The Federal Communications Commission opened a single self-approval route for eligible radiofrequency equipment on November 2, 2017, replacing verification and Declaration of Conformity with Supplier’s Declaration of Conformity, or SDoC. For US importers, the change offers more choice over testing laboratories but keeps a domestic business responsible for compliance. Eligible products can still use the old procedures until November 2, 2018. [S1][S2]

SDoC permits testing by laboratories that are not accredited; the earlier Declaration of Conformity procedure required accreditation, while verification did not. The FCC’s order says imposing accreditation across the combined procedure would add a substantial burden for manufacturers previously using verification. That is the agency’s rationale, not evidence of a particular importer’s savings. The new route covers equipment previously subject to those two self-approval procedures, not a blanket replacement for certification. [S1][S2]

Under the amended section 2.909, the party responsible for SDoC equipment must be located in the United States. For imported equipment or imported assembled systems subject to SDoC, that party is the importer. A retailer or original equipment manufacturer can agree with the designated responsible party to take over the compliance responsibilities. An importer needs to separate who performs a test from who remains accountable: purchasing a laboratory service does not by itself transfer that responsibility. [S2]

The paperwork travels with the product. Section 2.1077 requires a compliance information statement at marketing or importation identifying the product, giving the applicable compliance statement, and naming the responsible party with its address and telephone number or Internet contact information. The information can appear in the user manual or on a separate sheet. An electronic-only manual can carry it where the user can reasonably be expected to access that format. The FCC also makes its logo optional under SDoC; displaying the logo does not replace the required information or testing records. [S2]

The transition distinguishes new authorizations from already-authorized equipment. Section 2.950 allows eligible devices to continue through the old procedures until November 2, 2018. Devices authorized under verification or Declaration of Conformity before November 2, 2017 must continue to meet the old procedure’s requirements; changes to those devices after November 2, 2018 bring SDoC requirements into play. For an importer’s product list, the dividing line is the authorization history and whether a device is changed, not simply whether it remains on sale. [S2]

Source documents

  1. FCC 17-93 First Report and Orderhttps://docs.fcc.gov/public/attachments/FCC-17-93A1.txt
  2. Federal Register: Authorization of Radiofrequency Equipmenthttps://www.govinfo.gov/content/pkg/FR-2017-11-02/html/2017-23217.htm