> "Anything that contain a semiconductor..."

I think that you'll find the real reg is anything with a clock over 9kHz,
with an exception for digital watches.

> Actually, I think, by the law, it is illegal to do pre-testing, as the
device is not yet certified!

Hardly. You just can't sell the device. You're still responsible for it's
emissions.

You can also self-certify, but if the FCC finds your products in violation,
you better have really good paperwork. That's why the independent labs make
their money.