I came across an article from Cooley Go that I wish I had seen sooner. It should be required reading for anyone thinking about making an electronic device, even though the article is specific to the US market.
Devices subject to the FCC’s rules cannot be marketed until they have completed testing and, if necessary, have been approved by the FCC. Marketing includes selling or leasing a device, advertising that a device is available for sale or lease, and importing a device for purpose of selling or leasing it.