Which US tests does an electronic product need before you sell it: FCC, UL, batteries and children's products?

As of November 2026, most electronic products sold in the US need FCC Part 15 testing; a product with a radio also needs an FCC ID, its own or its radio module's; lithium batteries need UN 38.3 test reports to ship; and products for children 12 and under need third-party testing and a Children's Product Certificate (CPC). A safety listing from UL, ETL or another Nationally Recognized Testing Laboratory (NRTL) isn't required by federal law for most consumer electronics, but retailers, some Amazon categories and business buyers ask for one. A product without a radio is tested to Part 15 Subpart B and declared compliant by a US company, usually the importer, under a Supplier's Declaration of Conformity (SDoC), with nothing filed at the FCC. A product that uses a radio module with its own FCC ID, within that module's conditions, needs no new FCC ID, but still needs the Subpart B test and a check of the radio inside the finished product.

FCC testing for a small device that uses a Bluetooth or Wi-Fi module with its own FCC ID usually costs about $6,500 to $10,000 at a US lab and takes two to four weeks, done on units built the way production will build them. FCC-recognized labs in Asia often charge a fraction of that: in the order it adopted in October 2026, the FCC estimated about $1,400 to test a device with an unlicensed radio at a lab in China, and about 20% more at lower-cost labs in other countries with testing agreements. Your own radio design, a custom battery pack that needs its own tests, or a failed test can each add thousands of dollars and weeks to months, and a product with Bluetooth also pays the Bluetooth SIG's listing fee.

Which tests does your product need?

The table lists the US tests and certifications a small electronic product most often needs: what each applies to, who does it, and typical cost and time. Costs are ranges published by US labs, consultants and standards bodies in 2025 and 2026; quotes vary widely by product and by the country where the testing is done.

Requirement	Applies to	Who does it	Typical cost	Typical time
FCC Part 15 Subpart B, Supplier's Declaration of Conformity (SDoC)	Any product with digital electronics	A test lab you choose; a US company signs and keeps the records	About $1,500 to $5,000	1 to 4 weeks
FCC, with a pre-approved radio module (modular approval)	Wi-Fi, Bluetooth or LoRa modules with their own FCC ID, used within their approval	A lab tests Subpart B and checks the radio in your product; no new FCC ID	About $6,500 to $10,000 at a US lab; often a fraction of that at an FCC-recognized lab in Asia	2 to 4 weeks
FCC certification, your own FCC ID	Your own radio design, or a module used outside its approval	An FCC-recognized lab, then a Telecommunication Certification Body (TCB)	About $9,000 to $12,000 or more at a US lab for a single Bluetooth radio; dual-band Wi-Fi costs more	2 to 3 months or more
Bluetooth SIG qualification and listing	Any product that uses Bluetooth, even through a qualified module; also needed to use the Bluetooth name or logo	You, through the Bluetooth SIG	$12,000 per product at the free membership level since March 2026; less at paid levels	Days to weeks
Safety listing, to UL 62368-1 or the standard for your product type	Products sold through retailers, some Amazon categories or to businesses; not federally required for most consumer electronics	A lab recognized by OSHA (an NRTL), such as UL, Intertek (ETL), CSA or TÜV	Roughly $5,000 to $20,000, plus yearly inspection fees	Often 6 to 12 weeks
UN 38.3 battery transport test	Every lithium cell or battery pack design you ship	The battery maker, or a lab	Nothing extra if the maker already has it; about $500 in China to $5,000 to $7,000 at a US lab	2 to 6 weeks
Battery safety (IEC 62133-2; UL 2054 or UL 1642)	Asked for by safety labs, retailers and Amazon	The battery maker, or a lab	About $6,000 to $10,000 for IEC on a pack; up to $15,000 to $20,000 for UL on a pack	6 to 12 weeks or more
Children's product testing and Children's Product Certificate	Products designed mainly for children 12 and under	A lab accepted by the Consumer Product Safety Commission (CPSC) tests; the importer issues the certificate and files it at import	About $500 to $2,500 per product, with FCC and battery tests on top	1 to 3 weeks

What does the FCC require, with and without a radio?

No radio (Part 15 Subpart B). Any product whose circuits run on a timing signal faster than 9 kHz, which any microcontroller does, is what the FCC calls an unintentional radiator: it isn't meant to transmit, but its circuits give off radio noise, and Subpart B limits how much. (A few kinds, such as digital electronics used only in a car or a household appliance, are exempt.) Most products without a radio use a Supplier's Declaration of Conformity (SDoC). A lab measures the product, and the responsible party, which must be in the US and is usually the importer, keeps the test report and declares that the product complies. If a supplier delivers the units to you with duties paid, agree in writing which US company is the importer and the FCC responsible party. Nothing is filed with the FCC. After SDoC testing, you:

• put the Part 15 compliance statement, the two-condition notice that begins "This device complies with part 15 of the FCC Rules", on the product, or in the manual and on the packaging if the product is too small;
• ship a compliance information statement with the product, naming the US responsible party with an address and a phone number or website, and, for products sold to consumers, the Class B notice in the manual (Class A is for products sold only to businesses, with looser limits);
• keep the records: the test report with photos of the test setup and any changes made to pass, your production test procedures and the design files.

Anything changed at the lab to pass, such as a ferrite (a small magnetic sleeve clipped around a cable to soak up noise), has to be listed in the test report and built into production.

Your own radio. A product built to transmit is an intentional radiator, and one with its own transmitter design needs an FCC grant of certification. An FCC-recognized lab tests it, a Telecommunication Certification Body (TCB), a private organization the FCC authorizes, reviews the results and issues the grant, and the product carries an FCC ID. The ID starts with a grantee code the FCC assigns to your company once, for a $35 fee.

A pre-approved radio module (modular approval). A module's grant covers its transmitter tests with the antennas it was approved with. A product using such a module, the host in FCC terms, still needs:

• Subpart B testing for its own electronics;
• a check of the radio's emissions in the finished product, with every radio on;
• the module's integration conditions: only antennas of the same type as in its grant, with equal or lower gain, and the radio-exposure condition, often a distance of 20 cm from people. A handheld or wearable product that puts the antenna closer needs a module approved for that use, or a new evaluation;
• a label on the outside: "Contains FCC ID:" followed by the module's ID;
• if it uses Bluetooth, its own Bluetooth SIG qualification and listing, referencing the module's: $12,000 per product at the SIG's free membership level since March 1, 2026, separate from FCC testing. Wi-Fi Alliance certification is optional unless you use its logo.

A cellular product also needs approval from the networks it runs on (PTCRB for AT&T and T-Mobile, and Verizon's own program), even with a module that has its own FCC ID; ask the module maker which approvals carry over. If you change the antenna or can't meet a module's conditions, the module maker has to file a change to its grant, or you get your own FCC ID. For who buys the modules and other parts, see Who buys the parts for a first production run; for radio costs, Your prototype runs on an Arduino, ESP32 or Raspberry Pi.

Where can you test? The FCC's lab rules, as of November 2026

• Since September 8, 2025, the FCC hasn't recognized test labs or certification bodies owned or controlled by companies or governments on its prohibited lists, which include China's government, and Subpart B testing can't be done at such a lab either. The FCC says 29 labs have lost their recognition under this rule.
• On October 29, 2026, the FCC adopted a rule that, for certification applications received from December 1, 2028, testing must be done in the US or in a country with a mutual recognition agreement (MRA) or comparable reciprocal agreement with the US; mainland China is not one. Grants issued, and applications received, before then aren't affected. The rule covers certification, a new FCC ID; the FCC is still asking whether Subpart B testing under an SDoC should also need a recognized lab.
• Before you book, ask the lab to show its FCC recognition for your tests, and check that it isn't on the FCC's prohibited list.

Is UL listing required to sell electronics in the US?

• Who asks. No federal law requires a safety listing for most consumer electronics. Retailers, Amazon for some categories (check your category's compliance requirements in Seller Central before you budget; they change), insurers and business customers often do, and in workplaces OSHA requires many kinds of electrical equipment to be approved by a Nationally Recognized Testing Laboratory.
• What an NRTL is. A private lab OSHA has recognized to test products to US safety standards and mark them. There are 21, including UL, Intertek (the ETL mark), CSA and TÜV, and their US marks serve the same purpose, so UL isn't the only choice.
• Which standard. Computers, chargers, and audio, video and communication devices are tested to UL 62368-1, which replaced the older standards in 2020. Other products use their own: household appliances UL 60335 or an older UL standard for that appliance, lighting UL 1598 for fixed fixtures or UL 153 for plug-in lamps, with UL 8750 for the LED parts, and lab and test equipment UL 61010-1. Ask the lab which applies before you book.
• Keeping it small. A product powered by an external adapter that already has its own listing, with only low voltages inside, is a much smaller safety evaluation. A battery inside still needs its own safety evaluation; see the battery section below.
• What comes after. A listing comes with regular factory inspections and yearly fees, and the listing file names the critical parts and materials, such as the plastic's grade and flame rating. Changing them later needs the lab's review; see Aluminum or steel injection molds for what that means when a mold changes.

Which battery tests does a lithium-powered product need?

• UN 38.3. Every lithium cell and battery pack design has to pass the UN 38.3 tests before it ships by air, sea or road. A custom pack needs its own tests even if its cells have passed, and battery makers have to provide a test summary. Ask your pack supplier for the summary for that exact pack, and for its safety data sheet (SDS), the standard document on a battery's chemistry and handling; carriers, and Amazon in its dangerous-goods review, may ask for both. For shipping rules, see How do you ship your first production run.
• Battery safety. IEC 62133-2 (UL 62133-2 in the US), UL 2054 for packs and UL 1642 for cells are the battery safety standards that safety labs, retailers and Amazon ask for. Battery safety testing costs differ a lot between a single cell and a whole pack.
• Button and coin cells. Since October 23, 2023, under Reese's Law, any consumer product that uses button or coin cells has to meet UL 4200A-2023 (toys meet the toy standard's battery rules instead): a battery compartment that needs a tool, or two separate movements at once, to open, plus warnings on the product, the packaging and the manual. The product needs a General Certificate of Conformity (GCC), or a Children's Product Certificate if it's a children's product, which importers now file at customs too.

What extra testing does a children's product need?

• What counts. A children's product is one designed or intended mainly for children 12 and under. The CPSC judges that from how the product is designed, labeled, packaged and marketed, not from who ends up buying it.
• What's required. Testing at a CPSC-accepted third-party lab and a Children's Product Certificate from the importer or the US maker. Lead is limited to 100 parts per million in parts a child can reach and 90 in paint, with exemptions for some electronic components where lead is technically necessary. Toys and child care articles are limited to 0.1% of each of eight phthalates. Toys must meet the ASTM F963-23 toy standard, including its battery-compartment rules, and products for children under 3 can't have small parts. The product and packaging need permanent tracking labels showing who made it, where and when.
• Filing at customs. Since July 8, 2026, importers have had to file the certificate's data with US Customs when the goods enter, through Customs' ACE system (CPSC eFiling); for goods entering from a foreign trade zone, from January 8, 2027. Amazon also asks sellers for the certificate.

Do power adapters and built-in chargers need DOE or California approval?

• An adapter in the box has to meet the US Department of Energy's Level VI efficiency rules; buy one marked VI and listed in DOE's compliance database.
• A built-in charger. A device that charges its own battery, for example from USB-C, has a built-in charger in the Department of Energy's sense: it has to meet DOE's battery charger efficiency limits, the maker or importer reports it to DOE, and to be sold in California it has to be listed in the California Energy Commission's appliance database.
• Proposition 65. A business with 10 or more employees has to warn California buyers if the product can expose them to a listed chemical above set levels; in electronics, common sources are lead in solder or brass and phthalates in PVC cords.

When should you schedule testing?

• Pre-scan first. A pre-compliance scan, an informal EMC (emissions) check at a lab or with your own probes, run on a near-final board and again with the production enclosure and cables, finds problems while the design can still change. Labs rent chamber time by the hour or the day.
• Formal tests on production units. Run the formal tests on units built the way production will build them, from production tooling where there is any, usually the pilot run. Hand-built prototypes may not behave like the production product.
• Samples. FCC labs usually want two or three production-representative units, with test-mode firmware for the radio (firmware, often supplied by the module maker, that makes the radio transmit continuously on channels the lab picks); safety labs want more, and some are destroyed in fault tests; battery tests take dozens of packs (one battery maker lists 16 for UN 38.3).
• Timeline. For a product with a radio module, a listed adapter and a battery pack that already has its reports, plan the formal tests about 6 to 10 weeks before shipping, which leaves room for one failed attempt and a retest. With your own radio, a custom battery pack or a failed test, plan 3 to 6 months.

What should you change if your product fails FCC emissions testing?

• Find the source first. Test with and without each cable, and probe the board and seams near the failing frequency. Cables are often the antenna.
• Cables. A ferrite on the cable or a common-mode choke (a small filter part on the board where the cable connects), a shorter cable, a shielded cable with its shield connected all the way around at the connector, and the connector's metal shell tied to the case or the board's ground.
• A metal enclosure. Seams and openings leak according to their longest dimension. A common rule of thumb keeps any slot under a twentieth of the wavelength, about 15 mm at 1 GHz. Space screws closely along seams, use conductive gaskets or spring fingers, bond vents and panels all the way around, and leave anodizing or powder coat off where parts must touch; see Sheet metal, aluminum extrusion or CNC.
• A plastic enclosure. A conductive coating inside the case, or a metal shield can over the noisy part of the board, connected to the board's ground through spring contacts.
• The board. A continuous ground plane under fast signals, filtering where cables leave the board, slower signal edges, and a spread-spectrum clock, which spreads the clock's noise across nearby frequencies.
• Record the fix. Whatever you add to pass goes into the test report and into production.

A retest is billed by the hour or the day, but the bigger cost is time: rebooking the lab, getting new parts and, if the board has to change, a new board run.

Example: a Bluetooth desk device

This is an illustration, not a customer project. The product and all the numbers are made up.

In this made-up case, a desk device with a Bluetooth module that has its own FCC ID, a small lithium-ion pack that it charges over USB-C, and power from a listed adapter is sold online and on Amazon to adults. Its made-up first run is 500 units.

• FCC (made-up numbers): Subpart B testing plus a check of the module in the product at a US lab: $7,500 and three weeks.
• A failed first attempt (made-up numbers): radiated emissions from the USB cable fail. A ferrite and a better ground connection at the connector fix it, adding a made-up $2,000 and three weeks, and the ferrite goes into production and the test report.
• Built-in charger (made-up numbers): the device charges its own pack, so its charger is tested to DOE's method, reported to DOE and listed in California's database: a made-up $1,500, run alongside the FCC tests.
• Bluetooth listing: the product is qualified and listed with the Bluetooth SIG, referencing the module's qualification, at the SIG's published $12,000 for its free membership level.
• Battery (made-up numbers): the pack maker already has UN 38.3 and IEC 62133-2 reports for this exact pack, so a made-up $0 in new testing; the team keeps the test summary and the safety data sheet for shipping and for Amazon.
• Safety listing (made-up numbers): not needed at launch, because in this made-up case the Amazon category doesn't ask for one. When a retail chain asks a year later, the team budgets a made-up $12,000 and ten weeks, plus a made-up $3,000 a year in inspection fees.
• A version for children 12 and under (made-up numbers): about a made-up $2,000 more for children's product testing, plus tracking labels, a Children's Product Certificate and filing at every import.

In this made-up example, testing and listings at launch cost $23,000 and about six weeks: $7,500 for FCC, $2,000 for the failed attempt, $1,500 for the charger and $12,000 for the Bluetooth listing. The safety listing comes later. The general rule: choose parts that already carry their approvals, such as a radio module with its own FCC ID, a listed adapter and a battery pack with its reports, pre-scan early, and run the formal tests on units built the way production will build them.

What should you ask a test lab?

• Is the lab recognized by the FCC for the tests you need, and who owns it?
• What does a pre-scan cost, and can it be booked weeks before the formal test?
• How many units, what firmware and test modes, and which cables and accessories?
• What does a retest cost, and how soon can they rebook if you fail?
• For a module: will they check the module's conditions, such as the antenna, radio exposure and label, in your product?
• For a built-in charger: can they run the DOE battery charger test?
• Can the same visit cover Canada and the EU (CE marking), if you'll sell there?
• For safety: which standard applies, what the listing file will name, and what the yearly inspections cost.
• For a children's product: is the lab CPSC-accepted for each test you need?

Where we come in

If you're planning a first production run and need to fit testing into it, this is one of the situations Anamor takes on. We don't test or certify products ourselves: if you need FCC, UL or CE testing, we arrange it with an accredited lab, and the cost is itemized in your quote.

Anamor takes US hardware teams with a working prototype into their first production run: we redesign the product for production, line up partner factories and suppliers in the US and overseas, price it at your quantities, and run the build through to shipping.

Send what you have: photos of the prototype, CAD if you have it, the radio modules, battery and power adapter you use, who the product is for, and how many you plan to make. Need an NDA? We'll send our mutual NDA, or review yours, before you send files. Within two business days, a real person on our team will reply with a free first look at your production run and a few times to talk.

Frequently asked questions

Do I need FCC testing if my product uses a Bluetooth module with its own FCC ID?

Yes, but not a new FCC ID if you stay within the module's conditions. Your product still needs Part 15 Subpart B testing for its own electronics, a check of the radio in the finished product, the module's antenna and exposure conditions, and a "Contains FCC ID" label. A product that uses Bluetooth also needs its own Bluetooth SIG listing.

Is UL listing required to sell electronics in the US?

Not by federal law for most consumer electronics. Retailers, some Amazon categories, insurers and business customers often ask for a listing from a Nationally Recognized Testing Laboratory, such as UL, Intertek (ETL), CSA or TÜV, and OSHA requires approved equipment in many workplaces. Computers, chargers and communication devices are tested to UL 62368-1; appliances and lighting use other standards.

What US rules apply to a children's electronic product?

A product designed mainly for children 12 and under needs testing at a CPSC-accepted third-party lab and a Children's Product Certificate from the importer or US maker, on top of FCC and battery tests. Lead limits, tracking labels and, for toys, the ASTM F963-23 standard apply. Since July 8, 2026, importers file the certificate's data with US Customs.