Even if your device wasn’t designed to emit radio frequency (RF) energy, it may still fall under FCC rules as an Incidental Radiator—and that means certain compliance expectations still apply.
At American Certification Body (ACB), we help manufacturers understand FCC obligations, even for devices that emit RF unintentionally as a byproduct of operation. While these products typically do not require certification, you may still need to ensure proper shielding and responsible design to avoid causing interference.
What Are Incidental Radiators?
An Incidental Radiator is a device that generates RF energy during normal operation, but is not intentionally or unintentionally designed to do so. These are typically mechanical or electrical devices with motors, switches, or other components that produce low-level RF emissions.
Examples include:
- Electric motors
- Mechanical light switches
- Basic thermostats
- Relays or solenoids
- Electromechanical timers
- Some older appliances and tools
These devices can emit RF energy across a broad frequency range, but they don’t have embedded digital circuitry or RF transmitters.
Are Incidental Radiators Regulated by the FCC?
Yes—but differently than Intentional or Unintentional Radiators.
Under FCC Part 15, Section 15.13, Incidental Radiators are not subject to equipment authorization (no certification or SDoC required). However:
- Operators are required to use the device in a way that minimizes interference to licensed communications services.
- The device must be constructed using good engineering practices to reduce emissions.
- If your product causes harmful interference, the FCC can require you to take corrective action—even if certification isn’t needed.
For more details, you can refer to FCC Part 15, Section 15.13.
What’s Required for FCC Compliance?
Here’s what you typically need to do for an Incidental Radiator:
- Assess Emissions (optional but recommended)
Basic emissions testing may help confirm that your device isn’t likely to cause interference. - Use Sound Engineering Practices
Shielding, grounding, and proper wiring layouts can all help reduce RF noise. - Avoid Causing Interference
You are responsible for making sure your product does not interfere with licensed radio services (e.g., emergency comms, aviation, AM/FM). - No Certification or Labeling Needed
FCC IDs and SDoC documentation are not required for incidental radiators.
When to Get Expert Help
While incidental radiators typically don’t need testing or certification, things can get complicated if:
- Your product combines mechanical systems with digital controls
- You receive complaints about interference
- You plan to market your product in environments sensitive to RF noise (e.g., medical, aviation, telecom)
ACB can help you determine whether your product falls into the incidental category—or if it’s more appropriately classified as an Unintentional Radiator, which may require formal compliance.
For additional details on Unintentional Radiators, check out this article: FCC Unintentional Radiators.
Common Questions About Incidental Radiators
Q: Do incidental radiators need FCC certification?
A: No. FCC Part 15.13 does not require authorization. However, the device must not cause harmful interference.
Q: How do I know if my device is truly “incidental”?
A: If the RF emissions are purely a side effect of mechanical or electrical operation—and the device doesn’t contain digital electronics or transmitters—it likely qualifies.
Q: What if I receive interference complaints?
A: You may need to redesign or shield the product. The FCC has the authority to require corrections if your device is affecting licensed services.
Q: Can I test it anyway?
A: Absolutely. Pre-compliance testing is smart, especially if you’re unsure of the emission levels or plan to scale manufacturing.
Talk to ACB About Incidental Radiator Compliance
Have questions about your product’s classification—or concerns about emissions?
ACB can help you make confident decisions, reduce risk, and avoid regulatory issues down the road.
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