Hello @MCU-User ,
If your design consists of a passive NFC tag and NFC Antenna only. And there no other "active" electronic that requires an external power supply. Then the device is classified as "Unintentional radiator". In this case, the device does need to to be certified against FCC/ETSI.
But if your device contains some MCU, Display etc... and it is externally supplied, you typically have to proceed with FCC/ETSI radiation tests.
Regarding the NFC Forum. The NFC Forum Certification is optional and only required if your design should be NFC Forum compliment ("Compatible" with others NFC Forum certified devices)
BR
Tomas