Can products be imported to US for Beta testing without FCC certification

Question

We need to import two products that are newly designed and operate on wifi and BLE. We are planning to get them for beta testing. We have talked to a few interested parties where the products will be installed.

These products will not be marketed anywhere or sold. Will be used only for the beta and to gauge their interest and take their feedback.

Does this require us to have the product tested for intentional and unintentional radiation before import?

Point 3 in https://www.fcc.gov/oet/ea/importation#sec3 feels like we do not need to.

The radio frequency device is being imported in quantities of 4,000 or fewer units for testing and evaluation to determine compliance with the FCC Rules and Regulations, product development, or suitability for marketing. The devices will not be offered for sale or marketed. Prior to importation of a greater number of units, written approval must be obtained from the Chief, Office of Engineering and Technology, FCC (to request approval, see FAQ 8 below or KDB Publication 741304 Distinctly different models of a device and separate generations of a particular model under development are considered to be separate devices.

But we are not sure if we are interpreting it right. Will be very grateful for some help and clarification here.

Answer 1

Does this require us to have the product tested for intentional and unintentional radiation before import?

• Importing an uncertified piece of equipment is not illegal.
• Testing it is equivalent to a US based designer constructing a PCB or module to verify its performance and functionality prior to taking it through the certification process.
• There could be months of testing prior to certification is undertaken

You wouldn't certify something that hasn't been functionally tested and, neither can anyone expect you to certify the imported goods prior to functional testing.

If the equipment produces known emissions i.e. it's an intentional radiator then, you take precautions to contain the equipment in an EMI safe area during functional testing.