab Fees: Reduced scope of FCC testing means lower fees from the accredited laboratory.

  • Faster Certification: The time needed to complete the authorization process is dramatically shortened, allowing for faster product launch and quicker ROI.

3. Flexibility and Product Family Management

A single certified module can be used across an entire line of products (e.g., a manufacturer could use the same Wi-Fi module in their smart toaster, coffee maker, and security camera). This simplifies inventory and regulatory management, requiring only minor follow-up FCC registration procedures for the final host device.


The Fine Print: Conditions for Modular Compliance

While modular approval offers huge advantages, the OEM must adhere to strict conditions to maintain the module's grant of authorization:

  1. Antenna: The host device must use the same type of antenna and the same or lesser gain as the one originally tested with the module. If you change the antenna, the entire system likely requires re-certification.

  2. RF Exposure Compliance: If the final host product is used closer to the human body than was tested for the module, the OEM must perform additional RF exposure (e.g., SAR) testing.

  3. Labeling: The host product must carry its own label with the module’s FCC ID, typically stating: “Contains FCC ID: [Module’s FCC ID].”

Conclusion: A Strategic Approach

The decision to build a device using a custom radio or a pre-certified module is one of the most important strategic choices in hardware development. Leveraging Modular Approval is the smart choice for most mid-to-high volume producers, effectively lowering the financial barrier, complexity, and timeline associated with the required FCC compliance and FCC registration. It transforms the daunting task of FCC Certification into a manageable, predictable process.


Pankaj Kush

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