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# FCC ID Labeling Requirements: How to Display the FCC ID on Your Product

A product that clears FCC certification but ships with a non-compliant label is still in violation. Labeling rules under 47 CFR Parts 2 and 15 are specific, enforceable, and frequently misapplied — particularly for modular transmitters, sealed enclosures, and devices using the electronic labeling option.

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At a glance

Primary CFR citation

47 CFR § 2.925, § 15.19, § 2.935

E-label menu depth limit

3 steps from main menu

Required § 15.19 statement

Two-condition compliance statement

Grantee code source

FCC Equipment Authorization database

Module label prefix

'Contains FCC ID: \[ID\]'

## What the FCC labeling rules actually require

### The FCC ID Format: Grantee Code + Equipment Product Code

An FCC ID has two parts separated by a hyphen: a three-to-five character grantee code assigned by the FCC to the responsible party, followed by an equipment product code of up to 14 characters chosen by the grantee. Together they uniquely identify the authorization granted. The full string — exactly as it appears in the grant of equipment authorization — must appear on the label; abbreviations, truncations, or reformatting are non-compliant.

### § 15.19 Required Statements for Part 15 Devices

Intentional radiators must bear the statement: 'This device complies with Part 15 of the FCC Rules. Operation is subject to the following two conditions: (1) This device may not cause harmful interference, and (2) this device must accept any interference received, including interference that may cause undesired operation.' Unintentional radiators carry a shorter Class A or Class B statement depending on their interference limits. These statements are legally required — omitting or paraphrasing them is a labeling violation regardless of whether the underlying device is properly authorized.

### Physical Label Requirements: Permanence, Legibility, Placement

Under 47 CFR § 2.925, a physical FCC ID label must be permanently affixed to the device — not printed on packaging, not in the manual, not on a removable sticker. It must be readily visible without tools or disassembly. The FCC does not specify a minimum point size, but the label must be legible under normal viewing conditions. Labels on surfaces that routinely contact skin or accumulate wear must be protected from abrasion, adhesive failure, or fading over the product lifecycle.

### Electronic Labeling (E-Label) Under § 2.935

Devices with a display may use an electronic label in lieu of a physical FCC ID, provided the FCC ID is accessible through the device's menu system in no more than three steps from the main menu or settings screen. The access path must be described in the user manual with exact step-by-step navigation instructions. E-label is common for smartphones and tablets but is increasingly used for IoT devices with small displays. The label must remain accessible even when the device is not connected to a network.

### Modular Transmitter Labeling Under § 15.212

A certified modular transmitter has its own FCC ID. When that module is installed in a host product, the host product's label must display either the module's FCC ID or the host product's own FCC ID (if the host obtained a separate grant covering the integrated configuration). The module's FCC ID must be listed on the host label with the prefix 'Contains FCC ID:' or 'Contains Transmitter Module FCC ID:'. Omitting module FCC IDs from the host label is one of the most common post-market compliance failures in electronics.

### Intentional vs. Unintentional Radiators: Different Rules

Intentional radiators (Bluetooth, Wi-Fi, cellular, Zigbee — anything deliberately emitting RF) require full FCC authorization and must display the FCC ID. Unintentional radiators (microprocessors, switching power supplies, digital devices that emit incidentally) require verification or Declaration of Conformity — they do not get an FCC ID and instead display the Part 15 compliance statement. A device with both intentional and unintentional emission sources requires both treatments simultaneously, which affects label space planning.

## How to get FCC labeling right from design through certification

01

Obtain the FCC ID from the equipment authorization database (fcc.gov/oet/ea/fccid) and confirm the exact alphanumeric string as it appears in the grant of authorization — this is the string that must appear on the label verbatim.

02

Determine whether the product qualifies for electronic labeling under § 2.935: it must have a display, the FCC ID must be reachable in three menu steps or fewer, and the access path must be documented in the user manual.

03

If using a physical label, design the label to include: the FCC ID string, the required § 15.19 compliance statement (long form for intentional radiators, Class A or B for unintentional), and any applicable RF exposure statement if the device is a transmitter near the body.

04

Verify placement: the label must be visible during normal use without disassembly. For enclosed devices, the e-label route is typically cleaner than drilling a window in the enclosure — but only if a display is present.

05

For any integrated certified modules (Bluetooth, Wi-Fi, cellular), add 'Contains FCC ID: \[MODULE FCC ID\]' to the host product label. Pull the module grants from the FCC database to confirm each module's authorization is still valid and has not been superseded.

06

If using e-label, walk through the actual menu path on production firmware and count the steps. Document the path exactly — screen name, menu item, sub-menu — and include screenshots in the user manual. The TCB (Telecommunication Certification Body) will verify this during certification.

07

Submit a label sample or e-label demonstration as part of the equipment authorization application. Post-certification, any change to the label text, placement, or e-label menu path that differs from what was submitted requires a filing — either a Class II permissive change or a new application.

## Frequently asked questions

### Can I use an electronic label instead of a physical FCC ID label?

Yes, if your device has a display and the FCC ID is accessible within three menu steps from the main settings screen, you may use e-label under 47 CFR § 2.935. The user manual must describe the exact navigation path with step-by-step instructions. The e-label option does not eliminate the requirement for the § 15.19 compliance statement — that statement may also appear electronically on the same screen as the FCC ID. Devices without a display cannot use e-label and must carry a physical label.

### What's the minimum font size for an FCC ID label?

The FCC regulations do not specify a minimum point size. The requirement is legibility — the label must be readable under normal viewing conditions without magnification. In practice, TCBs and FCC staff interpret this as a minimum of about 6–8 point type for desktop-scale devices, but miniaturized products (hearing aids, earbuds, wearables) may use smaller text provided it remains legible. For very small devices, the e-label option or an alternative location disclosure (in the manual or on packaging, supplementing — not replacing — a visible label) may be appropriate.

### Does the FCC ID need to be visible without disassembling the product?

Yes. Under 47 CFR § 2.925(a), the label must be placed so it can be read without requiring the use of tools or disassembly. A label inside a battery compartment is acceptable if the battery is removable by the end user without tools. A label under a sealed enclosure, behind a screwed panel, or visible only when a non-user-accessible cover is removed is not compliant. This is a common problem in industrial IoT devices with IP-rated sealed enclosures — the e-label option resolves it if a display is available.

### What happens if I add a new radio module — do I need a new FCC ID?

It depends on how the module is authorized. If the new module holds its own FCC ID as a certified modular transmitter under § 15.212, the host product does not need its own new FCC ID — it simply needs to add 'Contains FCC ID: \[MODULE FCC ID\]' to the label and update the user manual. If the host product has its own equipment authorization that was issued for a specific radio configuration, adding a different radio module requires evaluating whether the change triggers a Class I or Class II permissive change — or a new application. Radio changes are high-risk post-certification changes; assume a new filing is required until counsel or a TCB confirms otherwise.

**Disclaimer:** Educational resource only. Regulatory requirements change frequently. Consult a licensed US customs broker, trade attorney, or compliance specialist before making decisions.

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