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FCCUnited StatesSmart plugs

Do smart plugs need FCC certification?

Updated

Short answer

Yes.

Every smart plug has a radio, whether Wi-Fi, Bluetooth, Zigbee, Thread or a proprietary 2.4 GHz link. That makes it an intentional radiator that must be certified by a TCB before it is imported or marketed, under 47 CFR 15.201(b). Most smart plugs use a pre-certified module, which carries the radio's FCC ID, plus SDoC testing of the plug as a Class B digital device.

What changes the answer

  • Module with a full modular grant. If the module's grant under 47 CFR 15.212 covers the antenna and layout used in the plug, the plug can rely on it. Mark the plug "Contains FCC ID" with the module's ID. The host still needs SDoC testing for unintentional emissions and AC line conducted emissions.
  • Limited modular approval or a custom radio. A module approved only for specific hosts, or a radio designed onto the main board, means the finished plug needs its own certification or a permissive change by the module grantee.
  • Plugs without a radio. A mechanical timer plug is not a radio device. A digital timer plug with a clock and microcontroller is a Class B digital device and needs SDoC.
  • Covered List. Equipment produced by an entity on the FCC Covered List must be certified, cannot use SDoC (47 CFR 15.103(j)), and may be barred from new grants.

What to do

  1. Get the module's FCC ID from the supplier and check the grant in the FCC equipment authorization database: grantee, model, antenna and any grant conditions such as limited modular approval.
  2. Have an accredited lab run Class B emissions tests on the finished plug, including AC line conducted emissions, since the plug runs from mains power.
  3. Issue the SDoC compliance information under 47 CFR 2.1077, naming a U.S. responsible party, and print the 15.19 statement on the plug or in the manual and packaging.
  4. Label the host with the "Contains FCC ID" statement, or with its own FCC ID if you certified the finished product.
  5. Electrical safety is separate from the FCC. No federal rule makes UL listing mandatory for consumer smart plugs, but retailers often require a safety listing from a nationally recognized lab, so budget for it.
HTS lines used for smart plugs
  • 8536.69.80.00

    8536: Electrical apparatus for switching or protecting electrical circuits, or for making connections to or in electrical circuits (for example, switches, relays, fuses, surge suppressors, plugs, sockets, lamp-holders and other connectors, junction boxes), for a voltage not exceeding 1,000 V; connectors for optical fibers, optical fiber bundles or cables

    Lamp-holders, plugs and sockets / Other

    Plugs and sockets, other. Used for many plug-in adapters; CBP rulings on smart plugs differ by design.

    General rate
    2.7%
    Free or reduced under 18 programs
  • 8536.50.90.65

    8536: Electrical apparatus for switching or protecting electrical circuits, or for making connections to or in electrical circuits (for example, switches, relays, fuses, surge suppressors, plugs, sockets, lamp-holders and other connectors, junction boxes), for a voltage not exceeding 1,000 V; connectors for optical fibers, optical fiber bundles or cables

    Other switches / Other

    Other switches. Some rulings treat a plug whose main function is switching a load as a switch. Check rulings before you enter goods.

    General rate
    Free

Next steps

Frequently asked questions

Does a smart plug with a certified Wi-Fi module need its own FCC ID?
Not if the module has a full modular grant and you use it within its conditions. You label the plug with "Contains FCC ID" and the module's ID, and you still authorize the host by SDoC.
Who files the FCC paperwork for an imported smart plug?
Certification is filed by the grantee through a TCB, often the module maker or the brand. For the SDoC part, the U.S. importer is the responsible party unless a U.S. retailer or OEM agrees to take over under 47 CFR 2.909(b).
Do online marketplaces check FCC IDs?
They are starting to have to. 47 CFR 2.803(c) requires online marketplaces to display a valid FCC ID for devices subject to certification, with the obligation for marketplaces that handle the goods taking effect March 1, 2027.

Sources

  1. 47 CFR 15.201, Equipment authorization requirement for intentional radiators, eCFR, National Archives
  2. 47 CFR 15.212, Modular transmitters, eCFR, National Archives
  3. 47 CFR 2.803, Marketing of radio frequency devices, eCFR, National Archives
  4. 47 CFR part 15, Radio frequency devices, eCFR, National Archives

This is general information drawn from the official sources linked above. It is not legal advice. Rules change and often turn on the facts of your product, so confirm your test plan with an accredited lab and your obligations with qualified counsel before you import or sell.