Many enterprises still view FCC SDoC certification as a simple process of "signing a declaration to gain market access", while overlooking its core nature: a self-declaration backed by a complete compliance evidence chain. With the implementation of the FCC Equipment Authorization Program Security New Rules in 2025, supply chain security has become a key variable in SDoC compliance, completely eliminating the possibility of "superficial compliance".
Combined with the latest FCC 47 CFR Part 15 regulations, the 2025 Supply Chain Security Ban, and industry practical cases, this article accurately breaks down the scope of application, practical operation points of SDoC certification, helping enterprises avoid compliance pitfalls and build a "safety barrier" for entering the US market.
SDoC (Supplier’s Declaration of Conformity) is a compliance certification pathway specified by the FCC for certain electronic devices. Its core is that enterprises self-declare product compliance with technical standards while bearing full legal responsibility. The fundamental difference between SDoC and FCC ID lies in "self-declaration" versus "official authorization", but the compliance requirements are equally stringent:
1.Scope of Application: Only Two Device Categories Qualify; Wireless Devices Are Explicitly ExcludedThe FCC strictly limits the scope of SDoC application—it does not apply to all low-power devices. It covers unintentional radiators, which are devices that do not actively transmit wireless signals but generate electromagnetic radiation during operation, such as computer hosts, printers, power adapters, LED lighting, and household appliances. It also covers specific receiving devices, which are devices with only signal reception capabilities and no active transmission function, such as TV receivers, FM radios, and satellite TV receiving equipment. All devices with intentional wireless transmission capabilities (e.g., Bluetooth, Wi-Fi, 5G module-equipped devices) must apply for FCC ID certification, and using the SDoC pathway for these devices will be deemed a direct violation of regulations.
2.Core Nature: Self-Declaration ≠ No Need for EvidenceWhen an enterprise signs an SDoC declaration, it is making a commitment to the FCC that "the product fully complies with the relevant standards of 47 CFR Part 15". Although the FCC does not conduct pre-market reviews, it will launch investigations through market spot checks and consumer complaints. If non-compliance is found or the evidence chain is incomplete, the enterprise will face mandatory product recall, destruction, and a ban on sales in the US market; substantial civil penalties (adjusted annually for inflation, with a maximum fine of hundreds of thousands of US dollars per violation in 2026), and criminal prosecution may apply in serious cases; listing of the enterprise on the FCC non-compliance list, resulting in strict restrictions on the import of all subsequent products into the US.
3.Key Details: Documents Must Be Retained for 2 Years; Laboratories Do Not Require Mandatory NVLAP AccreditationDocument retention requirements state that test reports, technical specifications, and other documents supporting the SDoC declaration must be retained by the US Responsible Party for at least 2 years after the device is discontinued, and the FCC requires these documents to be provided within 48 hours during an audit. It is important to note that the 10-year retention period is a requirement for FCC ID certification, and these two requirements must not be confused. On laboratory qualification, SDoC testing does not mandate NVLAP-accredited laboratories. Any laboratory that meets the ANSI C63.4 standard and has the corresponding testing capabilities is acceptable. However, choosing a laboratory with comprehensive qualifications and rich experience can significantly reduce the risk of test data being challenged.
II. 2026 SDoC Compliance Certification Practical Process
The core of SDoC compliance is "building a verifiable evidence chain". Combined with the 2025 new regulations, the following process has been validated through FCC spot checks and can be directly implemented:
1.Preliminary Determination: Clarify Product Classification & Applicable StandardsFirst, confirm whether the product falls within the scope of SDoC application, with a key focus on checking for intentional wireless transmission functions to avoid choosing the wrong certification pathway. Second, identify applicable standards by referring to FCC 47 CFR Part 15—unintentional radiators reference Part 15B, while receiving devices reference standards corresponding to their frequency bands (e.g., TV receivers reference Part 15D). A key action here is to compile a list of core product functions, clearly indicate whether it is a receiving device or an unintentional radiator, and retain the basis for classification determination.
2.Laboratory Selection: Supply Chain Security Is the Top PriorityFirst, verify that the laboratory meets the ANSI C63.4 standard and has corresponding testing capabilities (e.g., EMC testing, conducted/emission testing). Second, screen for restricted affiliations by checking the FCC official website "Covered List" to verify the laboratory name and parent company information, and if necessary, request the laboratory to provide a non-affiliation declaration. Third, prioritize experienced laboratories—organizations with global compliance service capabilities issue reports with higher recognition, reducing the risk of spot check failures.
3.Core Testing: Ensure Data Authenticity & TraceabilityThe mandatory test items include Electromagnetic Compatibility (EMC) testing, covering conducted emissions (150 kHz–30 MHz) and radiated emissions (30 MHz–6 GHz), which must meet the limit requirements specified by the FCC. On test sample requirements, samples must be identical to mass-produced products, with completely consistent component models and circuit designs, as the FCC will unseal and verify samples during spot checks, and any inconsistency will result in an immediate finding of non-compliance. For test report requirements, the report must clearly specify the test standards, laboratory information, and sample parameters, and test data must be complete and traceable, with no missing or contradictory data points.
4.Evidence Chain Construction: Complete Documentation & Logical ClosureA complete SDoC evidence chain should include product technical documents (technical specifications, circuit schematics, PCB layouts, Bill of Materials (BOM) for key components with component compliance certificates attached), test-related documents (test reports, laboratory compliance declarations, and enterprise due diligence records), and declaration & marking documents (SDoC declaration completed using the FCC template and signed and sealed by a corporate legal representative; product user manual that must include the phrase "SDoC Compliant" and the compliant standard number). All documents should be saved in English PDF format and retained by the US Responsible Party (e.g., US branch, authorized agent) to ensure rapid retrieval during FCC spot checks.
5.Market Access & Customs Clearance: Prepare Audit MaterialsThe SDoC declaration does not need to be submitted to the FCC; it is retained by the enterprise but must be signed before the product is launched on the market. For product marking, label the product itself or the smallest sales package with "FCC Compliant", and for devices with small dimensions, the label may be included in the user manual. On customs clearance preparation, provide a copy of the SDoC declaration, test report summary, laboratory compliance declaration to customs when importing into the US, as customs may conduct random checks to verify the consistency between the product and documentation.
III. 2026 Compliance Pitfalls: 6 Common Mistakes & Solutions
One common pitfall is using the SDoC pathway for Bluetooth/Wi-Fi enabled devices. To address this, enterprises should first determine if the product has intentional wireless transmission functions, and if yes, directly apply for FCC ID certification to avoid customs clearance failures due to incorrect pathway selection. Another pitfall is neglecting laboratory due diligence. The solution here is to establish a laboratory audit mechanism, check the FCC official website for the "Covered List", request the laboratory to provide a non-affiliation declaration, and retain audit records.
Enterprises also often make the mistake of deleting documents after only 1–2 years of retention. The fix is to set document retention reminders to ensure retention for at least 2 years after device discontinuation, and adopt dual storage methods (cloud backup + local storage) to prevent document loss. Selecting laboratories without ANSI C63.4 qualifications is another risky move; enterprises should request the laboratory to provide ANSI C63.4 qualification certificates before cooperation and prioritize organizations with FCC compliance service experience to reduce the risk of invalid test reports.
Missing supply chain security documents in the evidence chain is another common issue. Enterprises should supplement the evidence chain with laboratory compliance declarations and due diligence records to ensure logical closure of documents and meet FCC supply chain security audit requirements. Finally, inconsistency between test samples and mass-produced products can lead to compliance issues. Enterprises should confirm that samples are identical to mass-produced versions in terms of components and design before testing and retain samples after testing to avoid verification inconsistencies during FCC spot checks.
By 2026, FCC SDoC compliance is no longer a simple process of "signing a declaration and conducting a test". The implementation of the Supply Chain Security Ban has made "evidence chain + supply chain verification" the core of compliance. Only by accurately grasping the scope of application, keeping up with new regulatory requirements, and building a complete and credible compliance system can enterprises safely pass FCC spot checks and successfully access the US market. For professional certification consulting services, contact BLUEASIA at +86 13534225140.
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