Landed cost and certification path estimator
Describe your device, radios and first batch. See the likely US certification path with rough lab fees, the tariff layers for your HTS heading, and a landed cost per unit with every step of the math shown.
Your device
Loaded with an example: an LTE-M + GNSS asset tracker, 500 units. Change any answer and the estimate updates.
Your estimate
Tracker · LTE-M / Cat-1bis + GNSS · 500 units · assembled in China
- Landed DDP per unit, before one-time costs
- $36.12–$70.87
- Per unit in the first batch, certification included
- $90–$279
- Certification, one time
- $26,900–$104,000 over 2–4 months
- Tariff layer on factory value
- 20%–37.5% as of October 2026
1. Certification path
Rough ranges, lab quotes vary. US market only.
| Requirement | Why it applies | Rough lab fees | Typical time |
|---|---|---|---|
| FCC Part 15 Subpart B, Supplier’s Declaration of Conformity (SDoC) 47 CFR 2.906 · Part 15 | Every digital device is an unintentional radiator and must meet the Part 15B emission limits. You test at a lab and keep the records; no FCC filing. A receive-only GNSS receiver is covered here and needs no grant of its own. | $400–$4,000 | 1–2 weeks |
| FCC Certification (grant and FCC ID): Parts 22, 24 and 27 (licensed LTE bands) FCC equipment authorization | Transmitters need a grant from a TCB. A pre-certified module can carry its own grant if you follow its integration rules and approved antennas. The host still needs testing for co-location of several radios, any antenna change and RF exposure. Devices used more than 20 cm from people get an RF exposure (MPE) evaluation, usually by calculation. | $6,500–$12,000 | 4–8 weeks |
| PTCRB device certification ptcrb.com | AT&T and T-Mobile require it. The finished device needs its own PTCRB certification even when the module is already certified. This range includes PTCRB’s own certification fee and lab testing. | $20,000–$50,000 | 4–8 weeks |
| Carrier approval (one carrier) | AT&T adds 1–2 weeks after PTCRB and waives its own fee for AT&T-approved modules. Verizon uses its own Open Development process instead of PTCRB; Verizon charges no fee, the maker pays the lab, and older estimates run up to about $70,000. If Verizon is your launch carrier, plan on the high end of this range or above it. All three carriers together run closer to $80,000–$200,000 over 3–6 months. | $0–$30,000 | 1–2 weeks after PTCRB (AT&T); Verizon runs in parallel |
| UN38.3 lithium battery transport test 49 CFR 173.185 | Lithium cells and packs must pass UN38.3 before they ship. The cell or pack supplier usually holds the report; you need the test summary for your exact pack, and Amazon asks sellers to upload it. A new custom pack needs its own test. | $0–$8,000 | None if the supplier report covers your pack; 4–8 weeks for a new test |
| Total, one time | Sum of the rows. Excludes retests after a failed test. | $26,900–$104,000 | 2–4 months on the critical path |
- LTE band plan: use Cat-1bis or LTE-M with bands 2, 4, 5, 12, 13, 66 and 71. US 2G networks are gone, and AT&T no longer certifies new NB-IoT devices.
- Module choice: since the FCC’s FCC 25-71 order, a device that contains a module from a Covered List entity cannot be authorized. Since October 13, 2026, FCC 26-50 extends this to logic-bearing components made by Covered List entities. Quectel and Fibocom are not on the Covered List as of October 2026, but Quectel is on the Defense Department 1260H list. We keep a non-Chinese module option (for example Telit, u-blox, Sierra or Nordic) in the BOM.
- Since January 1, 2026, lithium batteries packed with a device (not installed in it) and shipped by air must be at 30% state of charge or less.
- Test labs: We run formal certification testing at FCC-recognized labs outside mainland China, such as Taiwan, Hong Kong or the US.
2. Tariff layers, as of October 2026
| HTS heading | Base duty | China Section 301 list | Forced-labor Section 301 | Combined |
|---|---|---|---|---|
| 8526.91.0040 Radio navigational aid apparatus (GNSS trackers) CBP ruling N315940 classified a cellular GPS tracking module here. Most likely heading for a GNSS tracker. | Free | List 1: 25% (9903.88.01) | 12.5% | about 37.5% |
| 8517.62.0090 Machines that receive, convert and transmit voice or data Possible if the product is mainly a cellular data device. A binding ruling settles which one applies. | Free | List 4A: 7.5% (9903.88.15) | 12.5% | about 20% |
- The estimate applies 20% at the low end and 37.5% at the high end until the HTS code is confirmed. For a GNSS tracker, plan on the high end.
- Layers stack: base duty (Free on these headings) + the China Section 301 list rate + the forced-labor Section 301 rate. Some trade tables list 13% for the new layer; we check the Federal Register notice (91 FR 47318) before quoting.
3. Main cost drivers
Share of the first-batch unit cost, using the midpoint of each range.
- Certification spread over the first batch: about $131 per unit (71%)
- Factory unit cost (BOM × conversion): about $38.30 per unit (21%)
- Tariffs: about $11.86 per unit (6%)
- Freight, brokerage and delivery: about $3.20 per unit (2%)
- Customs fees (MPF): about $0.13 per unit (0%)
- At 1,000 units the conversion assumption drops to 1.2–1.45×, and one-time costs per unit fall with every unit added.
- Certification costs more per unit than the device itself in this first batch. That is normal for a cellular product at this volume. It is paid once per product, not once per batch.
- Carrier certification is the largest one-time line. Choosing a module already approved by your target carrier and limiting launch to one carrier keeps it down.
- Classification swing: 8526.91 versus 8517.62 changes duty by 17.5 points of factory value, about $5.01–$8.40 per unit here. A binding ruling is worth asking for before volume shipments.
- Devices with lithium batteries ship as dangerous goods (UN3481). Air carriers add surcharges and paperwork, which sit in the freight line.
- Not in this estimate: engineering (NRE), injection-mold tooling and test fixtures. At small batches, the tooling choice (3D print, urethane casting, aluminum soft tool, steel tool) moves unit cost more than small BOM changes.
4. Landed cost per unit, step by step
Illustrative. Low end uses every low input, high end every high input.
| Step | Formula | This estimate, per unit |
|---|---|---|
| Factory unit cost (EXW) | BOM $22.00–$30.00 × conversion 1.3–1.6× (500–999 units) | $28.60–$48.00 |
| Tariffs | EXW × 20%–37.5% | $5.72–$18.00 |
| Customs fees | MPF 0.3464% of entry value (min $33.58, cap $651.50 per entry) ÷ 500 units | $0.10–$0.17 |
| Freight to your door | Air freight $0.80–$2.50 per unit + shipment fixed costs $450–$1,100 ÷ 500 units | $1.70–$4.70 |
| Landed DDP | EXW + tariffs + customs fees + freight | $36.12–$70.87 |
| Certification per unit | One-time $26,900–$104,000 ÷ 500 units in the first batch | $54–$208 |
| First batch, all in | Landed DDP + certification per unit | $90–$279 |
Get a reviewed estimate
An engineer checks your answers, the module and HTS options, and replies with corrections and next steps. A Duobay engineer replies within 2 business days. Your inputs travel with the link.
How the estimator works, and where the numbers come from
The estimator is a planning model. It turns seven answers into a certification path, a tariff layer and a landed cost range. Every assumption is listed below, so you can redo the math or swap in your own numbers. Regulatory facts are as of October 2026.
What each input changes
- Device category sets the freight assumption and the HTS headings we check first.
- Radios decide which FCC rule parts apply. BLE and 2.4 GHz Wi-Fi fall under Part 15C, 5 GHz Wi-Fi under Part 15E, and LTE under Parts 22, 24 and 27. LTE adds PTCRB and carrier approval.
- GNSS is receive-only, so it needs no grant. For a tracker it pushes the HTS classification toward 8526.91.
- Worn within 20 cm makes a transmitter a portable device under 47 CFR 2.1093, which brings SAR into scope.
- Battery adds UN38.3 and dangerous-goods shipping.
- Quantity picks the conversion multiplier and spreads fixed and one-time costs.
- BOM range is the base of the factory unit cost.
- Final assembly origin decides which Section 301 layers apply.
Certification ranges
Lab fees are rough ranges from public sources and our own planning ranges. Lab quotes vary by lab location, number of radios and bands, and how many retests you need. Durations are typical lab calendar time and exclude fixes after a failed test.
| Item | Range used | Basis |
|---|---|---|
| Part 15B SDoC | $400–$4,000 · 1–2 weeks | Published compliance-lab price guides: about $400–$1,300 at labs in China, $3,000–$4,000 at US labs. Rule: 47 CFR 2.906. |
| FCC Certification, BLE-only module design | $3,000–$8,000 · 4–8 weeks | Published lab and module-vendor cost guides for BLE module designs. |
| FCC Certification, Wi-Fi or LTE host | $6,500–$12,000 · 4–8 weeks | Published cost guides: $9,000–$12,000 for a wireless device, $6,500–$10,000 with a pre-certified module. A designer’s published bill for FCC, ISED and CE together came to about $12,200. |
| PTCRB | $20,000–$50,000 · 4–8 weeks | Cellular IoT provider cost guides. PTCRB’s own certification fee and lab testing are both included (ptcrb.com). |
| Carrier approval, one carrier | $0–$30,000 · 1–2 weeks after PTCRB | Our planning range. AT&T waives its own fee for AT&T-approved modules; Verizon charges no fee under its Open Development process, but older estimates put lab costs up to about $70,000. Public sources put FCC + PTCRB + one carrier at $30,000–$100,000 over 2–4 months, and all three carriers at $80,000–$200,000 over 3–6 months. |
| SAR | $4,000–$12,000 with LTE or Wi-Fi; $0–$5,000 BLE-only | Our planning range, to be replaced by lab quotes. BLE at low power often meets the test exclusion in FCC KDB 447498. Rule: 47 CFR 2.1093. |
| UN38.3 | $0–$8,000 | Our planning range. $0 when the cell or pack supplier’s test summary covers your exact pack. Shipping rule: 49 CFR 173.185. |
The estimate covers the US only. Canada (ISED), the EU (CE and RED) and the UK need their own testing, though one lab visit can often cover several markets at once.
We run formal certification testing at FCC-recognized labs outside mainland China, such as Taiwan, Hong Kong or the US. Separately, the FCC’s FCC 25-71 order bars authorization of devices that contain modules from Covered List entities, and since October 13, 2026 FCC 26-50 extends the bar to logic-bearing components from those entities. Both shape which lab and which module we plan from Gate 0.
Tariff layers, as of October 2026
For electronics, US import duty is a stack of layers on the customs value of the goods:
- Base (column 1) duty. Free for HTS 8517.62 and 8526.91.
- China Section 301 list rate. 25% for List 1 goods such as 8526.91.0040 GNSS trackers (9903.88.01), 7.5% for List 4A goods such as 8517.62.0090 (9903.88.15). Applies only to goods of Chinese origin. Source: USTR Section 301.
- Forced-labor Section 301 rate, in effect since July 24, 2026: 12.5% for China, Vietnam and Thailand; 10% for Indonesia and Malaysia; 0% for USMCA-qualifying goods from Mexico, 10% otherwise. Some trade tables show 13% for China; we check the Federal Register notice (91 FR 47318) before quoting.
That gives about 37.5% for a GNSS tracker from China under 8526.91, and about 20% under 8517.62. CBP classified a cellular GPS tracking module under 8526.91 in ruling N315940. For any product near that line, we recommend a CBP binding ruling. The estimator uses 20% at the low end and 37.5% at the high end for China, and 0%–12.5% for other origins, until the code is confirmed.
How we got here: on February 20, 2026 the Supreme Court ruled that IEEPA does not authorize tariffs. A 10% Section 122 tariff followed and expired on July 24, 2026, when the forced-labor Section 301 layer took effect. A separate Section 301 investigation into overcapacity, covering China, Vietnam and Mexico among others, is still open. When rates change, we update this page and its “as of” date.
Landed cost model
Landed DDP per unit = factory unit cost + tariffs + customs fees + freight. Certification is one-time and shown separately, then spread over the first batch. The low end combines every low assumption and the high end every high one, so the range is wide on purpose.
| Assumption | Value used | Why |
|---|---|---|
| Conversion multiplier (factory unit cost ÷ BOM) | 1.6–2.4× under 100 units 1.4–1.9× at 100–499 1.3–1.6× at 500–999 1.2–1.45× at 1,000+ | Covers SMT and assembly labor, programming, functional and RF test, packaging labor, yield loss, and factory and Duobay margin. Illustrative planning values, not a quote. Excludes engineering, tooling and fixtures. |
| Air freight per unit | Wearables $0.60–$2.00 Trackers $0.80–$2.50 Industrial $2–$8 Companions $4–$12 | Planning values by typical packed size and weight, including a dangerous-goods surcharge where a battery is inside. Ocean freight costs less per unit for large batches but adds weeks. |
| Fixed cost per shipment | $450–$1,100 | Pickup, export documents, dangerous-goods declaration, customs brokerage, bond and last-mile delivery. One shipment and one formal entry assumed. |
| Merchandise processing fee (MPF) | 0.3464% of entry value, min $33.58, cap $651.50 per entry | CBP fee on formal entries (19 CFR 24.23), fiscal year 2026 limits. The harbor maintenance fee (0.125%) applies to ocean shipments only and is left out because air is assumed. |
| Customs value | Factory unit cost | US duty is charged on the transaction value of the goods. International freight and insurance are not part of it. |
What the estimate leaves out
- Engineering fees for each gate, injection-mold tooling and production test fixtures.
- Mobile app and cloud backend. We deliver the device-side protocol and SDK and test against your backend.
- Markets outside the US, UL or IEC 62368-1 safety listing, and hazardous-location ratings.
- Cellular data plans, US sales tax, warehousing, returns, insurance and currency moves.
- Retests after a failed lab test, and component price swings between estimate and order.
How a reviewed estimate differs
A reviewed estimate starts from your actual requirements. The full version is Gate 0, Feasibility, which takes 1–2 weeks and delivers:
- System architecture document
- Costed BOM with landed DDP estimate
- Certification path (FCC / PTCRB / carrier as needed)
- Risk register
- Fixed quote for the next gate
Gate 0 is a paid, fixed-fee study. The fee is credited against later work if you continue. Certification and lab fees are paid by you at cost; we plan and manage them. What Gate 0 includes · How we quote landed DDP prices · How we run FCC certification.
Disclaimer. This tool gives rough planning numbers. It is not a quote, legal advice or a customs ruling. CBP decides classification and origin. An FCC-recognized lab and TCB confirm what testing your device needs. Tariff rates and FCC rules change; the rates shown are as of October 2026. Do not use these numbers for a customs declaration or a price commitment. The estimator runs in your browser and stores nothing.
Questions about the estimate
Can I skip FCC certification if I use a pre-certified LTE module?
Partly. The module grant can cover the radio if you follow its integration rules and approved antennas. The finished device still needs Part 15B testing, a SAR review if it is worn, and its own PTCRB certification for AT&T and T-Mobile. Full answer.
Why is the tariff range so wide for a tracker?
Classification. A GNSS tracker can fall under HTS 8526.91 (about 37.5% from China as of October 2026) or 8517.62 (about 20%). The product’s main function decides it, and a CBP binding ruling locks it in before you ship volume.
Does final assembly outside China remove the China Section 301 duties?
Only if the product’s country of origin changes. CBP looks for substantial transformation. Moving only the last assembly and packaging step usually does not change origin when the main board is built in China. We evaluate this per product.
Who pays the certification and lab fees?
You do, at cost. We plan the path at Gate 0, book the labs and manage testing, and the grants are issued in your company’s name. How we handle FCC.
Is anything I enter stored or sent?
No. The estimator runs in your browser. Your answers leave the page only if you click Get a reviewed estimate, which passes them to the request form as part of the link.