If your product contains clocks and digital circuitry, it is likely an unintentional radiator under FCC Part 15 Subpart B — even with no Wi-Fi. Intentional radiators (transmitters) add Subpart C (and others) obligations on top.
Many unintentional radiators use Supplier’s Declaration of Conformity (SDoC) with responsible-party documentation in the US. Intentional radiators generally need equipment authorization (Certification) via a TCB. Mixing these up delays Amazon listings and retailer onboarding.
Industrial vs residential emission limits change both lab cost and where you can market the device. Align US FCC class with EU EMC environment choices early — see Class A vs Class B and EMC Directive basics.
Need a scoped path? Hazloc Labs coordinates FCC and EU EMC evidence for hardware OEMs. Book a consultation.