The FCC’s component rule, in force since 13 October 2026, changes what a US equipment authorization depends on. Before it, the main question was who made the finished device. Now the FCC will not authorize a new device that contains certain components from companies on its Covered List. To know whether your monitor is affected, you have to know which of its parts count, and who made each of them.
The FCC defines a logic-bearing hardware component as any device, module, sub-assembly, integrated circuit or other physical component that uses digital techniques and generates and uses timing signals above 9,000 pulses per second. Mechanical parts, passive components, power-only parts such as a battery cell, and motors with no embedded digital controller are outside the definition, and firmware is not covered for now. In a video baby monitor, the processor, image sensor, radio module, display driver, memory and audio codec all fall clearly inside. Power management, LED drivers, motor drivers and some sensors depend on the specific part. For each in-scope part, a brand should record the manufacturer and its parent group, including approved alternates, before filing for authorization.
This is Part 03 of our October sourcing series. Our earlier article on the FCC’s October 2026 component rule explains the rule and its dates. This one goes inside the product.
§01What the FCC actually defined
Any device, system, module, sub-assembly, integrated circuit, or other physical component that generates and uses timing signals or pulses at a rate in excess of 9,000 pulses (cycles) per second and uses digital techniques, or that generates and uses radio frequency energy for the purpose of performing data processing functions. FCC 26-50, Third Report and Order, paragraph 28 (paraphrasing the definition added at 47 CFR 2.902)
Two conditions have to be met together: digital techniques, and timing signals above 9 kHz. The order says a device that runs above 9 kHz without using digital techniques is not covered, and gives fluorescent light ballasts and ultrasonic cleaners as examples.
The order also lists what is outside: mechanical and structural parts, passive electrical parts, power-only parts such as a plain battery cell, and a bare motor with no embedded digital controller. It describes non-logic-bearing components as fixed and not using digital techniques. Software and firmware are not covered by this rule for now, though the Commission kept that question open.
Two points from the order affect how you plan. First, the prohibition looks forward only: previously authorized equipment can continue to be marketed, imported and used. Second, an application that was pending before the effective date is exempt, but an amendment that adds or changes a logic-bearing component is treated as a new application.
§02A part-by-part map of a video baby monitor
The table below applies that definition to the parts of a typical two-unit video monitor: a camera unit and a parent unit with a screen.
| Part | Where | Reading | Why |
|---|---|---|---|
| Processing and radio | |||
| Main processor / system-on-chip, including the image signal processor | Camera, often parent | Inside | The central digital device. In a camera this is often the most important part to trace. |
| Microcontroller | Parent, sometimes camera | Inside | Digital, clocked well above 9 kHz. |
| Radio module or radio transceiver chip | Both | Inside | Digital radio. A radio module that is itself covered equipment was already barred under the FCC’s earlier modular transmitter rule. |
| Flash and RAM memory | Both | Inside | Clocked digital integrated circuits. |
| Imaging and display | |||
| Image sensor | Camera | Inside | Modern image sensors are clocked digital devices with on-chip conversion and control logic. |
| Camera module (sensor on a small board) | Camera | Inside | A sub-assembly that contains a logic-bearing part. Trace both the module maker and the sensor maker. |
| Display panel with its driver or timing controller | Parent | Inside | The driver circuitry is digital. Trace the panel supplier and the driver chip maker. |
| Touch controller, if fitted | Parent | Inside | Digital controller chip. |
| Audio and sensing | |||
| Audio codec or amplifier with digital input | Both | Inside | Digital audio interface. A purely analog amplifier would sit under “depends”. |
| Microphone | Camera, parent for talk-back | Depends | A digital-output MEMS microphone contains digital logic. An analog electret microphone does not. |
| Temperature or light sensor | Camera | Depends | A digital sensor chip is inside. A thermistor or photodiode on its own is a passive or analog part. |
| Power and motion | |||
| Power management chip | Both | Depends | Switching regulators run well above 9 kHz, but frequency alone does not make a part logic-bearing. Parts with digital control interfaces are more likely inside. |
| Battery protection and charger chips | Parent, battery cameras | Depends | Some are analog circuits, some contain digital control. Check each one. |
| IR LED driver | Camera | Depends | A simple constant-current driver may be analog. A driver with digital dimming control is more likely inside. |
| Motor driver for pan-tilt | Camera | Depends | The motor itself is outside unless it has an embedded digital controller. The driver chip depends on its design. |
| Crystal or oscillator | Both | Depends | It creates the timing signal, but a quartz crystal on its own is a passive part. Ask your TCB how to treat oscillator modules. |
| Mechanical and passive | |||
| Battery cell | Parent, battery cameras | Outside | Named in the order as a power-only part. Its protection circuit is a separate question, above. |
| Pan-tilt motors, gears, IR-cut filter switch | Camera | Outside | Mechanical, or a bare motor with no embedded digital controller. |
| IR LEDs, antennas, lens, resistors, capacitors, connectors, bare PCB, enclosure | Both | Outside | Passive, optical or structural parts. |
TABLE 01 · External power adapters are separate products and may have their own authorization path. Treat them as a separate line in your records.
§03Three traps in tracing component origin
1. The name on the part is not always the company you need
The Covered List, as the FCC applies it, reaches subsidiaries and affiliates of named entities. In its first enforcement action on 22 October 2026, the FCC described the chip maker involved as a subsidiary of a listed company. A marking or a brand name on a part may not show its parent group. Record the legal manufacturer and its parent, not only the name printed on the chip.
2. Modules hide their parts
A camera module, a radio module or a display assembly arrives as one line on the bill of materials. Each contains its own logic-bearing chips, often from other makers. Ask module suppliers to list the logic-bearing parts inside, with makers, and keep that list with your records.
3. Alternates change during production
When a part is short, factories often switch to an approved alternate. Every alternate needs the same check as the original. Put the rule into your supply agreement: no change to a logic-bearing part, including alternates, without your written approval. Our article on supplier evidence beyond a sample covers change control in more detail.
§04A component origin record
The order does not set out a form for this. It mentions bills of materials as one way device makers can check their supply chains, and the Commission is still considering disclosure requirements separately. A simple record kept per product is enough to answer a TCB, a retailer or your own legal team.
| Column | What goes in it |
|---|---|
| Unit and function | Camera or parent, and what the part does: processor, image sensor, radio, display driver |
| Part description | Part family and package, as on the bill of materials |
| Legal manufacturer | The company that makes the part, not the distributor |
| Parent group | The manufacturer’s ultimate owner, checked against the Covered List and its affiliates |
| Inside module? | If the part sits inside a module, which module and which module supplier |
| Our reading | Inside, depends, or outside, with the reason |
| Approved alternates | Each alternate, with its own manufacturer and parent group |
| Evidence and date | Where the answer came from (datasheet, supplier declaration, part marking) and when it was checked |
TABLE 02 · One row per logic-bearing part and per alternate. Parts marked “depends” stay in the record with the reasoning, so the decision can be reviewed later.
§05When to build it
Component origin check · project timeline
The record is cheapest to build before the design is frozen, and most expensive after a filing is refused.
- At platform selection: ask for the logic-bearing parts list of any platform you are considering, with makers and parent groups.
- Before the bill of materials is frozen: complete the record, including alternates and the contents of every module.
- Before the authorization filing: review “depends” rows with your test laboratory or TCB.
- If a filing is pending: do not change a logic-bearing part without advice, since an amendment that adds or changes one is treated as a new application.
- During production: approve every alternate for a logic-bearing part in writing, and update the record.
- For any later change to an authorized product: ask your TCB how the change should be filed before you make it.
How we handle it. For projects built on our platforms, we prepare this record together with the brand before any certification filing, so the questions are answered by the people who chose the parts. The development process shows where it sits, and our reference platforms are the starting point for most projects.
This article reflects our reading of the published order. Where a part could go either way, the decision belongs to your TCB and counsel.
References
FCC, Third Report and Order, FCC 26-50, adopted 22 July 2026. Read the order (PDF).
FCC, news release on the first enforcement of the component rule, 22 October 2026. Read the release (PDF).
§06Questions buyers ask
What is a logic-bearing hardware component under the FCC rule?
Any device, module, sub-assembly, integrated circuit or other physical component that uses digital techniques and generates and uses timing signals above 9,000 pulses per second, or that uses radio frequency energy to perform data processing. Mechanical parts, passive components, power-only parts such as a battery cell and motors with no embedded digital controller are outside it.
Which parts of a baby monitor count as logic-bearing?
In our reading, the processor, microcontroller, radio module, memory, image sensor, camera module, display driver and digital audio parts are clearly inside. Power management chips, LED and motor drivers, microphones and some sensors depend on the specific part. IR LEDs, antennas, lenses, battery cells, motors and passive components are outside.
Does the FCC component rule cover firmware?
Not for now. The Commission declined to prohibit software or firmware components in this order and kept that question open.
Does the rule affect baby monitors that are already authorized?
The order says previously authorized equipment may continue to be marketed, imported and used. Applications pending before the effective date are exempt, but an amendment that adds or changes a logic-bearing component is treated as a new application. For changes to an authorized product, ask your TCB how to file before making them.
What should a brand ask its factory about components?
For each logic-bearing part, ask for the legal manufacturer and its parent group, the logic-bearing parts inside every module, and the same details for every approved alternate. Then agree in writing that no logic-bearing part changes without your approval.
Need a component record for a new project?
Tell us which platform and target markets you are considering. We will work through the logic-bearing parts with you before the bill of materials is frozen.
Start the Component Review → Component records · Reference platforms · Certification support · OEM / ODM