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

Importer and manufacturers of certain types of electronic products in the United States must issue a Supplier’s Declaration of Conformity (SDoC). The SDoC is a self-issued declaration, supported by lab test reports.

In this guide, we explain for which products the SDoC is mandatory, how to create the document, required information, and more.

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

In order to comply with the FCC Part 15 requirements, radiofrequency devices must be authorized before being placed into the US market. For most unintentional radiators (devices that don’t emit radiofrequency energy by radiation or induction) this process requires manufacturers and importers to test their product and self-issue a Supplier’s Declaration of Conformity (SDoC).

The responsible person that signs the SDoC on behalf of the company must declare that the product is compliant with the specific requirements of FCC Part 15, including technical specifications, documentation, and labeling.

Also, the SDoC is often required as the primary compliance document by the authorities, distributors, retailers, and Amazon as well.

Which products require an SDoC?

FCC Part 15 regulates electronic and electrical devices that operate in the radio frequency range of 9kHz to 3,000 GHz, and mainly classifies the devices into three categories:

• Unintentional Radiators
• Intentional Radiators
• Incidental Radiators

The SDoC is applicable to most unintentional radiators, which include non-radio enabled devices (e.g. non-WiFi or Bluetooth). Here are a few examples:

• LED lighting
• Power banks
• Coffee machines
• Personal computers
• Mouses and keyboards
• Fans

Note that FCC Part 15 does not regulate all unintentional radiators. For example, the following products are excluded by the scope:

• Home-built devices (For personal use)
• Digital devices for transportation vehicle
• Digital devices for industrial, commercial, or medical test
• Digital devices used in Power line carrier systems

What information should be included in an SDoC?

In this section, we provide an overview of the main information that manufacturers and importers shall include in their SDoC.

Product identification

Manufacturers and importers shall specify their device SKU, model number, batch ID, or serial number. Note that, although there is no specific format, it’s important that each device is uniquely identified, and that the information matches the one in the test report, user manual, technical documentation, and labeling.

You may also include a product image on the SDoC if you deem it necessary.

Responsible party’s information

Typically, the responsible party might be the manufacture, the assembler, the importer, or a US representative.

The responsible party’s information shall include the following information:

• Company name
• Company address
• Phone number or email
• Name and signature of the responsible person

Note that the responsible party must be located in the United States, and non-US based companies shall hire a US representative, as we explaining in one of the following sections of this guide.

Compliance statement

Manufacturers and importers are responsible for product compliance and shall include a compliance statement in the SDoC, such as the following:

“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.”

Supporting documents

Manufacturers and importers shall also include supporting documents such as test reports, or other relevant documents that support the compliance statement.

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

Yes, the SDoC authorization procedure requires the products to be tested, in order to show compliance with appropriate technical standards.

Note that manufacturers and importers are not required to hire an FCC-recognized accredited testing laboratory, in order to carry out the tests. However, they shall still ensure that the laboratory of their choice is qualified for conducting tests according to FCC Part 15 requirements.

Thus, it might still be a good idea to appoint an accredited lab testing company.

How much does it cost to obtain an SDoC?

The SDoC is a self-issued document so there is no direct cost involved unless you decide to hire a consultant that drafts it on behalf of your company. However, as mentioned above, lab testing is required.

Therefore the cost mostly depends on the cost of the required tests for your devices, which might range from US$700 for relatively simple devices, to several thousands of dollars or more, depending on the complexity of the product.

SDoC Creation

Some testing companies also provide SDoC creation services. In general, it might cost US$500-700 to create one. Here are some examples of testing companies that offer this service:

• QIMA
• SGS
• Violette Engineering
• Intertek
• CSA Group

Can a non-US based company issue an SDoC?

No, the SDoC’s responsible party must be located in the United States. If your company is not based in the US, then you shall appoint a telecommunication certification body (TCB), or another US representative, to act as a responsible party on behalf of your company.

Here are some companies that offer this service:

• Intertek
• TÜV SÜD
• Eurofins

Can I get an SDoC from a manufacturer outside the United States?

Since the SDoC’s responsible party must be located in the United States, if an importer receives an SDoC from a manufacturer outside the United States, the responsible party in the SDoC shall be the TCB or other US representative appointed by the manufacturer.

In this case, we advise to also contact the representative in the US to confirm that they are effectively representing the overseas manufacturer, verify that the SDoC was drafted for the product that is being imported and that the test reports are valid.

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

The certification is a more strict authorization procedure that requires the tests to be carried out by an FCC accredited lab testing company and the certificate to be drafted by a Telecommunication Certification Body (TCB). That is, it can’t be self-issued as the SDoC.

For most unintentional radiators, manufacturers or importers can choose either the SDoC or certification authorization procedures. However, some types of unintentional radiators can only be authorized via the certification procedure, including:

• Scanning receivers
• Radar detectors
• Access broadband over power line

Meanwhile, intentional radiators, that is devices that emit radiofrequency energy by radiation or induction, are always required to go through the certification procedure. Here are some examples of intentional radiators:

• Wireless headphones
• Bluetooth speakers
• Wireless chargers
• Smartphones

As said, unlike the SDoC procedure, manufacturers and importers shall appoint an FCC-recognized telecommunication certification body (TCB) to carry out the certification procedure. TCBs are responsible for evaluating the compliance of radio devices, review the documentation such as technical files, test reports, and user manuals, and issuing the certificate.

Note, that, if your product contains both intentional and unintentional radiator components, you do not need to certify the whole product.

Let’s take a laptop as an example. It will typically contain some intentional radiators (the Bluetooth and wireless transmitters, for example), while the rest of the components (i.e. monitor, circuits, the cables), are unintentional radiators.

Importers are required to go through the certification procedure only for the transmitters – or choose to purchase transmitters that are already certified, – while the rest of the components can be authorized via the SDoC procedure.

Does the SDoC also apply to the FCC Part 18?

The SDoC is also required for some unintentional ISM (Industrial, Scientific, and Medical) equipment covered by FCC Part 18. FCC Part 18 contains the procedures and requirements for authorization if you are planning to import or sell such products in the United States.

Similar to the FCC part 15, covered products must either go through the SDoC or the certification procedure before being placed in the market.