Academy

11 July 2026 · 5 min read

Do you need both CE and FCC certification?

CE and FCC are separate, non-overlapping requirements for two different markets. If you sell hardware in both the EU and the US, you need both, in full.

By The Conformery Team

Close-up of hands working with a circuit board in a lab setting, representing the shared EMC and safety testing behind CE and FCC certification

Photo: Photo by Willquezada on Pexels

Yes: if your hardware product is sold in both the EU and the US, you need CE marking for the EU and the applicable FCC authorization for the US, in full, as two independent processes. Neither one substitutes for the other, and there's no shortcut where passing one waives a requirement of the other, even though the underlying electrical-safety and EMC engineering overlaps considerably.

Why they don't substitute for each other

CE marking is an EU self-declaration covering whichever harmonised directives apply to your product, such as Low Voltage, EMC, Radio Equipment, RoHS and others, depending on what the device does. FCC authorization is a US requirement under an entirely separate legal system, governed by 47 CFR Part 15, and split between Certification (for intentional radiators like Wi-Fi and Bluetooth devices, which need an FCC ID; see our FCC ID lookup guide for how to read one) and Supplier's Declaration of Conformity (for unintentional radiators, meaning most other digital electronics). A product needs to clear both regimes independently to be sold legally in both regions.

Where the engineering work overlaps

The two regimes test genuinely similar things: electromagnetic compatibility, RF emissions, electrical safety. That overlap is why hardware teams often bundle CE and FCC pre-compliance testing into the same lab engagement, even though the certificates and declarations that come out the other end are entirely separate documents governed by different legal regimes. A single EMC test session can often generate data useful for both the EU technical file and the US test report, which is the real cost saving, not a shortcut on the requirement itself.

What actually differs between them

  • Who checks your work. CE is a self-declaration with no pre-market filing; FCC Certification (for intentional radiators) requires a formal grant from an FCC-recognized Telecommunication Certification Body before you can sell. SDoC, for unintentional radiators, is closer to CE's self-declaration model.
  • What gets restricted. RoHS and REACH substance restrictions are EU-specific; the US has no direct federal equivalent at the FCC level (California's Prop 65 is a separate, state-level US disclosure requirement, not a federal electronics regulation).
  • Labeling. CE requires the CE mark itself plus, where applicable, other markings (WEEE bin symbol, battery labeling); FCC-certified intentional radiators require the FCC ID and Part 15 statement, while SDoC devices need a simpler compliance statement without an ID.

What's changing on each side in 2026

Two developments are making dual CE/FCC compliance more involved, not less, for connected products:

  • EU side: radio cybersecurity is now mandatory. Since 1 August 2025, any radio equipment placed on the EU market must also meet the cybersecurity requirements in Articles 3.3(d), (e) and (f) of the Radio Equipment Directive, assessed against the harmonised standards EN 18031-1, -2 and -3. If your device has Wi-Fi, Bluetooth or any other radio function, this sits on top of the EMC and safety work you already budget for the CE mark. It doesn't touch FCC at all, but it does add a new gate before you can affix the CE mark on anything wireless.
  • US side: the FCC is moving to bar Chinese and Hong Kong test labs. On 30 April 2026 the FCC voted to advance a rule barring FCC-recognized Telecommunication Certification Bodies and test labs based in China and Hong Kong from the equipment authorization process for Wi-Fi, Bluetooth, Zigbee, Z-Wave, RFID and other wireless devices. The rule isn't final; it's still working through a comment period, with the FCC expected to offer a roughly two-year transition once it is. But if a meaningful share of your FCC testing currently runs through a Chinese lab, this is worth tracking now rather than after a final rule lands, since finding and requalifying with an alternative TCB takes real lead time.

Neither change alters the basic answer above: you still need both certifications in full if you sell in both markets. But they both add lead time you'll want to plan for rather than discover during a launch window.

Practical sequencing

Design your EMC and safety testing plan around both regimes from the start if you know you're launching in both markets. Retrofitting FCC testing onto a product engineered purely to EU EMC limits (or vice versa) sometimes surfaces a marginal failure that a joint test plan would have caught first time. See our CE marking requirements and FCC Certification vs SDoC guides for what each process specifically requires.

Sources

  1. 01FCC - Equipment Authorization Procedures
  2. 02European Commission - CE marking
  3. 03Federal Register - Promoting the Integrity and Security of Telecommunications Certification Bodies, Measurement Facilities, and the Equipment Authorization Program
  4. 04EU Radio Equipment Directive - cybersecurity requirements (Art. 3.3(d)(e)(f))

Not sure which rules apply to you?

Answer a few honest questions about your product and see every applicable regulation for the EU, UK and US, each linked to its official source.

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