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Selling electrical and electronic products in the US

In the US, devices that emit radio frequency energy, from wireless gadgets to personal computers, are authorised under FCC rules before marketing, by certification or a Supplier's Declaration of Conformity, and carry FCC labels. Consumer products are also subject to CPSC rules, such as the button cell battery rule, and some appliances carry an FTC EnergyGuide label.

Updated · Each section links to the official source it comes from

Radio and digital devices
FCC, 47 CFR Parts 2 and 15
Transmitters
Certification by a Telecommunication Certification Body
Most digital devices
Supplier's Declaration of Conformity or certification
SDoC responsible party
Located in the United States
Button and coin batteries
16 CFR 1263, UL 4200A (Reese's Law)
Energy labels
FTC EnergyGuide, 16 CFR 305

Before a product goes on sale

The questions to answer, in the order they usually come up.

  1. 1Is the device an intentional radiator (a transmitter) or an unintentional radiator (a digital device)? Read more
  2. 2Does it need certification, or can it use a Supplier's Declaration of Conformity? Read more
  3. 3Do the device and manual carry the FCC ID, compliance statement and user information? Read more
  4. 4Does it contain or use button cell or coin batteries? Read more
  5. 5Is it an appliance or television that needs an EnergyGuide label? Read more
  6. 6If imported, does it meet the FCC import conditions? Read more
  7. 7Is there a way to report a defect to the CPSC within 24 hours? Read more

The rules, by area

What each area covers, the texts that set it, and what the official pages say.

FCC equipment authorisation

Authorising a radio frequency device before it is marketed.

  • 47 CFR Part 15 covers intentional, unintentional and incidental radiators operated without an individual licence. Marketing a device that does not meet it, including prior equipment authorisation, is prohibited.
  • Intentional radiators are, with exceptions, certified by a Telecommunication Certification Body before marketing; certification is based on representations and test data from the applicant.
  • Unintentional radiators, such as personal computers, peripherals, external switching power supplies and other digital devices, are authorised before marketing by a Supplier's Declaration of Conformity or certification.
  • Under an SDoC, the responsible party, which must be in the United States, makes the measurements; for imported equipment, the importer is the responsible party.
  • Radio frequency devices may be imported only if they hold a valid FCC equipment authorisation, need none and comply, or fall within limited exceptions such as testing or trade shows.

How we help: Compliant Always keeps the FCC grant or SDoC test report with each model and checks that the model on the pack matches the one authorised. Ask about this

FCC labelling and user information

What the device, its packaging and manual show.

  • Certified equipment bears a label with the FCC ID, permanently affixed and readily visible to the purchaser at the time of purchase; the information may be provided electronically where the rules allow.
  • Most Part 15 devices bear the statement that the device complies with part 15 of the FCC Rules and that operation is subject to two conditions, in a conspicuous place.
  • Where a device is too small for a four-point label and has no display, the statement goes in the manual and on the packaging or a removable label.
  • A product under an SDoC is supplied with a compliance information statement naming the product, the compliance statement and the US responsible party.
  • The user manual cautions that changes not expressly authorised by the party responsible for compliance could void the user's authority to operate the equipment.

How we help: Compliant Always sets your device label, packaging and manual beside the FCC labelling rules, and keeps each version with the authorisation it refers to. Ask about this

Product safety: CPSC rules

Safety rules for consumer electrical products.

  • Consumer products containing button cell or coin batteries comply with ANSI/UL 4200A, which keeps children from reaching the batteries, and carry warnings on the product, packaging and instructions, under Reese's Law.
  • Packages of button cell or coin batteries carry an English warning in a set format; zinc-air batteries are outside the rule, and toys meeting the toy standard's battery rules are exempt.
  • Hand-supported hair dryers without the immersion protection of UL 859 or UL 1727, and seasonal and decorative lighting that lacks set UL 588 features, are deemed substantial product hazards.
  • Products subject to a CPSC rule, such as the button cell rule, need a certificate of compliance, eFiled at entry for imports.

How we help: Compliant Always works out which CPSC rules apply to your product and keeps the certificate with the test reports it rests on. Ask about this

Energy labelling

EnergyGuide and similar labels for appliances and televisions.

  • The FTC's Energy Labeling Rule covers products such as refrigerators, freezers, dishwashers, water heaters, room and portable air conditioners, clothes washers, pool heaters, ceiling fans, televisions and some lighting products.
  • Manufacturers and private labelers may not knowingly distribute a covered product without the label or marking the rule requires.
  • The manufacturer makes each EnergyGuide or Lighting Facts label available on a public website, and keeps it there for six months after production of the model ends.
  • Catalogues and point-of-sale material for covered products include the energy information the rule sets.

How we help: Compliant Always keeps each model's energy test data and label together, and shows when a label is missing from the record. Ask about this

Defect reporting

Telling the CPSC about a hazard.

  • A firm reports to the CPSC when it obtains information indicating that a consumer product it has distributed fails a CPSC rule, has a defect that could create a substantial product hazard, or creates an unreasonable risk of serious injury or death.
  • Information about severe electrical shocks or severe burns that a defect has caused, or could cause, is reported unless the firm has investigated and found it not reportable.
  • The report should be made within 24 hours of obtaining information that reasonably supports the conclusion.

How we help: Compliant Always keeps complaints, test reports and production records with the product and lot, so the facts behind a reporting decision are in one place. Ask about this

Who answers for what

WhoWhat they answer forHow we help
GranteeCompliance of certified equipment with the FCC rules.Grants, test reports and label versions kept together by model.
SDoC responsible partyTesting and the compliance information statement; must be in the US, and is the importer for imported equipment.SDoC test reports read and dated before the goods ship.
ImporterFCC import conditions, CPSC certificates and eFiling.Overseas suppliers' authorisations and reports read before the goods ship.
Manufacturer or private labelerCPSC certificates, energy labels and defect reports.Certificates and labels kept with each model, with gaps shown.

Federal and state

Federal agencies set the national rules. States can add their own: California's Proposition 65, for example, can call for a warning on a product sold there.

Retailers and marketplaces often ask for more than the law does, such as test reports by lot or third party certificates.

Questions businesses ask

Does my electronic product need FCC approval?
If it emits radio frequency energy, usually yes. Transmitters are certified by a Telecommunication Certification Body; most digital devices use a Supplier's Declaration of Conformity or certification, before marketing.
What is the difference between FCC certification and SDoC?
Certification is a grant issued by the FCC or a Telecommunication Certification Body on the applicant's test data. Under an SDoC, the US responsible party makes the measurements itself, without filing them unless the FCC asks.
Who is the responsible party for an imported device under SDoC?
The importer. The responsible party for a Supplier's Declaration of Conformity must be located in the United States.
What FCC label goes on a device?
Certified equipment carries its FCC ID. Most Part 15 devices also carry the statement that the device complies with part 15 of the FCC Rules, subject to two conditions.
Can FCC labelling be electronic?
The FCC ID information may be provided electronically under 47 CFR 2.935, and a very small device without a display can put its compliance statement in the manual and on the packaging.
Can I import a device that has no FCC authorisation?
Only within exceptions, such as up to 4,000 units for testing and evaluation that will not be marketed, or limited quantities for trade shows.
What does Reese's Law require?
Consumer products containing button cell or coin batteries meet ANSI/UL 4200A and carry warnings; battery packages carry an English warning label in a set format.
Which products need an EnergyGuide label?
Covered products include refrigerators, freezers, dishwashers, water heaters, clothes washers, room and portable air conditioners, pool heaters, ceiling fans and televisions, under the FTC's Energy Labeling Rule.
Do electronics need a CPSC certificate?
When a CPSC rule, ban or standard applies to the product, such as the button cell battery rule, a certificate of compliance is issued and, for imports, eFiled at entry.
When must a defect be reported to the CPSC?
Within 24 hours of obtaining information that reasonably supports the conclusion that a product fails a CPSC rule, has a defect creating a substantial hazard, or an unreasonable risk of serious injury or death.
How does Compliant Always help with selling in the US?
Our team reads the rules for the markets you sell in. Compliant Always shows which apply to your product, keeps the documents behind each one ready, and watches federal sources for changes. It shows what the requirements say and what your documents show; you decide.

Sources

Compliant Always is a product of Lettuce Labs LLC. It shows what requirements say and what your documents show. It is not legal advice, and you decide.

Tell us what you make, and we will show you the rules for it.

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