Two parts of Part 15 apply
FCC Part 15 covers devices that emit radio frequency energy without an individual licence. Bluetooth glasses fall under it twice. First, the Bluetooth radio is an intentional radiator operating in the 2.4 GHz band, and for this product type the relevant section is 15.247. Second, the rest of the electronics - the audio processor, the charging circuit, the touch controller, and on richer models the camera or AI processor - are digital circuits that can emit unintended noise, which is covered by Part 15 Subpart B. A test plan normally covers both, and the grant for the transmitter is what produces the FCC ID.
The split matters because changes affect the two parts differently. A new frame colour does not touch either. A new antenna position, a different chipset or a change in output power touches the transmitter test. A redesigned charging board or a new camera module touches the unintentional emissions test. Knowing which part a change affects is the first question to ask the lab before approving an engineering change.
What the lab tests
The lab works from the product, its schematics and its operating modes, and builds a test plan around them. The specific measurements, limits and methods come from the rule and the procedures the lab follows, and they are not something a brand or a sourcing desk should improvise. What a buyer can do is make sure the lab receives the right inputs and that the samples match the production design.
| Area | Rule | What the lab usually needs from the program |
|---|---|---|
| Bluetooth transmitter | Part 15.247 | Chipset and firmware version, antenna type and position, test mode firmware that can fix channels and power |
| Unintentional emissions | Part 15 Subpart B | Final board revision, charging cable and cradle, every operating mode including charging |
| RF exposure | 47 CFR 1.1307, 1.1310 and 2.1093 | Output power, antenna location relative to the head, duty cycle data per firmware |
| Labelling and manual | Part 15 labelling provisions | Label artwork, user manual text with the Part 15 statement, any electronic labelling approach |
Test-mode firmware is the item that most often delays a project. Without it, the lab cannot hold the radio on a fixed channel at a fixed power, and the session stops while the plant prepares a build. Ask the partner plant early whether a test-mode build exists for the chipset and firmware version that will ship.
Sample choice matters as well. Labs usually want units built on the production board revision, with the production battery, frame material and charging cable, because each of these can affect emissions. Samples assembled by hand from engineering parts can pass and then differ from the units that ship. A simple rule helps: test on DVT or later samples built at the partner plant that will run the batch, record the board and firmware versions in the report, and keep a sealed reference unit for later comparison during pre-shipment inspection.
RF exposure for a device on the head
Glasses are worn close to the head for hours, and the antenna typically sits in a temple a few millimetres from the skin. That is why RF exposure is part of the FCC file rather than an afterthought. The rules sit in 47 CFR 1.1307 and 1.1310, with 2.1093 covering portable devices used close to the body. Depending on output power and the antenna's position, the lab will either show that the device is below the level where a full assessment is needed or carry out a specific absorption rate (SAR) evaluation. Which route applies is the lab's call based on the design; it is not something to assume from a spec sheet.
The FCC ID and the label
The grant gives the product an FCC ID, which combines a grantee code with a product code. The label normally carries "FCC ID: XXX" in that format, and the Part 15 compliance statement goes on the product or, where the product is too small, in the user manual or packaging as the rules allow. Glasses have very little flat surface, so plants usually place the label text on the inside of a temple by laser marking or pad printing; some programs use electronic labelling through the companion app where the rules permit it. The exact placement and wording should be checked with the lab before tooling, because a temple surface that is too curved or too small may not carry legible text.
Marketplaces also ask for the FCC ID, and many check it against the public database. A mismatch between the ID on the listing, the ID on the product and the grant holder's records is a common cause of listing holds. Sellers should make sure the ID used belongs to the exact model they sell, not to a similar model from the same plant. More on listing data is in smart glasses listing content.
Who applies, and what changes later
On catalog models, the partner plant usually already holds a grant and the brand sells under it; the brand should receive the grant, test reports and label artwork, and confirm the model name matches. On logo programs, the grant may stay with the plant if the hardware is unchanged. On full custom programs with a new board or antenna, a new grant is usually needed, and the brand may choose to be the applicant. The ownership choice affects who can make future changes and who holds the file, so decide it before testing starts. These routes are outlined on OEM and private label.
Lab testing for FCC commonly takes 3 to 6 weeks depending on the lab and the scope, outside the production lead time listed on MOQ and lead time. A firmware update that changes radio parameters, a new battery that changes the board layout or a new frame material around the antenna can require a review. The desk tracks hardware and firmware versions against the tested build and flags changes before they reach a lot. If you are planning a US launch, note it on the quote form so the plant can share its existing FCC file at sampling stage.