[nullc]

> if I throw an ESP32 into a product and use wifi, I don’t need further certification

Sounds like nonsense to me, at least from past reading of the regulation. These devices are supposed to be type-accepted-- your entire product is supposed to be certified.

Is the FCC really allowing this? (not that I'm complaining, the FCC certification burden is outrageous).

[milesvp]

Sorry, I was using imprecise (and possibly incorrect language). There are intentional radiators, and unintentional radiators. Using a given chip/SOC/module can greatly reduce the burden of dealing with the FCC for the purposes of intentional radiators. It's why you see products using Espressif's WROVER module have markings similar to

Contains FCC ID: 2AC7Z-ESP32WROVERE.