This guide covers Bluetooth headphones sold in the Chinese market and outlines the regulatory boundary, test requirements and approval process for SRRC (type approval of radio transmission equipment). Products may not be manufactured, imported or sold without the grant; the specific provisions shall be governed by the original text of the regulations and the current requirements of the authority and the designated test laboratory.
SRRC is administered by the Radio Administration Bureau of the Ministry of Industry and Information Technology (MIIT). Upon approval, a Type Approval Certificate for Radio Transmission Equipment and a unique type approval code (CMIIT ID) are issued. Article 6 of the Provisions on the Administration of Radio Transmission Equipment (MIIT Order No. 57, effective July 2023) stipulates that, except for short-range low-power devices, radio transmission equipment manufactured or imported for sale or use in China shall apply for type approval. Although Bluetooth is a short-range communication technology, conventional Bluetooth headphones generally exceed the exemption conditions for low-power devices and cannot be exempted merely on the grounds of low output power; whether an exemption applies shall be determined by checking the device categories and limits set out in MIIT Announcement No. 52 of 2019 and the 2400 MHz band management documents.
There is only one criterion: whether the device emits radio waves. Both earbuds of a TWS pair and the inter-ear communication link are active transmitters and must be included in testing; the headset itself is the approval unit, with one certificate per model.
A charging case that only handles charging, power management and wired contact power delivery, and contains no radio module, does not constitute radio transmission equipment, requires no separate approval, and does not carry its own CMIIT ID — this is the basis for the statement that "only the headphones are regulated". However, the precondition must be stated explicitly: once the case incorporates Bluetooth pairing/finding, NFC, UWB or wireless charging transmission, a re-assessment is required. Bluetooth and 2.4 GHz emissions require type approval; 13.56 MHz NFC is generally managed as a short-range low-power device (still subject to the limits of Announcement No. 52); wireless charging falls under ISM radiation equipment, is not subject to type approval, but remains subject to product quality and EMC regulations. Purely wired headphones and receive-only devices are likewise out of scope. It is advisable to fix the RF function list of both the headphones and the charging case at project kick-off to avoid supplementary testing after submission.
Per the original wording, testing focuses on three areas: frequency, power and radiated interference, and may use ETSI EN 300 328 V1.7.1 under the CE framework for pre-evaluation. The standard applies to wideband transmission equipment in the 2.4 GHz ISM band; its core items are EIRP (limit 100 mW / 20 dBm), power spectral density (10 mW/MHz, non-FHSS), frequency range (2400–2483.5 MHz), occupied bandwidth, hopping mechanism, and transmitter/receiver spurious emissions.
One point needs clarification: EN 300 328 is a harmonized standard under the EU R&TTE / RED directives (V1.7.1 is the 2006 edition), while the formal basis for domestic SRRC approval is the technical requirements issued by the national radio administration and the relevant national standards — EN standards are not directly adopted. The two overlap in test items but differ in limits and temperature/voltage conditions; the same module may "pass CE but fail a domestic item" or vice versa. An EN report is therefore suitable only for pre-evaluation and rectification targeting, and cannot replace the domestic test report.
Typical documents: business licence, application form and letter of commitment, technical specification and RF parameter table, circuit diagram and block diagram, list of key RF components, antenna specification, fixed-frequency test mode description, six-view and nameplate photos; usually 2–3 samples, at least one capable of continuous fixed-frequency transmission. The model name on the nameplate must match the application form; without a fixed-frequency test command, steady-state measurements cannot be performed.
Process: pre-evaluation → testing at the designated laboratory → test report → submission via the MIIT government service platform → review and approval → CMIIT ID marking. The authority decides within 15 working days of acceptance; sample shipping and testing time are excluded. Including laboratory scheduling, the overall timeline is about 6–10 weeks. The code shall be marked on the device or displayed electronically; where the device is too small, it may be placed on the independent outer packaging or in the user manual — particularly practical for true wireless earbuds. After the grant, a separate sales filing is required for commercial sale; it is independent of type approval.
The most common failure is spurious emissions exceeding limits, followed by antenna inconsistency with the submitted sample and incomplete documentation. Three frequent misconceptions: assuming "a certified module exempts the end product" (restricted modules and chip-based designs still require end-product approval, with possible test simplification only), assuming "one certificate covers multiple models", and delaying certification until just before mass production. After the grant, production parameters must remain consistent with the certificate; changing the chip, antenna or output power may trigger a change application or a new approval. The certificate is valid for 2–5 years as stipulated, must be renewed before expiry, and updates to rules such as 2400 MHz band interference-avoidance requirements should be tracked.
References: Radio Regulations of the People's Republic of China; Provisions on the Administration of Radio Transmission Equipment (MIIT Order No. 57); MIIT Announcement No. 52 of 2019 and the 2400 MHz band management documents; ETSI EN 300 328 V1.7.1. Timelines and sample quantities are industry practice and shall be confirmed against the current requirements of the designated laboratory and the authority.
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