FCC Certification and Testing for the U.S. Market

A Telecommunications Certification Body (TCB) is a private organization recognized by the FCC to evaluate and certify radio devices on behalf of the Commission. TCBs are accredited under ISO/IEC 17065 and designated by NIST. They offer competitive pricing due to market competition among TCBs, and a closer working relationship that makes first-time certification success more achievable. In December 2014, the FCC made TCBs the only route to FCC certification for most device categories. Element is one such FCC-recognized TCB with 3 worldwide locations.

An FCC Grant of Equipment Authorization is the official authorization issued by a TCB on behalf of the FCC confirming that a device meets applicable FCC rules and is authorized to be placed on the US market. The Grant is issued following successful evaluation of test reports, technical documentation, labelling, and user materials. It is posted immediately to the FCC's public database when issued. The Grant remains valid indefinitely as long as the equipment remains unchanged; modifications may require a Permissive Change application or new certification depending on the scope of the change.

Cellular, PCS, and 5G NR devices are primarily covered by FCC Rule Parts 22, 24, 27, and Part 30 for 5G NR FR2 devices. Other rule parts such as Part 90 or 96 may apply depending on what bands are being supported.  All cellular devices need to comply with the minimum set of test requirements as defined in FCC Part 2 Subpart J.  These minimum requirements also include RF Exposure compliance and may include SAR evaluation testing if the device is portable by FCC definitions. In addition, multi-radio devices that include Wi-Fi, Bluetooth, or other unlicensed radio technologies must also satisfy FCC Part 15 requirements for those radio components. Element's engineers assess which rule parts apply to your specific device configuration and develop a test plan that addresses all applicable requirements.

Yes. Element holds both FCC TCB status (U.S.) and ISED FCB status (Canada). Although the two certifications are separate — FCC is not accepted in Canada and ISED is not accepted in the U.S. — the test scopes overlap significantly, particularly for cellular and radio devices. Element manages both programs simultaneously, sharing test configurations where standards permit, and issuing both the FCC Grant of Equipment Authorization and the ISED Certificate of Acceptance. Products are then listed on both the FCC's public database and Canada's Radio Equipment List (REL), and are then available for sale in both the U.S. and Canada.

Required documents for submission to the TCB and eventual upload to the FCC include test reports, technical documentation such as schematic diagrams, bills of materials, Theory of Operation, plus the User's Manual, labelling exhibits, and required attestations from the applicant.  Element TCB maintains lists for all application types as well as attestation templates for applicant use.

Element holds a broad range of ISO/IEC 17025 accredited testing services and is an accredited ISO/IEC 17065 Certification Body. For Europe, Element is a Notified Body for the Radio Equipment, EMC, and ATEX Directives, and an Approved Body for the equivalent UK regulations. For North America, Element is an FCC TCB, HazLoc Certification Body, and NRTL for the U.S., and an FCB for Canada. In Asia, Element is a KC Certification Body for Korea and a CAB for Japan. Element is also a certification body under the IECEE CB Scheme, making Element one source for virtually worldwide market access.

When a previously certified device requires modification, a Permissive Change application is submitted instead of a completely new certification. Class I changes (minor modifications with no impact on initial compliance) do not require filing with the TCB or FCC. Class II Permissive Changes require a filing to be submitted to the TCB for review, and will be uploaded to the FCC database after TCB’s approval. Class III Permissive Changes also require filing with the FCC and are specific to devices that were initially approved as a Software Defined Radio. TCBs, like Element, can process Permissive Changes for any device they have certified and can also accept Permissive Changes for devices originally certified by a different TCB. Element handles all three classes of Permissive Changes, and can provide checklists for the necessary documentation needed for the Permissive Change filing.

In some cases, existing FCC test data may support a new application, permissive change, module integration, white-label product, or Change in Identification. Element reviews the original approval, product differences, grant conditions, and technical documentation to determine whether data reuse, spot testing, or full retesting is appropriate.

In May 2025 the FCC adopted new rules (ET Docket No. 24-136) prohibiting any TCB, test lab, or laboratory accreditation body owned or controlled by a designated foreign adversary or other prohibited entity from participating in the FCC equipment authorization program. Multiple test labs have already lost FCC recognition under these rules, and responsible parties using the SDoC process must now certify that their test lab is not a prohibited entity. Element's TCBs and test labs are not subject to any of these restrictions and remain fully operational for all FCC certification services.

By testing with an FCC Trusted Test Lab (like Element), the FCC is developing a process to streamline the pre-approval guidance procedures - especially important for our cellular customers who often have complex certification requirements that include pre-approval guidance for the FCC.

Manufacturers should verify the current status of any lab or TCB they use via the FCC's test firm search.