FCC Permissive Changes Explained: Class I, II and III

What is a permissive change?

Products change after certification: a new antenna, a different component supplier, a firmware update. The rule in 47 CFR § 2.1043 sorts these changes by how much they affect what was originally reported to the FCC. A permissive change keeps the same FCC ID. It can never change the device’s identification.

A permissive change is not allowed for changes to the frequency-determining circuitry, the frequency multiplier stages, the basic modulator, or the maximum power or field strength ratings. Those need a new application and grant (§ 2.1043(a)).

Class I permissive change

A Class I change does not degrade the characteristics reported to the FCC. Examples are a new enclosure color, a different capacitor with the same performance, or a lower-gain antenna of the same type. No filing is required. The grantee keeps records of the change. Class I changes do not appear in the public grant records.

Class II permissive change

A Class II change degrades a reported characteristic but the device still meets the rules. The grantee files new test results with a TCB, and the modified device cannot be marketed until the change is accepted. The FCC ID stays the same, and a new grant entry appears on the record with the application purpose “Class II Permissive Change”. More in Class II permissive change.

Class III permissive change

A Class III change applies only to software-defined radios. It covers software changes that alter the frequency range, modulation type or maximum output power beyond what was approved, or change the conditions of use. The grantee files test results, including RF exposure. The new software cannot be loaded or marketed until the change is accepted. A device that already had a Class II change cannot use Class III.

The three classes compared

	Class I	Class II	Class III
What changes	Nothing reported gets worse	A reported characteristic gets worse, still within the rules	Software-defined radio parameters
Filing	None	Test results to a TCB	Test results, including RF exposure
Sell before acceptance?	Yes	No	No
FCC ID	Same	Same	Same
Shows on the public record	No	Yes	Yes

Change in Identification

A Change in Identification gives an already certified device a new FCC ID, without electrical changes. It is common when a device is rebranded or sold by a different company. If nothing reportable changed, the grantee can use a short-form application (§ 2.933). Example record: FCC ID QGH-ACEVC80G, filed as a Change in Identification.

Look up an FCC ID

Sources

47 CFR Part 2, Subpart J: Equipment Authorization Procedures
FCC Equipment Authorization System (public records)

FCC permissive changes explained