FCC 47 CFR Part 15 Supplier’s Declaration of Conformity (SDoC): A Practical Guide

If you import or manufacture some type of electronics into the United States, you need to ensure that you comply with the Supplier’s Declaration of Conformity (SDoC) requirements.

Specifically, the SDoC procedure covers most unintentional radiators, that is, products that do not feature Bluetooth, Wi-Fi, or other wireless functions.

In this guide, we address commonly asked questions regarding the SDoC procedure, the SDoC compliance information statement, and other related topics.

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

The “Supplier’s Declaration of Conformity”, a term mentioned in 47 CFR Part 15 – Radio Frequency Devices, is used to indicate:

a. The procedure that you must use to ensure that your unintentional radiators adhere to the relevant technical standards and other requirements, and

b. A compliance information statement that you must provide with your product

As part of the procedure, you should test your product to ensure compliance with technical requirements, maintain the required documentation, and prepare a compliance information statement.

The responsible party (e.g. manufacturer) should use the compliance information statement to specify that their product adheres to the applicable FCC rules.

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

The Supplier’s Declaration of Conformity (SDoC) is the authorization procedure that you should use to ensure that covered unintentional radiators meet the relevant technical standards and requirements under 47 CFR Part 15 for radio frequency devices.

According to the FCC, in order to complete the procedure, you should:

1. Get your products tested

2. Declare that each unit of equipment adheres to the applicable FCC requirements

3. Keep records (e.g. test reports) and required documentation proving compliance with the applicable FCC requirements

4. Prepare a compliance information statement

5. Label your product with:

• The FCC logo, only if said product fully adheres to the SDoC procedure
• The FCC Identifier, if the component is authorized under a grant of certification

Which products require an SDoC?

The SDoC procedure applies to unintentional radiators, which are devices that unintentionally emit radiofrequency energy within the product or via connective wiring, either by induction or radiation. These devices typically operate within the frequency range of 9 kHz to 3000 GHz.

Here are some examples of products that are unintentional radiators and thus require an SDoC:

• Coffee pots
• Wrist watches
• Cash registers
• Personal computers
• Printers
• Telephones
• Garage door receivers

However, per Table 1 in 47 CFR Part 15.101, you should only use the certification authorization procedure for the following types of unintentional radiators:

• Scanning receiver
• Radar detector
• Access broadband over power line (Access BPL)

According to 47 CFR Part 15.101, you can optionally choose the certification procedure for most devices subject to the SDoC procedure.

Note that we explain the difference between the SDoC and certification authorization procedures in one of the following sections of this guide. In short, the certification is a more stringent procedure that must be followed for authorized intentional radiators, that is, products that have wireless functionalities.

Which products are exempt from the SDoC requirement?

There are several types of products that are exempt from the SDoC requirements.

According to the FCC, products may be specifically exempted from the SDoC requirement under 47 CFR Part 15.103 if they contain only digital logic. Here are the exempted devices as listed under 47 CFR Part 15.103:

a. Devices used only in transportation (e.g. cars, aircraft)

b. Digital devices used as control or power systems used by public utilities or industrial plants

c. Digital devices used as industrial, commercial, or medical test equipment

d. Digital devices used as appliances (e.g. microwaves, dishwashers, dryers, air conditioners)

e. Specialized medical devices used under professional supervision

f. Digital devices with power consumption below 6 nanowatts

g. Passive add-on controllers (e.g. joysticks or mice with simple circuitry)

h. Devices operating below 1.705 MHz and not powered by AC lines

What are the requirements to comply with the SDoC procedure?

To ensure you comply with the SDoC procedure, you should adhere to several requirements, such as:

1. Compliance with rules and technical requirements, such as ensuring that:

• You manufacture your product according to good engineering design and manufacturing practices
• The user instructions for Access BPL equipment specify the installer- or user-control settings
• You stop operating devices covered by FCC Part 15 if they cause harmful interference

2. Compliance with standards such as:

• FCC/OET MP-2 – Measurement of UHF Noise Figures of TV Receivers
• ANSI C63.17-2013 – American National Standard Methods of Measurement of the Electromagnetic and Operational Compatibility of Unlicensed Personal Communications Services (UPCS) Devices
• ANSI C63.4-2014 – American National Standard for Methods of Measurement of Radio-Noise Emissions from Low-Voltage Electrical and Electronic Equipment in the Range of 9 kHz to 40 GHz

3. SDoC compliance statement, which should include the following information:

• Product identification (e.g. name and model number)
• Statement of compliance
• Your name, US address, and phone number, or internet contact information

4. Labeling

• You should label your devices covered by the SDoC procedure
• You can voluntarily use the FCC logo, but only on products that fully adhere to the SDoC procedure’s requirements
• You should use the FCC Identifier for certified products.

5. Product testing

• You are not required to use an FCC-recognized accredited test lab to perform the tests, but you may choose to do so
• Test reports – required to be provided to the FCC upon request

6. Supporting records (e.g. test reports, equipment samples) – you are not required to maintain these, but you need to provide them to the FCC upon request.

SDoC Compliance Statement Overview

Under the SDoC procedure, you should provide a compliance information statement with your product. Note, however, that there are two types of compliance information statements – a “basic” compliance information statement and a compliance information statement for products assembled from authorized modular components.

This section lists the information you need to provide for both types of compliance statements.

Compliance information statement (Basic)

Your “basic” compliance information statement for products subject to the SDoC procedure needs to contain:

a. Product identification – e.g. the product’s name and model number

b. A statement of the product’s compliance, and

c. The responsible party’s name, address, or internet contact information

Note that the responsible party should be located in the United States.

Compliance information statement (for modular components)

According to 47 CFR Part 2.1077, you need to provide a compliance information statement with your assembled product if it:

a. Comprises modular components authorized under SDoC and/or a grant of certification, and

b. Is subject to authorization under the SDoC procedure but does not need to undergo additional testing

In this case, your compliance information statement for modular components should contain:

a. The identification of the assembled product – e.g. name and model number

b. The identification of the modular components in the assembly

c. A statement of the assembled product’s compliance

d. The name, US address, and telephone number, or internet contact information of the party that assembled the product

e. Copies of the compliance information statements for each individual authorized component in the assembled product

Do I need to test my product before issuing an SDoC compliance statement?

Yes, the FCC requires you to test your product before issuing an SDoC compliance statement.

Note that while you do not need to use an FCC-recognized accredited lab to test your products, you can use one if you wish.

How much does it cost to obtain an SDoC compliance statement?

You can create the Supplier’s Declaration of Conformity, and the accompanying compliance statement for free. However, you need to pay for the mandatory product testing before you can create the SDoC compliance statement.

For example, Compliance Testing is an accredited test lab that claims its pricing depends on device type. Here is their cost breakdown for FCC testing and certification, as stated on their website:

a. USD 3,000 to USD 5,000 — basic electronic devices without transmitters

b. USD 6,500 to USD 10,000 — devices with FCC Pre-certified modules using approved components

c. USD 9,000 to USD 12,000 — unlicensed transmitting devices (e.g. Bluetooth, LTE, WiFi)

d. USD 12,000 to USD 15,000 — licensed devices with non-precertified modules

Do we need to keep the SDoC compliance statement updated?

We were not able to find specific information on the FCC website or the eCFR concerning whether you need to keep your SDoC compliance statement updated.

However, you need to ensure that your SDoC compliance information statement contains the correct information (e.g. product identification, responsible party identification). As such, if information about the product or the responsible party changes, you need to update your SDoC compliance statement to reflect these changes.

The FCC requires you to comply with the applicable technical requirements, test your product under the SDoC procedure, and provide records (e.g. test reports) upon request. As such, if anything about your product changes, you should, for instance, test your product to ensure continued compliance.

How long is an SDoC compliance statement valid?

We could not find any information concerning the validity period of an SDoC compliance statement.

However, as explained in the previous section, you still need to ensure that the information you provide in your SDoC compliance statement is accurate and up to date.

Can a non-US-based company issue an SDoC compliance statement?

We found that a non-US-based company cannot issue an SDoC compliance statement, as the FCC requires the responsible party (importer or manufacturer) to be located within the United States.

While we found that some websites claim that companies located outside the United States need to hire a US-based representative, we were not able to find any information in 47 CFR Part 15 or on the FCC website about this.

According to the FCC, under the SDoC procedure, the “importer of record” is considered the responsible party and needs to be based within the United States.

Can I obtain an SDoC compliance statement from a manufacturer outside the United States?

As mentioned in the previous section, you cannot obtain an SDoC compliance statement from a manufacturer outside the United States.

Responsible parties can include manufacturers, but they need to be based within the United States.

What is the difference between the SDoC and Certification authorization procedures?

While the SDoC authorization procedure applies to unintentional radiators, the Certification authorization procedure applies to intentional radiators.

According to the FCC, there are different requirements for products subject to the Certification authorization procedure.

If your equipment is approved under the Certification procedure, you need to get your product tested by an FCC-recognized accredited test lab. You then need to:

1. Obtain a 10-digit FCC registration number (FRN)

2. Obtain a Grantee Code from the FCC

3. File an application for a grant of certification with a Telecommunication Certification Body (TCB)

Does the SDoC also apply to the FCC Part 18?

Yes, according to 47 CFR Part 18, consumer industrial, scientific, and medical (ISM) equipment that emits electromagnetic radio frequencies is subject to either the Supplier’s Declaration of Conformity or certification procedures.

Note that in this regulation, the SDoC procedure applies to:

a. Non-consumer ISM equipment, and

b. Consumer ultrasonic equipment that:

• Generates less than 500 watts, and
• Operates below 90 kilohertz