Use ESP32 as MCU (no radio) -- Certification needed?

[p-rimes]

Hi, certification experts!

The ESP32 seems to be a decent CPU with a decent toolchain, for a decent price -- not bad! I love the GPIO matrix, the dual-core/FreeRTOS, and there are ample peripherals (CAN, QSPI, ...). It's good enough that I would consider using it as an MCU, even without the flagship radio features (Wifi + Bluetooth).

So if I wanted to sell low-volume commercial products -- WITHOUT any radio features of any kind -- would I still need to obtain FCC certification (and/or IC, CE), ensure the IC has an RF shield, etc? Are there eFuses to burn, which could permanently disable the radio, and would that be necessary to prove there is no possible radio activity?

Thanks for any suggestions.

[danak6jq]

I am not an attorney, but, if you don't turn the radio on and don't attach an antenna to the chip, then it's not an intentional radiator. So I'd think it's like any other MCU in that case - you may still require some FCC certification for Part 15.

Cheers,
Dana