Satellite Network Regulatory Compliance
Review this guide for regulatory certification for your device's use of the Hubble Satellite Network protocol in North America (United States, Canada and Mexico).
Overview
This guide covers certification for Hubble Satellite Network enabled device operation in the United States under the Federal Communications Commission (FCC), in Canada and in Mexico under their respective jurisdictions.
Certification only applies to Satellite Network: The Hubble Terrestrial Network protocol operates entirely within standard Bluetooth® Low Energy (BLE) specifications, so it doesn't require re-certification in any of these jurisdictions.
Responsible Party
Certification is required for any compliant, commercially deployed product using the Satellite Network protocol, and needs to be in place before commercial launch of your product. Obtaining this certification is the responsibility of the device manufacturer or operator ("responsible party"), not Hubble. Typically, this is the company that holds the equipment authorization for the device — whoever brings the device to market under their name, even if manufacturing is outsourced to a contract manufacturer or ODM (original design manufacturer).
FCC Part 15 (United States)
The FCC regulates unlicensed radio frequency (RF) devices operating in the US, including Bluetooth to satellite. FCC Part 15 certification is specific to the exact frequencies, timing, and power levels a device was tested with — it doesn't automatically extend to operation outside those parameters (per FCC Part 15.21).
Differences for Satellite Network
Satellite Network operates the radio differently than standard Bluetooth in order to reach satellites in low Earth orbit (LEO). Consequentially, your device's original Bluetooth certification doesn't extend to Satellite Network operation.
If your device runs both Satellite and Terrestrial protocols, it needs to be certified for Satellite Network even though Terrestrial-only operation wouldn't require it.
| Parameter | Standard Bluetooth | Hubble Satellite Network |
|---|---|---|
| Operating frequencies | 2.402–2.480 GHz (40 channels) | 2.481+ GHz, band-edge (19 channels) |
| Frequency hopping | Standard BLE hopping | Inter-packet hopping for dwell-time compliance |
| Silence period | Standard BLE timing | 0.8 ms between packets |
| Preamble format | Standard BLE preamble | Always-on preamble |
| Target receiver | Terrestrial | Satellite (LEO) |
Already have a certified device?
If your device already holds an FCC ID for standard Bluetooth, that certification does not cover Satellite Network operation — even though it's the same piece of hardware. The existing certification was tested and granted for the standard BLE parameters above; adding Hubble's Satellite Network firmware changes the frequencies, hopping pattern, and timing enough that it falls outside that grant's scope. You'll need a new Part 15 certification for the Satellite Network-enabled configuration before commercial deployment, though your existing Bluetooth certification (and any chipset-level certification from your vendor) can typically be reused as supporting documentation rather than starting from zero.
Doesn't Hubble's own FCC authorization cover this?
No. Hubble holds its own FCC authorizations for the satellite constellation and ground stations, but those fall under a different part of the FCC rules (Part 25, space stations) than the ones governing your device (Part 15, unlicensed transmitters). Hubble's network-level authorization doesn't extend to your endpoint; each device design needs its own Part 15 certification, obtained separately by the responsible party.
How to Initiate Certification
- Finalize your hardware and firmware. Certification testing is done against your production (or near-final) hardware running Hubble firmware with Satellite Network enabled — not a bare dev kit.
- Gather your existing certification data. Your chipset vendor's Core Design Number(s) and any existing Bluetooth FCC ID for the device speed up the process, since the test house can scope testing to what actually changed.
- Choose an FCC-accredited test house (an FCC-recognized Telecommunication Certification Body, or TCB) and submit your device for testing. Not sure where to start? Reach out to Hubble Support — we can point you to labs we have experience working with.
- The test house runs the required tests (see below) and reports the results.
- If the device passes, the test house or your TCB files for an FCC ID / equipment authorization on your behalf, covering that hardware design.
- If any test doesn't pass, the lab will tell you which parameter failed — you make the needed adjustment and retest.
Typical Timing and Cost
- Typical timeline: 4–8 weeks (device prep, lab testing, FCC filing)
- Typical cost: roughly $15,000-$25,000, depending on test house and device complexity
Since this takes 4–8 weeks and must be complete before commercial launch, start the process as soon as your hardware and firmware are finalized so it doesn't become a blocker on your launch date.
This certification covers every unit of that hardware design, not just the individual device tested — the same way a phone manufacturer certifies one model and ships millions of units. Firmware updates that don't change RF parameters remain covered by the existing certification.
Alternative Approaches
Pilot or Demo
If you're only running a limited pilot or demo, an FCC Part 5 experimental license lets you operate without full Part 15 certification — but only within specific locations, timeframes, and small device quantities, and never for paying commercial service. Full Part 15 certification is required before any customer-facing, revenue-generating deployment.
Pre-certified RF module
Starting from an FCC-certified BLE module helps, but doesn't remove the requirement. It gets you:
- Certification of the RF transmitter itself (the "intentional radiator")
- A reduced testing scope
You'll still need:
- Testing of unintentional radiation from your complete device (digital circuitry, power supply, etc.) — Part 15.109
- Your own Declaration of Conformity or FCC ID filing
- Confirmation that Satellite Network doesn't push the module outside the parameters it was originally certified for
Test Requirements
| FCC Certification Test | Requirement |
|---|---|
| Conducted power (15.247(b)) | Max conducted output power ≤ 1 W (30 dBm), measured at the antenna port |
| Frequency hopping (15.247(a)(1)) | Minimum 15 hopping channels; channel spacing ≥ 25 kHz or ⅔ of 20 dB bandwidth; average channel occupancy ≤ 0.4 s per 20 s |
| Out-of-band emissions (15.209) | Radiated emissions beyond the band edge must meet the spectral mask — especially important given Satellite Network's band-edge operation |
| Unintentional radiation (15.109) | Emissions from digital circuitry; required regardless of module certification |
Pass all tests: If your device passes all four tests, the test house (or your TCB) files for your FCC ID / equipment authorization directly — no design changes needed. In practice, devices built on a supported chipset running Hubble's Satellite Network reference firmware configuration typically pass without hardware changes, since the RF behavior has already been validated in Hubble's own testing.
Remediation: If a test doesn't pass, the lab's report identifies exactly which parameter failed (for example, transmit power slightly over limit, or dwell time on a channel exceeding spec). Remediation is usually a firmware-level adjustment — tuning power output or hopping timing — rather than a hardware redesign, and you retest just the failed item rather than restarting the full process. Antenna or shielding changes are occasionally needed for unintentional radiation (Part 15.109) findings, since those depend on your device's full physical design, not just Hubble's firmware.
Submission Checklist
- ✅ Device is running finalized firmware with Satellite Network enabled
- ✅ Conducted power tested for Part 15.247(b) compliance
- ✅ Frequency hopping tested for Part 15.247 compliance
- ✅ Out-of-band emissions tested for Part 15.209 compliance
- ✅ Unintentional radiation tested (Part 15.109) — required even with a pre-certified module
- ✅ FCC ID / equipment authorization obtained for the hardware design
ISED RSS-247 (Canada)
Satellite-side authorization in Canada (a Foreign Satellite Approval, or FSA) is a separate regulatory track that covers satellite reception — it doesn't cover your device, and doesn't substitute for RSS-247 certification. Your device needs its own certification regardless of any satellite-side approval.
Certification in Canada is handled by Innovation, Science and Economic Development Canada (ISED), the federal department responsible for radio equipment certification.
Because SatNet is a frequency-hopping system operating in the 2400–2483.5 MHz band, it falls under RSS-247 ("Digital Transmission Systems, Frequency Hopping Systems and Licence-Exempt Local Area Network Devices") — Canada's direct equivalent to FCC Part 15.247. The technical thresholds are closely aligned: a minimum of 15 hopping channels, with average occupancy per channel not exceeding 0.4 seconds within a period of 0.4 seconds times the number of channels.
RSS-247 classifies SatNet-enabled devices as Category I equipment, which requires either a Technical Acceptance Certificate from ISED's Certification and Engineering Bureau, or certification through a recognized Certification Body.
CRT Homologación (Mexico)
As in Canada, satellite-side authorization in Mexico (Confirmación de Criterio) is separate from device certification and doesn't substitute for it. Your device needs its own homologación regardless of any satellite-side approval.
Certification in Mexico is handled by the Comisión Reguladora de Telecomunicaciones (CRT), the technical regulatory body operating under the Agencia de Transformación Digital y Telecomunicaciones (ATDT). CRT took over telecom equipment certification (homologación) after Mexico's previous regulator, the Instituto Federal de Telecomunicaciones (IFT), was dissolved in October 2025.
Devices operating in the 2400–2483.5 MHz band using spread spectrum or frequency hopping require homologación under NOM-208-SCFI-2016, evaluated against Technical Provision IFT-008-2015. The process involves lab testing at an accredited facility, a Certificate of Conformity issued by a certification body, and a Certificate of Homologation issued by CRT.
Mexico's regulatory structure changed recently — CRT has been the certifying body for less than a year as of this writing. Confirm current procedures with your test house or Hubble Support before starting, since some specifics may still be settling.
FAQs
1. Do we need to certify every device?
No, certification is per hardware design. One certified representative device covers every unit of that design, including firmware updates that keep the same RF parameters. A certification can't be carried over to a different hardware design, even if it runs the same firmware.
2. Does duty cycle matter — what if the device only transmits a few times a day?
No. Certification requirements are based on whether the device transmits RF energy, not how often.
3. Can I keep changing the Satellite Network protocol without re-certifying?
Depends on what changes. Frequency plan, timing/dwell-time, or power level changes require re-certification. Payload content, encoding, or application-layer changes that don't touch RF parameters do not.
4. Can we test or demo without certification?
Yes, under an FCC Part 5 experimental license — limited to R&D, specific locations/timeframes, and small quantities. Not permitted for commercial service.
Resources
- FCC Part 15 Rules (47 CFR §15)
- FCC Equipment Authorization Procedures
- FCC-Accredited Test Lab Directory
- ISED RSS-247, Issue 4 (Canada)
- NOM-208-SCFI-2016 (Mexico — radio communication systems using spread spectrum/frequency hopping)
Questions about your specific device or timeline? Reach out to Hubble Support.