Federal Communications Commission
Office of Engineering and Technology
SUPPLIER’S DECLARATION OF CONFORMITY GUIDANCE
Supplier’s Declaration of Conformity (SDoC) is an FCC equipment authorization procedure that requires the party responsible for compliance to ensure that the equipment complies with the appropriate technical standards.1 The responsible party is not required to file an equipment authorization application with the Commission or a TCB; therefore, equipment approved under the SDoC procedure is not listed in any Commission database. However, the responsible party must provide a test report and other information demonstrating compliance with the rules upon request by the Commission.2 For any equipment subject to the SDoC procedure,3 the certification equipment authorization procedure may be used in place of the SDoC procedure at the option of the responsible party.4
The key FCC rule sections for SDoC are:
- Section 2.906 Supplier’s Declaration of Conformity
- Section 2.909 Responsible party
- Section 2.931 Responsibilities
- Section 2.938 Retention of records
- Section 2.1072 Limitations on Supplier’s Declaration of Conformity
- Section 2.1074 Identification
- Section 2.1077 Compliance Information
2. EQUIPMENT SUBJECT TO SUPPLIER’S DECLARATION OF CONFORMITY
Equipment that does not contain a radio transmitter and contains only digital circuitry – such as computer peripherals, microwave ovens, ISM equipment, switching power supplies, LED light bulbs, radio
1 The Commission has two equipment authorization procedures: (1) Supplier’s Declaration of Conformity (SDoC); and (2) certification. Certification is an equipment authorization, using a third-party FCC-recognized Telecommunication Certification Body (TCB), based on an evaluation of supporting documentation and test data contained in an application submitted by the responsible party (e.g., the manufacturer or importer) to the TCB. Compliance testing for certification is performed by an FCC-recognized accredited testing laboratory. Technical parameters and descriptive information for all certified equipment is posted on a Commission-maintained public database (https://www.fcc.gov/oet/ea/fccid). See 47 CFR §§ 2.907 et seq.
2 See 47 CFR § 2.938(b) Retention of records.
3 See 47 CFR §§ 15.101 and 18.203.
4 See 47 CFR § 2.906(c). Any device subject to SDoC may instead be approved by certification (which is a more rigorous equipment authorization procedure than SDoC) at the option of the responsible party.
receivers, and TV interface devices – is subject to approval using the SDoC procedure with an option to use the certification procedures.5
For equipment that contains both unintentional radiators (e.g., digital logic circuitry)6 within an end product and intentional radiators, the unintentional radiator portion can be generally authorized under either SDoC or certification while the intentional radiators (e.g., radio transmitters) contained in the equipment is typically required to be certified.7
Where a responsible party optionally chooses to certify the equipment subject to SDoC, as allowed by Section 2.906(c), Appendix B provides further information for the use of equipment class codes with applications for certification.
3. RESPONSIBLE PARTY FOR SDOC
The responsible party is typically one of the following: the manufacturer, the assembler (if the equipment is assembled from individual component parts), or the importer (if the equipment is imported).8 This party is responsible for the compliance of the equipment with the applicable standards and must maintain a United States presence. A retailer or original equipment manufacturer (OEM) located in the United States may enter into an agreement with the responsible party (manufacturer, assembler, or importer) to assume the liabilities of guaranteeing compliance of the equipment and become the new responsible party for the purposes of the Commission’s rules.9 In all cases, the compliance information provided with the equipment must identify the responsible party by name, United States-based address, and telephone number or internet contact information.
Although supporting records are not required to be maintained within the United States, the responsible party, located within the United States, is required to be able to provide any compliance information, such as test reports and equipment samples at no cost to the FCC, when requested by the Commission.
In determining compliance for devices subject to SDoC, the responsible party warrants that each unit of equipment marketed under an SDoC will be identical to the unit tested and found acceptable with the standards, and that the records maintained by the responsible party continue to reflect the equipment being produced under the SDoC within the variation that can be expected due to quantity production and testing on a statistical basis.10
4. TESTING LABORATORY
For equipment authorized using the SDoC procedure, it is not necessary to perform the testing at an FCC-recognized accredited testing laboratory (although the responsible party may use an accredited testing
5 See 47 CFR §§ 15.101 and 18.203.
6 See 47 CFR §§ 15.3(z) and 15.101.
7 See 47 CFR §§ 15.3(o), 15.101, 15.201. Some unintentional radiators do require certification, such as Scanning Receivers, Radar Detectors, and Access Broadband over Power Line (Access BPL) equipment.
8 See 47 CFR §§ 2.1203 and 2.1204. Section 2.1203 requires that no radio frequency device may be imported into the United States unless the importer or ultimate consignee, or their designated broker, determines that the device meets one or more of the conditions for entry set out in Section 2.1204.
9 See 47 CFR § 2.909.
10 See 47 CFR § 2.931.
laboratory if it wishes to do so). The testing laboratory that is used must maintain a description of the test facility, as required by Section 2.948(b). The description of the test facility does not need to be submitted to the FCC, unless requested.
Test reports must be signed by a representative of the responsible party with the authority to act on behalf of the responsible party. It is not necessary for the representative that signs the test report to be located in the United States.
Devices subject to SDoC are required to be uniquely identified by the responsible party prior to importing the equipment to or marketing it in the United States. The label shall not be of a format which could be confused with the FCC Identifier required on certified equipment.11 The responsible party is required to maintain adequate identification records to facilitate positive identification for each device.12 See KDB Publication 784748 for labeling guidance.
Devices subject to authorization under SDoC can be labeled with the following FCC logo on a voluntary basis. However, use of the FCC logo is limited to products that fully comply with the SDoC procedures.
6. COMPLIANCE INFORMATION
6.1 Basic compliance information statement
For products using SDoC, in addition to the labeling described in Clause 5, a compliance information statement shall be supplied with the product at the time of marketing or importation, containing the following information:13
a)Identification of the product, e.g., name and model number;
b) A statement that the product complies with the rules;14 and
c) The identification, by name, address, and telephone number, or internet contact information, of the responsible party as defined in Section 2.909. The responsible party must be located within the United States.
For illustration purposes, Appendix A shows an example compliance information statement.
11 The FCC Identifier (FCC ID) requirements for certified equipment are given in Sections 2.925 and 2.926.
12 See 47 CFR § 2.1074(a).
13 See 47 CFR § 2.1077(a).
14 For devices subject to Part 15 rules, the statement specified in Section 15.19(a)(3) and for devices subject to Part 18, the statement specified in Section 18.212 will satisfy this rule requirement.
6.2 Compliance information statement for end products assembled from separately authorized components
The following applies to end products:15 (1) assembled from components (e.g., enclosures, power supplies, and CPU boards) that, by themselves, are authorized under SDoC or a grant of certification or both; and (2) where the assembled product is also subject to authorization under SDoC but, in accordance with the applicable regulations, does not require additional testing. Such products shall be supplied, at the time of importation or marketing, with a compliance information statement containing the following information.16
a) Identification of the assembled product, e.g., name and model number.
b) Identification of the authorized components used in the assembly. A component authorized under SDoC shall be identified as specified in Section 2.1077(a)(1).17 A component authorized under a grant of certification shall be identified by name and model number (if applicable) along with the FCC Identifier number, as specified in Sections 2.925 and 15.212.18
c) A statement that the product complies with the rules.19
d) The identification, by name, address, and telephone number, or internet contact information, of the responsible party who assembled the product from modular components, as defined in Section 2.909. The responsible party for an SDoC must be located within the United States.
e) Copies of the compliance information statements for each authorized component used in the system that is authorized under SDoC.
6.3 Placement of Compliance Information Statement
The compliance information statement shall be included in the user’s manual or as a separate sheet. In cases where the manual is provided only in a form other than paper, such as on a computer disk or over the Internet, the information required may be included in the manual in that alternative form, provided the user can reasonably be expected to have the capability to access information in that form. The information may be provided electronically as permitted in Section 2.935.20
07/02/2018: 896810 D01 SDoC v01r01 replaces 896810 D01 SDoC v01. APPENDIX A was changed for clarification of responsible party for compliance to Section 2.1077 compliance information.
15 See 47 CFR § 2.1(c). End Product. A completed electronic device that has received all requisite FCC approvals and is suitable for marketing.
16 See 47 CFR § 2.1077(b).
17 See 47 CFR § 2.1077(a)(1).
18 See 47 CFR §§ 2.925 and 15.212.
19 See note 16, supra.
20 See 47 CFR §§ 2.1077 and 2.935.
EXAMPLE OF SUPPLIER’S DECLARATION OF CONFORMITY COMPLIANCE INFORMATION STATEMENT WITH AN END PRODUCT AT THE TIME OF MARKETING OR IMPORTATION21
NOTE: The Commission does not have a required SDoC format. This is an example only and is provided to illustrate the type of information that may be supplied with the product at the time of marketing or importation for meeting the FCC SDoC requirement Section 2.1077 compliance information.
Supplier’s Declaration of Conformity
47 CFR § 2.1077 Compliance Information
Unique Identifier: (e.g., Trade Name, Model Number)
Responsible Party – U.S. Contact Information
Telephone number or internet contact information
FCC Compliance Statement (e.g., products subject to Part 15)
This device complies with Part 15 of the FCC Rules. Operation is subject to the following two conditions: (1) This device may not cause harmful interference, and (2) this device must accept any interference received, including interference that may cause undesired operation.
The following repeats the information from Table 1 of Section 15.101(a), and with an added column for appropriate equipment authorization system (EAS) equipment class for use for certification applications filings per Section 2.911. Note: the use of an equipment class is only required when the device is certified and not when using SDoC.