Understanding the Supplier’s Declaration of Conformity (SDoC) Procedure for the United States

Understanding the Supplier’s Declaration of Conformity (SDoC) Procedure for the United States

When bringing electronic devices to the U.S. market, ensuring compliance with Federal Communications Commission (FCC) regulations is crucial. One of the key FCC equipment authorization processes is the Supplier’s Declaration of Conformity (SDoC). This process allows manufacturers to self-declare that their products meet FCC standards without needing direct FCC approval, making it a popular choice for certain electronic devices.

Let’s explore what the SDoC procedure involves, the types of products it applies to, and how it benefits manufacturers.

What is the Supplier’s Declaration of Conformity (SDoC)?

The Supplier’s Declaration of Conformity (SDoC) is an FCC equipment authorization procedure that allows manufacturers, importers, or responsible parties to declare that their devices meet the relevant FCC technical standards. Unlike FCC certification, which involves third-party review, the SDoC is a self-declaration method, meaning the manufacturer ensures compliance without submitting documentation to the FCC.

This procedure is ideal for products that are considered unintentional radiators, meaning they emit radiofrequency (RF) energy as a byproduct of their primary function but are not designed to intentionally transmit radio signals.

Devices Eligible for SDoC

The SDoC process applies primarily to devices that fall under unintentional radiators as defined by Part 15 of the FCC rules. Common examples include:

• Computers and peripherals (e.g., printers, keyboards)
• Television receivers
• Microwave ovens
• LED light bulbs
• Industrial, Scientific, and Medical (ISM) equipment

In cases where a device has both intentional and unintentional radiators, such as a Wi-Fi-enabled device, the unintentional radiator portion (e.g., the digital circuitry) can be authorized under SDoC, while the intentional radiator (e.g., Wi-Fi transmitter) requires FCC certification.

Key Features of the SDoC Process

No Filing with the FCC:

One of the major benefits of the SDoC process is that manufacturers are not required to submit any application or test results to the FCC for approval. The responsible party simply ensures that the product complies with the relevant FCC standards and maintains the necessary documentation.

Testing Requirements:

While testing is required, it does not need to be conducted at an FCC-recognized accredited lab. Manufacturers or responsible parties can use any testing facility as long as it meets the technical standards. This provides flexibility, as accredited testing labs tend to be more costly. However, the responsible party must maintain a description of the test facility, and the test report must be made available to the FCC upon request​(GetAttachment.html (7)).

No FCC ID Required:

Products authorized under the SDoC process do not need to have an FCC ID. However, the product must include a compliance statement, either in the product manual or as a separate document, indicating that the device complies with Part 15 of the FCC Rules.

Responsible Party for Compliance:

The responsible party—whether the manufacturer, importer, or assembler—must be based in the United States and is responsible for ensuring the product’s compliance. If the FCC requests information, the responsible party must provide test reports, equipment samples, or other documentation.

Labeling and Documentation Requirements

Even though the SDoC does not require filing with the FCC, proper labeling and documentation are still necessary. The product must have a unique identifier (e.g., model number), and the responsible party must provide a compliance statement, typically included in the user manual or as a separate sheet.

The compliance statement should look something like this:

Additionally, the name, address, and contact information of the responsible party must be included in the compliance documentation.

Benefits of the SDoC Process

1. Simplified Market Entry:
   • Because there is no need for FCC certification or application review, products can be brought to market more quickly, helping manufacturers meet demand and capitalize on opportunities faster.
2. Cost Savings:
   • The SDoC process eliminates the need for formal certification, which reduces costs related to third-party testing and FCC filing fees. This makes the SDoC particularly beneficial for manufacturers of low-risk devices.
3. Flexible Testing Options:
   • Testing can be conducted at any laboratory, allowing manufacturers to choose more cost-effective testing solutions. The flexibility in testing requirements is another reason why SDoC is an attractive option.
4. No FCC ID:
   • Since there is no requirement for an FCC ID under the SDoC, manufacturers can simplify product labeling and packaging. Only a compliance statement is required, along with the responsible party’s contact information.

Responsibilities and Risks

Although the SDoC process is simplified, the responsible party must ensure that the product meets all relevant FCC standards. If the product fails to comply with regulations, the FCC can request documentation and test results. Non-compliance can lead to penalties, product recalls, and damage to the company’s reputation.

How IoT Consulting Partners Can Assist with the FCC SDoC Procedure

Navigating the FCC SDoC process can be challenging, but IoT Consulting Partners is here to help. We offer comprehensive support to ensure that your products meet all the necessary requirements for FCC compliance.

Here’s how we assist with the SDoC process:

1. Compliance Strategy and Assessment:
   • We help you determine whether your product qualifies for the SDoC procedure or if FCC certification is more appropriate. Our experts will guide you through the decision-making process based on your product’s technical specifications.
2. Testing Coordination:
   • We work with a network of trusted testing labs to ensure that your products meet the required FCC standards. Whether you choose an accredited lab or not, we oversee the testing process to guarantee accurate results.
3. Documentation Preparation:
   • Our team helps prepare all necessary compliance documentation, including test reports and compliance statements. We ensure everything is in order and ready should the FCC request additional information.
4. Labeling and Compliance Information:
   • We guide you on proper labeling practices and help draft the compliance statement required for your products. This ensures that your product is fully compliant when it reaches the U.S. market.
5. Ongoing Compliance Support:
   • Compliance doesn’t end once your product is on the market. We offer continuous support to ensure your products remain compliant as regulations evolve.

By partnering with IoT Consulting Partners, you can bring your IoT products to market with confidence, knowing that you’ve met all FCC requirements under the SDoC procedure.

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Frequently Asked Questions (FAQs)

Q1: What is the main difference between SDoC and FCC certification?
A: The Supplier’s Declaration of Conformity (SDoC) is a self-declaration process where the responsible party ensures compliance with FCC standards without submitting documentation to the FCC. In contrast, FCC certification involves third-party testing and approval through a Telecommunication Certification Body (TCB), with the device receiving an FCC ID and being listed in a public database.

Q2: Do I need to use an accredited lab for SDoC testing?
A: No, testing for the SDoC process does not require an accredited lab. You can use any testing facility as long as it complies with the FCC’s technical standards​.

Q3: Does the SDoC process apply to all devices?
A: No, SDoC primarily applies to unintentional radiators such as computers, peripherals, and digital devices. Devices that intentionally emit RF energy, like Wi-Fi routers, typically require FCC certification.

Q4: Do I need to label my product with an FCC ID for SDoC?
A: No, products authorized under SDoC do not require an FCC ID. However, they must include a compliance statement indicating adherence to Part 15 of the FCC rules.

Q5: How long do I need to keep compliance documentation?
A: The responsible party must maintain all relevant documentation, including test reports, for as long as the product is marketed, and be able to provide it to the FCC upon request.

Conclusion

The Supplier’s Declaration of Conformity (SDoC) is an efficient and cost-effective way to comply with FCC regulations for certain electronic devices. It offers flexibility in testing and eliminates the need for direct FCC approval, making it a great choice for manufacturers of lower-risk products.

For tailored support in navigating the SDoC process, contact IoT Consulting Partners today. We’ll help you ensure smooth market entry and ongoing compliance for your IoT devices in the U.S. market.

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