United States
United States compliance review and market access
The United States has no single approval that opens the market. Radio and EMC sit with the FCC, electrical safety sits with a private certification scheme that is commercially unavoidable, and energy, consumer safety and state-level requirements are administered separately again. We map the set that applies to your product and run the programme.
What applies to your product
The starting point is never the mark — it is which regimes your product falls under, and what evidence each one accepts.
| Area | What applies | Practical effect |
|---|---|---|
| Radio and EMC | FCC Part 15 Subpart B for unintentional radiators, Subpart C for intentional radiators such as Wi-Fi and Bluetooth, and Part 18 for ISM equipment. | Most Subpart B products may use a Supplier's Declaration of Conformity. Anything that transmits requires Certification through a Telecommunication Certification Body and receives an FCC ID. |
| Electrical safety | No federal safety mark. Certification by a Nationally Recognised Testing Laboratory (UL, Intertek/ETL, CSA, TÜV and others) under the OSHA NRTL scheme. | Legally required for equipment used in workplaces, and required in practice almost everywhere else by the local authority having jurisdiction, retailers, insurers and installers. Field evaluation is the alternative for small volumes. |
| Test laboratories | Certification testing must be performed at an FCC-recognised accredited laboratory. Since September 2025, laboratories and certification bodies owned or controlled by specified prohibited entities may not be relied on. | Existing test reports from a laboratory that has since lost recognition can require re-testing. Worth checking before you rely on an inherited report. |
| Energy and labelling | US Department of Energy conservation standards with certification filed in CCMS, FTC EnergyGuide labelling, and separate California Energy Commission listing. | California listing is a precondition of offering many products for sale in that state and is not satisfied by the federal filing. |
| Consumer product safety | CPSC general certificate of conformity, or a children's product certificate based on third-party testing. | Certificate data must now be filed electronically with US Customs at entry for imported consumer products. |
| Other common triggers | FDA requirements for laser products, UN 38.3 for lithium battery shipments, California Proposition 65 warnings, and state electronics and battery stewardship registration. | These are registration and labelling obligations rather than testing, but each can block lawful sale on its own. |
You will need a US party — which one depends on the route
This is the requirement most often discovered late, and it differs between the two FCC authorisation routes.
For a Supplier's Declaration of Conformity, the responsible party must itself be located in the United States. A foreign manufacturer cannot hold that role — a US importer or affiliate has to take it on, with the compliance liability that carries.
For Certification, a foreign applicant may hold the grant, but must designate a US Agent for Service of Process, with an agreement signed by both parties. The designation has to be maintained for at least a year after marketing or importation permanently ceases.
We advise on which route your product qualifies for, arrange the agent or responsible-party arrangement, and make sure the obligations attaching to it are understood before they are signed.
What we provide
- Product classification and determination of the correct FCC route — SDoC or Certification through a TCB
- Gap analysis of an existing CB, IEC or CE test report against UL/ANSI safety standards and FCC requirements
- Scoping and coordination of top-up and delta testing at FCC-recognised laboratories
- NRTL selection, quoting and project management through to listing, or field evaluation where volumes do not justify listing
- TCB selection and management of the certification application
- Screening of laboratories and modules against the FCC Covered List and equipment authorisation restrictions
- US Agent for Service of Process arrangements, and advice on the SDoC responsible-party role
- FCC label artwork, e-label implementation and user manual compliance statement review
- DOE certification data for CCMS, FTC EnergyGuide, California Energy Commission listing and CPSC certificate preparation
- Technical file structuring and record retention so the evidence survives an audit
Where these programmes usually stall
- Assuming a CE or IEC file transfers. Construction requirements, 120 V/60 Hz mains, plug and cord sets, creepage and clearance, and marking all differ
- No US-located responsible party in place for an SDoC product
- No US Agent designated for a certification application
- A radio module used without confirming the modular grant conditions, or without the host testing that grant requires
- Reliance on a test report from a laboratory that has since lost FCC recognition
- California Energy Commission listing discovered after stock has landed
- Packaging printed before the FCC ID is issued, or with incorrect label placement
- CPSC certificate data not prepared for electronic filing at entry
Common questions
United States compliance — frequently asked questions
Is the FCC mark enough to sell an electrical product in the US?
No. FCC authorisation addresses radio and electromagnetic interference only. It says nothing about electrical safety. In practice a mains-powered product also needs NRTL listing — legally where it will be used in a workplace, and commercially almost everywhere else, because the local inspection authority, retailers and insurers will ask for it.
What is the difference between SDoC and Certification?
A Supplier's Declaration of Conformity is a self-declaration: no filing with the FCC, no FCC ID, and the responsible party must be located in the United States. Certification is an application through a Telecommunication Certification Body which results in a published grant and an FCC ID, and is mandatory for anything that intentionally transmits. Most non-transmitting digital devices may use SDoC.
Do we need UL specifically, or will another mark do?
UL is one of several Nationally Recognised Testing Laboratories. Intertek (ETL), CSA, TÜV and others hold OSHA recognition for the relevant product categories, and their marks are equally valid. Which is best depends on the product category scope, cost, lead time and — sometimes decisively — which mark your intended retailer accepts.
Can Universal Approvals issue the FCC grant or the NRTL listing?
No, and no consultancy can. Grants are issued by the FCC or a TCB, and listings by an NRTL. Our role sits outside both: we determine the pathway, prepare and review the evidence, select and manage those bodies, and resolve non-conformities. Because we hold no ownership interest in any laboratory, we have no reason to recommend testing your product does not need.
Want to learn more?
Speak to a Chartered Professional Engineer about your product, your target market and the approval pathway that actually applies to it.
Talk to an engineer
Planning a United States launch?
Send us the product and whatever test evidence you already hold. We will set out what transfers, what has to be added, and what the pathway costs — in writing.