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I'm considering importing Wifi enabled electronics that are FCC and CE certified by the manufacturer in China. We will sell them in US/Europe under our company name (no mention of OEM). Does the FCC and CE certification for that electronic item needs to be under our brand name ?

Edit/Update: The device is a mini PC. We're making NO changes to electronics. The only changes are: 1. The Electronics will be placed inside a different Custom shell that better suits our purpose. 2. The Brand name and model name for this product will be different than what was used in FCC certification. The device is powered by a DC adapter, so the AC to DC conversion happens at the adapter level.

Update 2: The old case is an ABS plastic case and came with a sticker like wifi antenna that was positioned towards the front. In the new case the same antenna will be positioned more or less in same direction.

Curious101
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  • Is the case (old one or new one) metal? Are you changing any of the shielding? – Jack B Oct 04 '18 at 17:11
  • The case will be ABS/PC blend with fire resistance for UL Testing. No changes to the shielding. I don't see any shielding on the PCB. I have verified that the FCC ID of the device is listed on FCC's website along with the Photos of the device. – Curious101 Oct 04 '18 at 17:14

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FCC testing usually includes rf testing of the unit in the case, unless it is a certified modular device. Changing the case will likely require retesting, and certification.

Keep in mind that even generic device's that are rebranded, only cosmetically, will often have their own fcc id. That's for devices that don't have case changes too.

Of course we are not lawyers, and the fcc process comes with heavy legal implications. Consult a lawyer. They may just say to recertify as a precaution. An upfront potentially unnecessary cost is easier to deal with than a large unforeseen fine or recall.

Passerby
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  • Thanks Passerby. I'll accept your answer and I do agree with your reasoning it is better to be safe and plan on spending the time and money as a precaution. It's just when you're starting out it is difficult to spend a lot of money like that. – Curious101 Oct 05 '18 at 00:15
  • @Curious101 Understandble. That's why consulting with a good product, communications or fcc specializating lawyers is recommended. They have a better idea on when or what requires FCC certification – Passerby Oct 05 '18 at 00:29
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Adding peripherals to WiFI adapters may negatively impact performance and certs. You may not assume compliance without your own diligent RF tests and records for FCC/CE etc. compliance. Listing FCC etc registration may be required for export to regional requirements.

SAFETY compliance demands AC to DC products that are external and safety listed are ok. You cannot modify them unless a waiver is allowed by regional authority. Putting them inside a container may raise the temperature rise and affect leakage results or even affect HIPOT results if tested floating and becomes earth bonded out.

Tony Stewart EE75
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A change in outer casing and instructional material could require a review of the certification. You will need to check with an agency that specializes in certifications. For USA, you will need listing and labeling by UL, ETL or another nationally recognized testing agency.

  • UL is generally about product safety, not emissions, so a separate issue from FCC (although CE covers both for the European market). – The Photon Oct 04 '18 at 16:03
  • Thanks Charles. Can you elaborate on "could require a review of the certification" please? For Shell - we will get the UL testing and certification. For FCC, I just want to make sure whether the FCC id issued for product is still usable by us or do we need to plan on spending time and money for re-certifying it. – Curious101 Oct 04 '18 at 17:10
  • I think your other two answers explained the concern better than I can. I disagree somewhat about consulting a lawyer. I think a technical consultant that specializes in FCC and perhaps safety as well might be a better choice. In any event, it is best to have an expert look at it rather than depending on answers here based on your description. –  Oct 05 '18 at 02:37