Do I REALLY Need to Certify My New Electronic Product?
So you think your product doesn’t need certification? Because it uses a pre-certified module? Or doesn’t have wireless functionality? Or because the product seems totally harmless?
Think again.
Here’s the first thing to remember, certification applies to the entire product, not just the individual parts.
For instance, even if you use a pre-certified module, once you integrate it into your design, your final product still has to meet regulatory requirements.
Broadly speaking there are three main categories of regulatory certifications: ElectroMagnetic Interference (EMI), safety, and hazardous materials.
For EMI certification we have FCC in the US, ISED in Canada, and CE marking in Europe.
Using a pre-certified wireless module does make EMI certification a lot easier and cheaper, but it doesn’t eliminate it.
If your product uses a pre-certified wireless module without modifying the radio, it is classified as a non-intentional radiator by the FCC.
That means you can use a Supplier’s Declaration of Conformity (SDoC), which is a much simpler and cheaper process than full FCC certification.
With an SDoC, you verify compliance yourself through basic testing and documentation.
Full FCC certification, on the other hand, is required for products classified as intentional radiators which are devices that intentionally emit RF from a non-certified radio.
This includes any product that integrates a custom radio design, modifies a pre-certified module’s antenna, or directly generates RF signals.
For example, if you use a wireless module that uses an external antenna, if you don’t use the same identical antenna then your product is no longer covered by the module’s certification, and it becomes your responsibility to get full FCC approval.
Intentional radiator devices require rigorous RF testing in an FCC-accredited lab and formal approval a much more expensive and time-consuming process.
The process for full FCC certification can take months, and if your product fails testing, you may have to redesign and retest leading to even more costs.
This is why it’s generally preferable to use pre-certified wireless modules, to avoid the delays and expense of full certification.
But, what about if your product doesn’t even have a wireless radio?
Sorry, but you’re almost surely still going to need to go through the FCC SDoC process.
The FCC regulates any device with a circuit that oscillates above 9 kHz, which means that even products without wireless functionality can be classified as non-intentional radiators.
This includes microcontrollers, switching regulators, and most modern electronics, which can still generate electromagnetic interference that needs to be tested.
Now, what about safety certifications like UL?
Unlike FCC, which is legally required for anything that emits RF energy, UL certification isn’t legally required in most cases.
But it’s often required by retailers and liability insurers especially if your product directly plugs into an AC wall outlet.
The good news is that if your product runs on DC power, you can bundle it with a UL-certified AC/DC adapter and usually avoid UL certification altogether.
But if your device is AC-powered, you’ll need UL certification to protect yourself from liability and to ensure retailers will actually carry your product.
Regardless of any liability concerns, obtaining UL certifications actually makes your product safer which is obviously something you want too.
For some product categories, UL certification is essentially mandatory.
If you’re developing a smart home device that plugs into an AC electrical outlet, retailers won’t even consider selling it without UL approval.
Also, battery-powered products that deal with large lithium batteries, like e-bikes or power tools, may also face stricter safety requirements.
In the U.S., FCC and UL are typically the two most complex and expensive certifications, assuming we’re not talking about a medical product.
Other certifications, like RoHS compliance for hazardous materials, may also apply, but they tend to be much cheaper and easier to obtain.
When it comes to any rechargeable lithium batteries, you need to make sure those have the appropriate certifications as well.
In Canada, you’ll need ISED certification instead of FCC certification, although many times the same testing can be used for both.
Instead of UL, Canada uses the CSA safety certification, although there are usually identical requirements.
In Europe, things work a little differently.
In Europe, instead of separate FCC and UL certifications, most products require CE certification, which covers both RF emissions and electrical safety under a single certification process.
Many CE-marked products can be self-certified, meaning you test it yourself and declare compliance.
But for higher-risk categories, you may need approval from an independent certification lab.
CE marking also includes RoHS compliance on any hazardous materials like lead.
So, does your product need certification? Yes, almost certainly.
Skipping certification can be a costly mistake. If regulators find your device non-compliant, you could face product recalls, import bans, and large fines.
If you’re developing a new product, think about certification early.
It’s much cheaper to design with compliance in mind from the start than to fix problems later.
Finally, as a special bonus tip, delay these certifications as long as possible, ideally doing them as part of your initial manufacturing setup.
If your product is a non-intentional radiator, and it doesn’t plug directly into an electrical outlet, then in most cases you can do small sales tests BEFORE you spend the money on certifications.
Also, if you do certifications too early, then any design changes will require retesting.
