Question 1: My product has previously been placed on the market under the Declaration of Conformity
(DoC) or verification rules; is it also required for the product to comply with the new Supplier’s
Declaration of Conformity (SDoC) requirements?
Answer 1: No, products that were subject to either the DoC or verification equipment authorization
procedures in the past are not required to be changed and updated under the new SDoC requirements, as
long as the devices remain unmodified (see also Question 2).
Question 2: When is it required to use the new SDoC procedures?
Answer 2: A transition period is provided in the rules allowing use of the former DoC or verification
procedures, whichever was previously applicable for a device, until November 2, 2018.
Equipment approved prior to November 2, 2018 using the former DoC or verification procedures is
grandfathered; it is not necessary to re-test or apply the SDoC procedure.
If any changes are made to equipment previously approved using either DoC or verification after
November 2, 2018, then the procedures for SDoC apply for the modified equipment.
Question 3: For SDoC, is it necessary to have my product tested at an FCC-recognized accredited testing
Answer 3: No, with the new SDoC procedure it is not necessary to have testing performed at an
accredited testing laboratory. The use of an FCC-recognized accredited testing laboratory is required
when using the DoC procedure but is not required when using the SDoC procedure.
Question 4: What are options to meet the requirement for the responsible party to be located in the
Answer 4: 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
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.
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.
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