I'd like to import a USB device similar to a mouse to the USA and Canada, does it need to be certified by Nationally Recognized Testing Laboratories (NRTL) or UL? Does it make a difference if the device is manufactured in Japan or in China? As well, who should be responsible for this certification if it is necessary - the distributor (me) or the manufacturer?


  • 1
    \$\begingroup\$ Non-expert, but NRTL/UL is not a mandatory thing. And computer mice are considered passive by FCC regulations, so they don't need Part 15 or Form 740 submittal either. BUT if you are getting into importing, you might want to talk to an actual lawyer knowledgable about these things. \$\endgroup\$
    – Passerby
    May 31, 2013 at 6:30
  • \$\begingroup\$ Looking at the bottom of the mouse I'm using, I see that it is FCC certified and UL listed. How many are you planning to sell? \$\endgroup\$
    – david
    May 31, 2013 at 8:51
  • \$\begingroup\$ @david You are right. I should have said that corded mice don't require part 15. Wireless mice would. \$\endgroup\$
    – Passerby
    May 31, 2013 at 16:29
  • \$\begingroup\$ You need to demonstrate USB compliance to use the USB logo. \$\endgroup\$ Jun 30, 2013 at 15:50

2 Answers 2


NRTL certification is not a legal requirement, but may be a practical requirement in many situations. Resellers may not be willing to carry the item if it is not certified to their satisfaction, and some large institutions may have policies to not buy uncertified devices. Also, having certification may help in liability cases where the device is alledged to have caused damage or injury.

The legal requirement is that the device meet the radiated and conducted (if it plugs into the wall) emission limits as set by the FCC in part 15 of their rules. You are not required to get unintentional radiators tested. It is simply your obligation to ensure they comply. Getting the device tested is one way for you to know it complies, and will help matters later in the unlikely event there is a complaint, the FCC looks into it, and finds some of the devices to be illegally radiating.

If the device is a intentional radiator, then it must be certified by a FCC-approved test house, and will have to be assigned a FCC certification number. Intentional radiator are taken seriously, so you really need to follow the rules in that case.


Further to Olin's answer:

FCC part 15 is the U.S. requirement. For Canada, there's an largely identical requirement set by Industry Canada called ICES-003, based on CSA standards:

  • C108.8-M1983, "Electromagnetic Emissions from Data-Processing Equipment and Electronic Office Machines"
  • CAN/CSA-CISPR 22-96

The Canadian boilerplate text that's equivalent to the FCC part 15 statement reads like this:

This Class A/B digital apparatus meets all requirements of the Canadian Interference-Causing Equipment Regulations.

Cet appareil numérique de la classe A/B respecte toutes les exigences du Réglement sur le matériel brouilleur du Canada.

As with FCC part 15, an unintentional radiator doesn't require a test report - you must ensure that it complies.

I believe that if there is a compliance issue with the product, you as the seller will be in the focus of the governmental scrutiny. I doubt that you'd be able to negotiate that responsibility away from yourself and put it on your supplier, but if they have any test reports for the product, it would be good to have a copy as a first line of defense.


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