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LegalUpdated September 4, 2026

Certifications & Compliance

The radios and certification-relevant components in every ZeroTrace device, the Espressif ESP32-S3 / ESP32-C5 module certification matrix (CE, FCC, IC, KCC, SRRC, TELEC, MIC, NCC, ANATEL, Wi-Fi, BQB), the Echo 433 MHz sub-GHz radio, and the USBLogger's direct-SoC integration.

This policy is issued by NetzSec and applies across everything we operate, including the ZeroTraceproduct line (zerotrace.one and its subdomains). Where it says “NetzSec” or “we,” that covers ZeroTrace too.

1. Overview

ZeroTrace hardware is built around genuine Espressif ESP32-S3 and ESP32-C5 radio modules, with the Echo adding a separate 433 MHz sub-GHz radio. Where a pre-certified module is used, the radio sub-system carries the module manufacturer's certifications, which are inherited by the assembled product. ZeroTrace firmware does not alter the radio parameters, antenna configuration, or transmit power of the underlying module.

This page lists the certification-relevant components in each device, the module certification matrix, and the compliance notes that apply to the radios that are not covered by a pre-certified module.

2. Which radio is in which product

ProductPrimary radio moduleSecond radioAntennaBands
AirLeak ProESP32-S3-WROOM-1UESP32-C5-WROOM-1UExternal U.FL / IPEX2.4 GHz Wi-Fi + BLE, 2.4 / 5 GHz Wi-Fi
AirLeak MiniESP32-S3-WROOM-1UESP32-C5-WROOM-1UExternal U.FL / IPEX2.4 GHz Wi-Fi + BLE, 2.4 / 5 GHz Wi-Fi
EchoESP32-S3-WROOM-1U433 MHz sub-GHz (CC1101 front-end)External U.FL (Wi-Fi/BLE) + SMA (sub-GHz)2.4 GHz Wi-Fi + BLE, ~410–450 MHz sub-GHz
DongleESP32-S3-WROOM-1—On-module PCB antenna2.4 GHz Wi-Fi + BLE
USBLoggerESP32-S3 SoC (direct, not a module)—2.4 GHz chip antenna2.4 GHz BLE (used only for the app link)

Firmware-only products (for example AirLeak Firmware) run on a user-supplied ESP32-S3 board; the certification of that board is the responsibility of its manufacturer and the buyer.

3. Pre-certified modules used

Most ZeroTrace hardware uses fully certified Espressif modules. ZeroTrace firmware does not change the radio, antenna configuration, or transmit power, so the module's conformity assessment continues to apply.

  • ESP32-S3-WROOM-1, 2.4 GHz Wi-Fi + BLE, PCB antenna — Dongle
  • ESP32-S3-WROOM-1U, 2.4 GHz Wi-Fi + BLE, external IPEX/U.FL antenna — AirLeak Pro, AirLeak Mini, Echo
  • ESP32-C5-WROOM-1U, dual-band 2.4 / 5 GHz Wi-Fi + BLE, external IPEX/U.FL antenna — AirLeak Pro, AirLeak Mini
  • ESP32-S3-MINI-1, compact 2.4 GHz Wi-Fi + BLE module — listed for firmware-only / bring-your-own-board use

Manufacturer test reports and certificates are linked in the matrix below.

4. Module certification matrix

Region / AuthorityWROOM-1 (PCB)WROOM-1U (ext. ant.)MINI-1C5-WROOM-1U (dual-band)
CE, EuropePDFPDFPDFPDF
FCC, USAPDFPDFPDF2.4 GHz · 5 GHz
IC, CanadaPDFPDFPDFPDF
KCC, KoreaPDF—PDFPDF
SRRC, ChinaPDFPDFPDFPDF
TELEC / MIC, Japan—PDFPDF2.4 GHz · Ch 14 · 5 GHz
MIC, VietnamPDF—PDF—
NCC, TaiwanPDF——PDF
ANATEL, BrazilPDF———
Wi-Fi, Wi-Fi AlliancePDFPDF—PDF
BQB, Bluetooth SIGPDF—PDF—

A dash (—) means Espressif has not published a certificate for that variant in that region. The module may still be usable there under host-product certification; additional national approvals (for example UKCA, RCM, WPC) may exist at module level, contact us before bulk-ordering for a specific region.

5. Echo — 433 MHz sub-GHz radio

Alongside its ESP32-S3 Wi-Fi/BLE module, the Echo carries a separate sub-GHz radio (a TI CC1101 with a 433 MHz front-end module), an intentional radiator operating around 410–450 MHz into an external SMA antenna. This radio is not covered by the Espressif module certificates above.

  • In the EU/EEA, the harmonised 433.05–434.79 MHz SRD band is available under short-range-device rules (EN 300 220 / ERC 70-03); Echo's default operating point of 433.92 MHz sits inside it.
  • In the United States, operation in the 433 MHz band under FCC Part 15 is restricted (for example the periodic-operation limits of §15.231); continuous or arbitrary transmission is not permitted.
  • Other regions allocate the sub-GHz spectrum differently. Frequency, duty cycle and power limits vary by country, and it is the operator's responsibility to use the radio only on frequencies and in modes permitted where the device is used.

Use Echo for authorized testing only, and keep transmission within the limits that apply in your jurisdiction.

6. USBLogger — direct SoC integration

The USBLogger does not use a pre-certified WROOM module. It integrates the ESP32-S3 SoC directly on the board, with a 2.4 GHz chip antenna, and uses Bluetooth LE only for the link to the mobile app (there is no radio in the wired keystroke path).

Because the radio is a bare SoC rather than a certified module, it does not inherit a modular grant. Where a finished-product radio certification is required for a target market, that certification is a finished-product responsibility. Contact us about regional availability before deploying the USBLogger where a specific national radio approval is mandatory.

7. Non-radio components & general compliance

The remaining certification-relevant parts are not radios, they are covered by general product compliance (electromagnetic compatibility as an unintentional radiator, and materials directives) rather than a radio grant:

  • USB 2.0 hub (Microchip USB2514B) on the AirLeak Pro / Mini, and the USB bridge (CH554) on the USBLogger.
  • Power path components, chargers and regulators (TI BQ25185, TPS63020, TPS2121; onsemi NCP167), and the WS2812B status LED.

These fall under EMC rules (for example FCC Part 15 Subpart B in the US and the EMC Directive in the EU) as part of the finished product, and under RoHS, REACH and WEEE for materials and end-of-life. ZeroTrace hardware is built lead-free / RoHS-compliant.

8. Compliance & legal

  • Pre-certified modules are certified and legally importable in the regions listed in the matrix; certificates are issued by Espressif and their authorised laboratories.
  • ZeroTrace firmware does not alter the radio parameters, antenna configuration, or transmit power of a module; the manufacturer's conformity assessment therefore continues to apply.
  • For the WROOM-1U and C5-WROOM-1U variants, attaching a non-certified external antenna can invalidate the manufacturer's conformity. Use only the antenna shipped with the module, or another of equivalent gain and pattern certified for the target region.
  • The Echo sub-GHz radio and the USBLogger's direct-SoC radio are not covered by a pre-certified module (sections 5 and 6); operate them only within the rules of your jurisdiction.
  • Responsibility for local compliance when modifying or further integrating the firmware or hardware lies with the buyer. If you are deploying into a region with a gap above, contact us first.