Documents and Validity Period for FCC SDoC Certification of Non-Wireless Electronic Products (2025 Update)

2025-10-17

1️⃣ Introduction: Why FCC SDoC Documentation Matters

For electronic products without wireless transmission functions, the FCC SDoC (Supplier’s Declaration of Conformity) is a mandatory compliance requirement to legally access the U.S. market.

Proper preparation of technical and administrative documents is the foundation of a successful certification. As of October 2025, new rules on laboratory qualification and document traceability have made this step more critical than ever.



2️⃣ List of Documents Required for FCC SDoC Certification

Document CategoryCore Content & Description
Product Technical DocumentsCircuit Schematics & Block Diagrams — Clearly show signal paths and functional modules.
Product Manual — Must include the FCC compliance statement and warning such as “This device complies with Part 15 of the FCC Rules.”
List of Critical Components — Identify key parts affecting EMC performance.
Testing-Related DocumentsComplete EMC Test Report — Issued by a qualified and FCC-recognized laboratory, covering all required test items (Conducted Emission, Radiated Emission, etc.).
Laboratory Qualification Proof — Provide valid ISO/IEC 17025 accreditation certificate or FCC recognition document.
Compliance Declaration DocumentsSigned SDoC Declaration Document — Must be signed by the U.S. Responsible Party (manufacturer, importer, or authorized representative).
Include product model, FCC statement, and complete contact details of the Responsible Party within the U.S.
Product Identification DocumentsExterior & Interior Photos — Show the device’s construction and label placement.
Label Diagram — FCC logo is no longer mandatory, but the manual or label should include the compliance statement.

 

3️⃣ Understanding the FCC SDoC Certification “Validity Period”

Unlike traditional certifications, FCC SDoC certification has no fixed expiry date — but its validity is conditional. It can become invalid if certain changes or violations occur.

 When Certification Becomes Invalid

  1. Product Design Changes
    Major hardware or circuit modifications affecting EMC performance require re-testing and re-declaration.

  2. FCC Standard Updates
    The manufacturer must ensure the product continuously meets the latest FCC rules. When standards change, previous test reports may no longer be accepted.

  3. Failure During Market Surveillance
    The FCC conducts random spot checks. If a product is non-compliant or a false declaration is found, the SDoC is revoked, and the company may face fines or market bans.

Document Retention Requirement

All technical and declaration documents must be retained for at least 10 years after production of the product ceases.
These records must be available to the FCC upon request for inspection or investigation.

Tip: Maintain digital backups and version control of schematics and reports to demonstrate traceability during audits.



4️⃣ Summary of the FCC SDoC Certification Process

  1. Confirm Applicability — Ensure the product has no wireless functions (Bluetooth, Wi-Fi, RF).

  2. Select a Qualified Laboratory — Use an FCC-recognized lab that complies with the 2025 security rule (prohibiting “covered entities” from participation).

  3. Perform EMC Testing — Conducted Emission, Radiated Emission, and Harmonic Current tests as required.

  4. Sign the Supplier’s Declaration of Conformity (SDoC) — The U.S. Responsible Party signs and retains it.

  5. Archive All Documents — Maintain a complete technical file for 10 years.

Remember: Using a non-qualified lab or failing to retain records may invalidate your certification and block market entry.



5️⃣ Key Takeaways for Manufacturers in 2025

No Fixed Expiration: FCC SDoC remains valid as long as the product and standards remain unchanged.
Laboratory Verification Is Mandatory: Only FCC-approved, security-cleared labs are accepted.
10-Year Record Retention: Required for legal compliance and audit readiness.
Product Labeling Flexibility: The FCC logo is optional, but textual compliance statements are recommended.



 Blue Asia Technology — Your Trusted FCC Compliance Partner

At Blue Asia Technology (Shenzhen), we specialize in helping manufacturers achieve fast, accurate, and fully compliant FCC SDoC certification.

Our services include:

  • Full-scope EMC testing (FCC Part 15 & Part 18)

  • U.S. Responsible Party representation

  • Documentation and SDoC file preparation

  • Compliance consulting under the 2025 FCC Security Rule

king.guo@cblueasia.com
+86 135 3422 5140


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