By 2026, FCC compliance regulations have entered a phase of "in-depth enforcement". Mere technical testing compliance is no longer sufficient to gain access to the US market.
From the implementation of the 2025 Supply Chain Security Ban to the release of the Foreign Adversary Control Declaration Draft in January 2026, the core logic of FCC SDoC certification has been completely restructured. Combining the latest FCC announcements, practical cases, and compliance pain points, this article breaks down the dual core, new regulatory details, and implementation plans of 2026 SDoC certification, helping enterprises avoid policy traps and build a compliance system that can withstand audits.
FCC SDoC (Supplier’s Declaration of Conformity) essentially requires enterprises to self-guarantee product compliance. However, "compliance" in 2026 has been given a dual meaning:
1.Technical Compliance as the Foundation: The Unchanging Market Access BaselineThe scope of SDoC application has never expanded, which is the prerequisite for all compliance work. It covers only two device categories: unintentional radiators (products without active wireless transmission functions, such as power adapters, LED lighting, and computer peripherals) and specific receiving devices (devices with only signal reception capabilities, such as FM radios and TV receivers). All products with intentional wireless transmission functions, such as Bluetooth, Wi-Fi, and 5G-enabled devices, must apply for FCC ID certification, and using the SDoC pathway for these devices will be deemed a direct violation of regulations. The core technical testing requirement is compliance with relevant standards in FCC 47 CFR Part 15, with a focus on completing Electromagnetic Compatibility (EMC) testing to ensure that product electromagnetic radiation does not interfere with other devices.
2.Supply Chain Security as the Core: A New Mandatory ThresholdThe Supply Chain Security Ban, which took effect in September 2025, saw further rule refinement in 2026. The core regulatory logic is that entities on the "Covered List" (and their affiliates) are prohibited from participating in the entire SDoC process, including testing laboratories, component suppliers, and module manufacturers. The January 2026 draft further clarifies that equipment authorization has been included in Schedule A of the Foreign Adversary Control Declaration, requiring enterprises to declare that products are not controlled by foreign adversaries. A 10% or higher ownership stake constitutes "control", while a 5% or higher stake requires reporting of relevant information. The consequences of non-compliance are severe: even if a product passes technical testing, if the supply chain involves restricted entities or the required declaration is not submitted, the SDoC declaration will be deemed invalid immediately, and the product will face detention, recall, or even fines.
II. 2026 FCC SDoC Compliance Certification New Regulations
The FCC released a series of policy updates in early 2026, with three core changes becoming mandatory requirements for enterprise compliance:
1.Foreign Adversary Control Declaration: Reporting Must Be Completed Within 60 DaysOn January 8, 2026, the FCC released GN Docket Report and Order Draft No. 25-166, planning to add a new Subpart GG to Part 1 of the FCC rules. It clearly requires that all SDoC Responsible Parties (US-based enterprises) must submit a Foreign Adversary Control Declaration within 60 days after the FCC issues a reporting notice, and small entities may be granted a 120-day grace period. The declaration must clearly state whether the product is controlled by a foreign adversary, including direct or indirect ownership stakes and actual control relationships, and false declarations will result in criminal liability. The draft will be voted on by FCC management on January 29 and will be formally incorporated into regulations upon approval, becoming a mandatory document for SDoC compliance.
2.Module Regulation Implementation: From Draft to Practical OperationThe module regulation draft proposed in October 2025 has clear implementation guidelines in 2026. The scope of regulation covers core modules (RF modules, power modules, key chips, etc.), which are included in the supervision of "covered equipment". Using modules produced by restricted entities will result in a ban on SDoC declarations, even for devices without wireless functions. Enterprises are responsible for obtaining a compliance commitment letter from module suppliers, confirming that modules do not involve restricted entities, and retaining module traceability records (production batches, supply chain flow, etc.). The only exemption exceptions are applicable to certain foreign-manufactured drones and key components, with the exemption period valid until the end of 2026, but Chinese enterprises are not included in the exemption list for the time being.
3.Enhanced Supervision of US Agents: Virtual Addresses Are Completely InvalidAfter the FCC updated its Guidelines for Covered Equipment, the US Agent (a legal document service agent located within the US) has become a key node in compliance. The mandatory requirement is that US Agents must have a real physical office address within the US, and virtual addresses and PO boxes are no longer accepted. The verification mechanism stipulates that Telecommunication Certification Bodies (TCBs) will conduct substantive verification of US Agent information, and false information will directly invalidate the SDoC declaration. For information retention, the US Agent’s name, address, and contact information must be entered into the FCC official database and must be consistent with the information on product labels and user manuals to facilitate subsequent audits.
III. 2026 FCC SDoC Compliance Certification Practical Implementation
Combined with the latest regulations, the following process has been verified through practical implementation by multiple enterprises and can be directly adopted:
1.Preliminary Determination: 3 Steps to Lock in the Compliance PathwayFirst, screen product functions to confirm the absence of intentional wireless transmission functions, avoiding the incorrect selection of the SDoC pathway. Second, compile a list of core components, with key marking of modules, chips, and other critical parts, and conduct an initial screening to check if suppliers are on the "Covered List". Third, determine applicable test standards by referring to FCC 47 CFR Part 15 (e.g., Part 15B for unintentional radiators), clarifying test items and compliance limits.
2.Supply Chain Verification: In-Depth Due DiligenceFirst, screen suppliers by checking the FCC official website "Covered List" to establish a supplier whitelist, and require core suppliers to provide a "Non-Restricted Entity" declaration. Second, conduct full-process traceability for key modules, retain procurement contracts, batch certificates, and supplier qualification documents to ensure source traceability. Third, update the "Covered List" query results quarterly, conduct secondary verification of existing suppliers, and promptly remove high-risk entities.
3.Laboratory Selection: Dual Qualification VerificationFirst, verify technical qualifications by confirming that the laboratory meets the ANSI C63.4 standard, has EMC testing capabilities, and can provide qualification certification documents. Second, obtain a compliance declaration by requiring the laboratory to issue a "Non-Restricted Entity" declaration, confirming that it is not on the "Covered List" and has no equity affiliation with restricted entities. Third, prioritize international laboratories with high report recognition and the ability to quickly adapt to new FCC regulatory requirements.
4.Evidence Chain Construction: Adding 2 New Categories of Key DocumentsA complete 2026 SDoC evidence chain requires "basic documents + new regulation documents", all in English PDF format. Basic documents include product technical specifications, circuit schematics, EMC test reports, and SDoC declaration signed and sealed by a legal representative. New regulation documents include Foreign Adversary Control Declaration, module supplier compliance commitment letter, component traceability records, and US Agent qualification certificates (e.g., physical address lease contract). For retention requirements, all documents should be stored unifiedly by the US Responsible Party using dual methods ("cloud backup + local hard drive"), and must be retained for at least 2 years after device discontinuation to ensure availability within 48 hours during FCC spot checks.
5.Declaration & Customs Clearance: Prepare a Complete Set of MaterialsFirst, complete the submission of the Foreign Adversary Control Declaration in accordance with FCC requirements and retain the submission receipt. Second, prepare customs clearance materials including a copy of the SDoC declaration, test report summary, laboratory compliance declaration, module traceability records, and US Agent information. Third, for e-commerce listing, platforms such as Amazon and TEMU require additional submission of the Foreign Adversary Control Declaration receipt, and product detail pages must display "SDoC Compliant" and the US Agent’s contact information; otherwise, listing will be rejected.
IV. 2026 FCC SDoC Compliance Certification Pitfall Avoidance
One high-risk pitfall is neglecting the submission of the Foreign Adversary Control Declaration. To avoid this, enterprises should establish a new regulation tracking mechanism, pay close attention to the official notice after the draft vote on January 29, complete declaration submission within 60 days, and retain the submission certificate. Another high-risk issue is the failure of module suppliers to provide compliance commitment letters. The solution is to incorporate the "Non-Restricted Entity Declaration" into supplier cooperation agreements and exclude any suppliers without such letters from the procurement system.
Using a virtual address for the US Agent is also a critical mistake. Enterprises should select a US-based Agent with a physical office space, request to provide the address lease contract and office photos, and confirm information validity with the TCB in advance. Missing traceability records in the evidence chain can lead to compliance risks as well; enterprises should establish a component traceability ledger, recording procurement date, batch number, supplier, inspection results, etc., to form a closed loop with other documents.
Enterprises also need to watch out for laboratories that fail to update compliance declarations. The fix is to require laboratories to update their "Non-Restricted Entity" declarations every six months and cross-verify through the FCC official website to avoid situations where the laboratory is later added to the "Covered List". Finally, confusing the scope of application between SDoC and FCC ID can cause significant delays. Enterprises should clarify product function boundaries in the early R&D stage, and if wireless transmission functions are involved, directly initiate the FCC ID certification process to avoid rework due to incorrect pathway selection.
By 2026, FCC SDoC certification is no longer a simple process of "testing once and done", but a systematic project integrating "technical compliance + supply chain security + new regulation adaptation". Only by accurately grasping regulatory changes and integrating compliance into the entire process of product design, supply chain selection, and declaration can enterprises successfully navigate US market trade barriers and avoid significant losses such as goods detention and heavy fines caused by non-compliance. For professional certification consulting services, contact BLUEASIA at +86 13534225140.
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