please kindly help me understand the "subassembly" exemption of the Part 15 certification requirements regarding intentional radiators. I want to produce and sell a MCU board which includes wireless communication features built-in. Obviously this board must be incorporated with other circuitry in a final product/system by the purchaser, in order to make a working product, so my product is not a "final product".

Does this qualify as a "subassembly" and thus would be exempt from FCC certification requirements, or does the fact that it is an intentional radiator nullify the "subassembly" aspect?

Thank you.


1 Answer 1


From my experience with this (several products, using various combinations of wireless devices), then if the wireless module you use (be it cellular, Bluetooth, BLE, Wi-Fi or ZigBee or ISM) includes an antenna, and the entire module (radio + antenna) has been tested per FCC requirements (and therefore has an FCC ID stamped on it), then you do not have to do any further testing.

Here is an exmple of the type of module I am referring to. Note the chip antenna on the upper left corner.

enter image description here

Note the one pictured above is pretty much blank. The real one I have on my workbench is covered with text and logos, including an FCC ID and CE mark.

As long as you have only one wireless device on your board, (and there are no other wireless devices on other boards) the person using it in their product should be able to use the FCC ID that is stamped on the module.

But, if you have a module that attaches to a separate antenna, and only the module was certified (or not), then you must test the combination together. Furthermore, if you have more than one radio in the final product, then they must be tested together, even if they have been certified separately.

This is my understanding. You should have it verified by someone else before proceeding.

  • \$\begingroup\$ Thanks tcrosley, my project does not include a tested module: instead the MCU chip contains the radio circuitry which must be connected to a PCB antenna. \$\endgroup\$ Oct 16, 2014 at 13:58
  • \$\begingroup\$ @RyanGriggs Then I'm afraid you'll have to go through FCC testing. But I don't believe whomever is imbedding your board in their product will not to do so. Double-check for sure. Good luck. \$\endgroup\$
    – tcrosley
    Oct 16, 2014 at 15:02
  • \$\begingroup\$ Thanks, can you recommend the best way to get started? People to contact, best companies to use, etc? \$\endgroup\$ Oct 16, 2014 at 22:02
  • \$\begingroup\$ @RyanGriggs Best to go local if possible. Where are you located? \$\endgroup\$
    – tcrosley
    Oct 16, 2014 at 23:23
  • \$\begingroup\$ @RyanGriggs I couldn't find one in Kentucky. Here is the closest one I could find in Ohio. And this is the one my client uses in Arizona if you want to compare quotes. \$\endgroup\$
    – tcrosley
    Oct 18, 2014 at 8:03

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