Time to read: 8 min
You and your team have a killer consumer electronics product idea and the necessary skill set to bring it to market. But 50% of consumer electronics products fail EMC testing during their first pass. A failure in certification testing can stop your product development process in its tracks, resulting in large costs and significant delays to releasing your product.
Don’t get caught up in red tape.
There are plenty of long, technical books on everything from FCC regulations and UL testing requirements to PCB antenna design that can aid you as you take a deep dive into this process (here’s one I’ve personally found quite valuable). To accelerate your learning and help inform product design requirements in the early stages, here’s an overview of certification requirements for consumer electronics to be sold in the United States, including:
- FCC Requirements
- EMC Testing
- RF Testing
- Safety Testing
This guide should help you avoid or mitigate the impact of costly and untimely certification testing failures, and get your product into the hands of your customers as quickly and seamlessly as possible.
FCC Requirements
The Federal Communications Commission (FCC) requires that electronics meet certain standards in order to be marketed and sold in the United States. These requirements are comprised primarily of two major sets of requirements: EMC (Electromagnetic Compatibility) testing and RF (Radio Frequency) testing.
EMC Testing
EMC testing measures the strength of the electromagnetic fields that your product generates to ensure it falls within limits set by the FCC. The requirements that apply to your product vary. Although you can determine applicable requirements by combing through regulatory documents, the simplest way to assess the necessary requirements is to engage with FCC-accredited test labs and leverage their expertise.
A comprehensive list of test labs can be found here. In order to get timely and helpful feedback from test labs, get an NDA signed quickly and be ready to provide a breakdown of where you plan to sell your product and expected use cases for your product, so the test lab representative can help you determine market and product-specific requirements.
It’s worth noting that some products are exempt from EMC testing altogether, though these exemptions aren’t typically within the realm of consumer electronics. The Code of Federal Regulations, Title 47, Part 15 (47 CFR 15), Section 15.103 spells out the devices that are exempt. That being said, the FCC still strongly recommends that all products meet the technical requirements for the product in question, as the FCC can still stop the sale of your exempt product if it is shown to produce harmful electromagnetic interference.
RF Testing
RF testing measures the intentionally generated electromagnetic fields from within the radio frequency portion of the electromagnetic spectrum that your product generates. These are generated from the RF transmitter (e.g., a Bluetooth or WiFi module) in your product. However, requirements for RF, like channel allocation and emissions bandwidth, vary based on the end use of your product.
In order to determine which transmission frequencies are appropriate for your product and target market, do consider speaking with accredited test labs. The RF transmitter in your product generally will either take the form of a pre-certified module (i.e., a separate printed circuit board subassembly that can transmit and receive RF energy), which has already been tested and approved, or your own RF module that you’ve designed from scratch.
Pre-certified modules can significantly cut down on the required design effort, testing costs, and testing timeline but have a much higher cost per unit when compared to a module you’d design from scratch (roughly $10 to $50 per unit for a pre-certified module, compared to $4 to $10 for your own module). Additionally, you’d be dependent on an OEM’s supply and support of that module.
If you design your own RF module up front, the exact same module can be used as a pre-certified module in later products you develop, allowing you to realize the benefits of lowered testing costs and reduced time to test, while still having a lower cost per unit.
Cost and Timeline
With the experience and advice of accredited test labs, you should be able to minimize risk and de-mystify the EMC and RF requirements of your product. But beyond the technical requirements, there are still questions that may have huge implications on your product development lifecycle. What is the cost for testing? How long does it take to test?
In order to answer these questions, first identify whether your product is considered an unintentional radiator (a device that either uses a pre-certified module or doesn’t use a wireless transmitter at all) or if it is an intentional radiator. Then identify whether your product is subject to authorization to by “Verification,” “Declaration of Conformity,” or “Certification.” Unintentional radiators have their required authorization path spelled out in Subpart B of Section 15.101 of 47 CFR 15, while intentional radiators most often fall under the Certification authorization requirement (with some exceptions being carrier current systems and AM transmission systems used in educational systems).
Certification takes roughly four to six weeks, and while costs can vary widely by the accredited test lab in question and the specific requirements of your product, can generally cost between $8,000 and $20,000. On the other hand, “Verification,” which requires engaging either a “2.498 listed” test lab or FCC accredited test labs, and Declaration of Conformity, which requires engaging a FCC accredited test lab, both only require a few days of testing and cost roughly $2,000.
There’s also the question of where in the product development lifecycle you should plan on testing. On the one hand, you want to test as early as possible to understand what issues you may run into and correct those prior to having a production-ready product. On the other hand, you need for your product to be both fully functional (i.e., running all operations of which it is capable) and fully fleshed out mechanically (i.e., in the near final enclosure that requires only slight changes that don’t alter, or only slightly alter, the emissions of your product) before conducting your final testing.
For these reasons, if you are able to afford the cost and wish to avoid delays, it is a good practice to send a prototype of your product in for a pre-scan once you have the firmware and electrical layout near stabilized to work out any bugs, and then to send your product in for final testing after a design freeze (but prior to your final pre-mass production build, usually called PVT).
Safety Testing
Safety testing, as you’d guess, tests how safe certain components or aspects of your product are. The safety “mark” that you need to place on your product is dependent on what your customer (e.g., ecommerce or brick and mortar retail, end consumer, large enterprise, etc.) requires, with the UL mark and then the ETL mark being the most common.
The safety mark and testing requirements are also dependent on what liability concerns you want to alleviate, since testing results showing that a certain characteristic of your product is safe can be helpful if a lawsuit questions your product’s safety. It’s best to engage with labs like UL, Intertek, SGS, or Met Labs to determine what testing is required and recommended.
NRTL Program
If you’re planning on selling your product for use in the workplace, you’ll want to take into account the Nationally Recognized Test Lab (NRTL) Program set up by the Occupational Health and Safety Administration (OHSA), which has authority over government and private employers in the United States. This means that while OHSA can’t prevent you from marketing your product, it can prevent employers from buying it if it is not deemed “acceptable.”
A product being “acceptable” is spelled out in 29 CFR Section 1910.399, but generally means it requires testing by an NRTL, with UL being just one of them. A list of NRTLs can be found here.
Cost and Timeline
As with FCC requirements, testing timeline and cost can vary greatly depending on your product and how you intend to market it. Also, costs and testing timelines can vary significantly between NRTLs and the mark that they provide. That being said, the testing for a NRTL mark can take four to six weeks, with costs ranging from $3,000 for some safety marks to upwards of $30,000 for UL, depending on the complexity of your product.
These estimates don’t even take into account the time necessary for consulting with NRTLs or safety consultants up front around how to design your product and packaging to ensure you are well within the requirements. Be sure to start thinking about and designing for the safety requirements your end customer will require at the beginning of your product development lifecycle.
Additional Considerations to Avoid Costly Delays
These are the biggest certification requirements, but there are others that you must consider in order to avoid delays. For instance, if you have lithium batteries in your product and are shipping internationally, you’ll likely require UN38.3 certification (for shipping via air) or IEC 62281 certification (for shipping via sea, land, or air).
Although not costly compared to previously discussed certifications (last time around, I was charged $800 for UN38.3), any unexpected delays can throw a wrench in your plans as you march towards releasing your product to market. Consider speaking with trading partners at all points in your value chain (e.g., manufacturer, 3PL, customs broker, customers) to be fully informed about any certification or testing requirements that may be specific to your product.
Main Takeaways
This guide is intended to just scratch the surface of requirements for certification testing and provide you with some additional resources to leverage in your trek to getting your product to market in the United States. Expanding your certification and testing requirements to allow for marketing and sale into Canada (governed by Industry Canada) is relatively simple and is best carried out concurrently with FCC testing. Expanding to Europe (CE), China (CCC), Japan (VCCI), and other markets, however, comes with a number of considerably different certification requirements and variations to the aforementioned EMC, RF, and Safety Testing requirements in the United States.
That is not to say there is no overlap, as designing up front to the safety requirements for CE may cover most of the safety requirements you’ll come across in the United States. Being diligent about staying informed of applicable rules and regulations is the bottom line. In order to do so, incorporate design reviews for product and market-specific certification requirements, and start conversations with accredited test labs early in the product development lifecycle. This will give you the tools to design your product according to necessary requirements and help you avoid huge hits, costs, and delays that could pose a life-threatening risk to your product before you make a single sale.
