In 2025-2026, the FCC’s regulatory focus is shifting toward "supply chain security + dynamic compliance," and SDoC certification is no longer just about "gathering documents to pass." Combining the latest FCC regulatory developments (including the January 2026 draft) and practical cases, this article breaks down the "mandatory requirements" and "best practices" for documentation, clarifies the core rules for validity periods, and helps you build an error-free compliance evidence chain.

I. Misconceptions About FCC SDoC Compliance Certification:

1.Misconception 1: SDoC documentation is a "fixed list"—gather them and you’re done.Reality: It’s a "dynamic evidence chain" that must support supply chain traceability. Missing any traceability document can render the certification invalid.

2.Misconception 2: The longer you keep documents, the better—following FCC ID’s 5-year standard.Reality: SDoC explicitly requires documents to be retained for "at least 2 years after the product is discontinued." Keeping them longer is unnecessary, while keeping them shorter is non-compliant.

3.Misconception 3: The "Foreign Adversary Control Declaration" is already mandatory.Reality: This is part of FCC Docket 25-166, released in January 2026. It will only become mandatory after the vote on January 29—submission is not required at this time.

  II. 2026 FCC SDoC Certification Documentation:

The key to preparing documentation is "prioritizing correctly": Mandatory requirements are the bottom line—missing any will result in failure. Best practices are critical for passing random inspections and significantly reducing compliance risks.

1. Mandatory Requirements:

These are the required documents explicitly specified by the FCC. In 2026, verification will be stricter, with a focus on authenticity and consistency:

-Product Basic Information:

·Product Information Form: Includes full model number (must exactly match the physical nameplate, including case sensitivity and symbols), operating frequency, manufacturer information, and details of the U.S. Responsible Party (US Agent). The US Agent must provide a physical business address—Telecommunication Certification Bodies (TCBs) will conduct substantive verification to ensure legal documents can be received. Virtual addresses will be directly rejected.

·Series Product Difference Statement: For different models in the same series, list hardware differences (e.g., antenna type, core chip model) to avoid duplicate testing and reduce costs.

-Technical Documents:

·Circuit Schematic + PCB Layout: The schematic must mark key component parameters; the PCB layout must clearly show shielding design for RF sections. The FCC will verify compliance with electromagnetic compatibility (EMC) requirements.

·Bill of Materials (BOM): Specify the supplier name and model for each component. Critical components (e.g., chips, filters) must be checked against the FCC "Covered List" (Query Link: https://www.fcc.gov/supplychain/covered-list). Components on the list are strictly prohibited.

·English Product Manual: Must include the standard compliance statement (fixed format: "This device complies with Part 15 of the FCC Rules. Operation is subject to the condition that this device does not cause harmful interference.") and safety warnings (e.g., "Keep away from medical devices").

-Testing & Declaration:

·Compliance Test Report: Issued by a laboratory meeting ANSI C63.4 standards, including core EMC test data (e.g., conducted emissions, radiated emissions). The report must be accompanied by the laboratory’s "Non-Restricted Entity Statement" to confirm it is not on the FCC’s prohibited list.

·SDoC Compliance Declaration: Hand-signed by the manufacturer or U.S. Responsible Party (electronic signatures are no longer accepted), specifying the FCC part the product complies with (e.g., Part 15B), test laboratory name, and test date.

2. Product-Specific Mandatory Documents:

Additional documents are required based on product type—this is the most easily overlooked compliance point:

·Products with Certified Modules (with FCC ID): Provide a copy of the module’s FCC ID certificate + module manufacturer’s authorization letter. The authorization letter must clearly mark the adapted end-product model; vague statements like "applicable to all products" are not allowed.

·Non-Wireless Electronic Devices (e.g., power adapters, LED lights): Supplement with additional explanations for EMC testing, clarifying the correlation between product working principles and test methods.

3. Supply Chain Security Best Practices:

In 2026, the FCC’s random inspection focus will shift to supply chains. While these documents are not explicitly mandatory, their absence will directly increase compliance risks:

·Supplier Compliance Documents: Obtain "Non-Restricted Entity Statements" from core component suppliers and test laboratories to confirm they are not on the FCC’s supply chain blacklist. This is the core of building a supply chain evidence chain.

·Module Traceability Records: Include module purchase contracts, logistics documents, and production batch certificates to ensure module source traceability. One company was required by the FCC to recall products for failing to provide traceability records.

·Supply Chain Compliance Self-Assessment Form: Independently sort out key supplier qualifications and component compliance status, and retain self-assessment records for quick reference during FCC inspections.

  III. 2026 FCC SDoC Certification Validity Period:

SDoC certification has no fixed "expiration date," but compliance validity is subject to specific conditions. In 2026, cases of product detention due to invalidation have increased by 40% year-over-year:

·Basic Validity Premise: No "major modifications" to the product (e.g., replacing the antenna model, modifying PCB layout, substituting core chips) and no updates to relevant FCC regulations.

·Document Retention Requirement: All certification documents must be retained by the U.S. Responsible Party for at least 2 years after the product is discontinued, and must be readily available for FCC inspection and retrieval.

·Supply Chain Compliance Requirement: Core suppliers are not on the FCC "Covered List." If a supplier is added to the list, SDoC compliance will be invalidated even if the product remains unchanged.

The essence of FCC SDoC certification has evolved from a "product qualification certificate" to a "dynamic evidence chain for dual compliance of products + supply chains." The key to compliance in 2026 is: first, distinguishing between "mandatory requirements" and "best practices" to avoid unnecessary work and non-compliance; second, adhering to the core rules for validity periods to prevent compliance invalidation due to minor oversights. For professional certification consulting services, contact BLUEASIA: +86 13534225140.