Automotive remote transmitters – including key fobs, remote-head keys, flip keys and proximity (PEPS or “smart”) keys – are required by law to be certified with the FCC and to have the FCC ID marked on the outside of consumer products. This is for consumer protection – so that you can know that the product’s transmission characteristics have been tested, that the product transmits reliably and safely, and so that you can file a report if you experience an interference problem caused by the product.
However, in the automotive electronics world, products frequently do not comply with FCC requirements. This is possible because (1) FCC compliance is not an easy thing to police and (2) the FCC’s enforcement capability has been basically eliminated by successive rounds of budget cutting at the hands of legislators who favor business over the consumer and tax cuts over regulatory protection. I will let you guess with which party most of those legislators are affiliated.
Failure to comply with FCC requirements can take many forms. Some products are neither tested nor labelled. Others may be properly tested and certified, but are not properly labeled. And still others may or may not be tested, but are labeled with an invalid FCC ID. We know that the FCC has some awareness of the existence and nature of violations and chosen not to pursue enforcement. We do not know why that is. When the FCC does choose to act, it may be purely as a result of one business “reporting” another rather than because of a consumer complaint or through the FCC’s own compliance efforts. Of course, in these situations, the FCC may be serving the interests of one company versus another more than they are really serving the consumer. So, not only is regulation sometimes toothless, it can also be used to serve private gain rather than public service. Such is the absurd regulatory world in which we now live. Of course, automotive remotes are not medical devices or Boeing 737 MAX airplanes, but the forces shaping the outcomes are the same.
Having been in the automotive remote business for more than 20 years, we are aware of dozens of invalid FCC IDs shown on automotive remote transmitter cases. And there may be even more situations where no FCC ID label appears on a transmitter or it would be nearly impossible for a consumer to read. You might think it is mostly unscrupulous off-shore manufacturers who fail to comply with FCC requirements. While those suppliers certainly are a problem, you may be surprised to know that Chrysler, Ford, GM and most other automakers have also used and sold products that fail to comply. So do major add-on system manufacturers responsible for brands you know.
Three examples are Chrysler parts 68155686AA, 68155687AB and 68394195AA. These three “tombstone” style smart keys used on recent model vehicles. All are labeled with FCC ID M3M-40821302. There is no listing of FCC ID M3M-40821302 on the FCC’s public information website. The first three or five characters of an FCC ID are the grantee. The grantee identification for “M3M” is a UK company that certified one device in the 1990s and is not active in the automotive transmitter industry. One might argue that the labeling of these products violates FCC requirements, in addition to the fact that the FCC ID shown on the label is not a valid one. This is because the average consumer will never find the FCC ID on these products because of its size (very small) and location (under the emergency key insert). Our staff often needs work-table lighting and a magnifying glass to read the FCC IDs on Chrysler tombstone transmitters.
It seems unlikely that Chrysler is knowingly selling non-FCC-certified products. It is possible that M3M-40821302 was printed on these parts by mistake. The FCC is one character different from a valid FCC ID number – M3N-40821302, for which the grantee is a large automotive component supplier, Continental Automotive Systems. Interestingly, though, while tombstone smart keys with FCC ID M3N-40821302 are basically interchangeable with each other, parts marked with FCC ID M3M-40821302 are not interchangeable with those others. So, maybe the invalid FCC label M3M-40821302 was not really a mistake after all.
One ironic effect of a situation like this is that now there are countless sellers of remotes who include the “FCC ID” M3M-40821302 as a search term for the Chrysler parts that are marked that way. We have a search for that FCC ID set up on our website because; otherwise, consumers might not find the remote they need. Almost any one of sellers who references M3M-40821302 would tell you that it is a valid FCC ID. Thus, by repetition on the Internet, fiction becomes truth. Can you think of any other circumstance in which this has happened?