The FCC’s law enforcement has intensified in 2026—there are 3 frequent bottlenecks in the certification process. A minor oversight can result in delays of 2–4 weeks or even compliance risks.
Combined with the latest 2026 FCC law enforcement trends, the implementation requirements of the Secure Equipment Act, and industry practical cases, this article breaks down the full SDoC certification process of "compliance pre-judgment → testing key breakthroughs → declaration finalization", marking the time range, bottleneck solutions, and risk prevention points for each link. It helps you efficiently complete compliance in 2–4 weeks under the premise of simple products, no rectification needed, and smooth laboratory scheduling, avoiding ineffective waiting.
Many people confuse "regulatory revisions" with "law enforcement intensification", leading to misjudgments about the SDoC process. First, SDoC remains a self-declaration system—the FCC does not "certify" or "approve" products. However, multiple penalty cases involving the use of components from restricted entities have occurred between 2023 and 2025, and Customs and the FCC have significantly strengthened inspections of supply chain sources. Second, supply chain verification and module traceability are not explicitly mandated by new FCC rules but are key evidence chain elements for responding to spot checks. If you cannot prove that key components/laboratories are not involved with "Covered List" entities, even valid test reports may be challenged for compliance authenticity. Third, products with wireless modules (e.g., Bluetooth, Wi-Fi) cannot use the SDoC pathway and must switch to FCC ID certification. This core rule has never changed, yet many enterprises still fall into this trap.
In short, the framework of the SDoC process has not changed in 2026, but the requirements for the "completeness of the compliance evidence chain" have been significantly raised. Skipping key evidence retention steps may result in higher costs for subsequent spot check rework.
II. 2026 FCC SDoC Certification Full Steps & Timeline
The core of SDoC certification is "independent leadership + closed-loop evidence chain". The 2026 process can be divided into 5 phases, each with a clear time range and practical details:
Phase 1: Product Classification & Compliance Pre-Judgment (Timeline: 1–2 days, Avoid "Wrong Path Selection")
This is the most overlooked yet critical step, and early screening can avoid major rework later. The core operations include three parts: first, confirm whether the product has wireless transmission functions (e.g., Bluetooth, Wi-Fi), and if yes, immediately switch to the FCC ID process instead of wasting time pursuing SDoC. Second, confirm the applicable FCC rule subpart for the product: unintentional radiators (e.g., power adapters, keyboards) correspond to Part 15B, while smart devices with non-wireless modules (e.g., smart lighting) still fall under Part 15B but require additional module compatibility testing. Third, conduct initial supplier screening by checking the "Covered Communications Equipment or Services" list via the FCC Supply Chain Security official page to quickly verify if module and chip suppliers are on the "Covered List", and initiate supplier replacement within 24 hours if any supplier is listed.
A common time bottleneck here is that replacing a supplier on the "Covered List" will take an additional 3–5 days, so it is recommended to reserve 2–3 alternative suppliers in advance. For risk prevention, do not judge product classification based on experience. For example, a smart socket with Bluetooth—even if Bluetooth is only used for control functions—must use the FCC ID pathway. Last year, a manufacturer chose the wrong SDoC pathway, resulting in 3 weeks of goods detention.
Phase 2: Supply Chain Evidence Retention & Laboratory Selection (Timeline: 1–3 days, Key Enhancement in 2026)
With stricter FCC law enforcement in 2026, supply chain evidence retention has become critical for compliance and cannot be omitted. Core operations include three steps: first, retain supply chain evidence by entrusting a third-party organization to issue a "Supplier Non-Restriction Statement" covering laboratories, module suppliers, and chip suppliers, which costs approximately USD 300–700 (CNY 2,000–5,000) and takes 1–2 days, serving as core evidence for responding to spot checks. Second, select a laboratory that meets the ANSI C63.4 standard, require it to provide a "Non-Restricted Entity Related Certificate", and confirm that the laboratory has module compatibility testing capabilities, which is essential for module-equipped products. Third, sign a testing agreement that clearly specifies test items, report delivery time (7 working days for ordinary products, 10 working days for module-equipped products), and includes a clause for "one free retest for initial testing failure" to avoid additional fees later.
A time bottleneck in this phase is that laboratory scheduling during peak seasons (March–April, September–October) will result in an additional 3–5 days of waiting, so it is recommended to book 2 weeks in advance. For risk prevention, do not select low-cost, unqualified laboratories. Last year, a manufacturer used a non-ANSI C63.4 compliant laboratory, and its test report was challenged by the FCC, requiring 2 extra weeks for re-testing.
Phase 3: Product Testing & Pre-Rectification (Timeline: 1–3 weeks, Key Determinant of Total Timeline)
Testing is the phase with the greatest time variance—simple products can be completed in 1 week, while module-equipped products may take 3 weeks, and the core is to reduce the probability of initial testing failure. Core operations include three parts: first, conduct pre-testing, which is optional but highly recommended. This involves conducting simple EMC testing (radiated and conducted emissions) independently or entrusting a laboratory, which takes 1–3 days and costs approximately USD 70–210 (CNY 500–1,500), and can identify radiation exceeding limits and other issues in advance to avoid formal testing failures. Second, carry out formal testing: for simple products (e.g., power adapters), only EMC testing (radiation + conduction) is needed, with reports issued in 1–2 weeks; for module-equipped products (e.g., smart lighting), additional module compatibility testing is required to ensure modules do not interfere with the electromagnetic radiation of the entire device during operation, with reports issued in 2–3 weeks; for products with FCC ID modules, ensure that modules have already obtained FCC ID certification when the complete machine uses the SDoC pathway, and the complete machine testing includes EMC testing with modules in operation. Third, handle testing rectification: if testing fails (e.g., radiation exceeding limits), component replacement (e.g., adding filters) or PCB layout optimization is required, which takes 1–3 days for rectification and 1 week for retesting, and pre-testing can reduce the rectification probability by 80%.
The main time bottleneck here is the rectification phase, which is the most prone to delays, especially when hardware adjustments are involved, potentially taking an additional 2–3 days. For risk prevention, provide a complete BOM list to the laboratory before testing to allow the laboratory to pre-judge risks. For example, a manufacturer’s selected power module had potential radiation exceeding risks, and the laboratory recommended replacement in advance, saving 1 week of rectification time.
Phase 4: SDoC Document Preparation & Signing (Timeline: 1–3 days, Details Determine Evidence Validity)
SDoC documents do not need to be submitted to the FCC but must be complete and traceable, and they will be the focus of FCC law enforcement spot checks in 2026. Core operations include three steps: first, prepare documents that include 8 core pieces of information (supplier name + US Responsible Party information + product model + applicable FCC subpart + test report number + module traceability record + signatory information + compliance declaration clauses), and for module-equipped products, attach a "Module Supplier Compliance Commitment Letter". Second, conduct internal review where the compliance department checks documents, with a focus on verifying the authenticity and validity of US Responsible Party information and consistency of test report numbers, which takes 1 day. Third, sign the declaration, which must be signed by personnel responsible for compliance within the enterprise, scanned and archived, and while submission to the FCC is not required, ensure all records are readily accessible within the US at any time.
A time bottleneck here is that missing module traceability records will render documents invalid, requiring re-preparation and taking an additional 1–2 days, so it is recommended to cross-verify against the BOM list item by item during preparation. For risk prevention, use the SDoC template recommended by the FCC official website to avoid format irregularities caused by self-formatting, which may affect evidence validity.
Phase 5: Product Marking & Document Archiving (Timeline: 1–2 days, Retain for 5 Years for Future Reference)
In 2026, the FCC has increased spot check frequency—standardized marking and document archiving are the foundation of compliance. Core operations include two steps: first, label the product itself or packaging with compliance declarations, where simple products can be labeled "FCC Part 15 Compliant", module-equipped products are recommended to have "Module Supplier: XXX" added, and markings must be permanently legible (etching or silk-screening is preferred; stickers are not recommended), which takes 1 day. Second, archive documents by retaining SDoC declarations, test reports, supply chain compliance certificates, module compliance commitment letters, product schematics, and other materials for at least 5 years as required, preparing both electronic and paper copies to ensure ready access within the US at any time, which takes 1 day.
A time bottleneck here is that illegible or easily worn markings may result in customs requiring rectification, taking an additional 1 day for re-sampling. For risk prevention, confirm marking locations with the laboratory in advance—for example, small power adapters can be labeled on the bottom to ensure markings do not fall off or become blurred during transportation and use.
III. 2026 SDoC Certification Total Timeline Analysis
There is no fixed standard for total SDoC certification time, which is mainly affected by product complexity, laboratory scheduling, and rectification needs, with the overall timeframe ranging from 2–6 weeks. For simple unintentional radiators (e.g., ordinary power adapters), the process takes 2–3 weeks, including 1 week for testing, 1 day for documentation and 1 day for marking, assuming no rectification and smooth scheduling. For devices with non-wireless modules (e.g., smart lighting), the process takes 4–6 weeks, including 2–3 weeks for testing, 2 days for supply chain evidence retention and 3 days for documentation. For product series (multiple devices with the same architecture), the main model takes 3–4 weeks, with an additional 1–2 weeks per sub-model since only difference testing is required.
IV. 2026 SDoC Self-Checklist
1.Confirmed that the product has no wireless transmission functions and clearly belongs to FCC Part 15B.
2.Core suppliers (components, laboratories) have been screened, are not on the "Covered List", and relevant certificates have been retained.
3.The selected laboratory meets the ANSI C63.4 standard and has corresponding testing capabilities.
4.For module-equipped products, module compliance has been confirmed (modules with FCC ID have obtained certification), and compatibility testing is included.
5.SDoC declaration information is complete, the signatory is compliant, and all records are accessible within the US.
6.Product markings are permanently legible, and documents have been retained as required (electronic + paper copies).
SDoC certification has never been about "going through the motions and wasting time", but about "building a complete compliance evidence chain". Against the backdrop of stricter FCC law enforcement in 2026, while the process steps remain unchanged, requirements for evidence completeness and supply chain transparency have been significantly raised—skipping key evidence retention may save 1–2 days in the short term but could lead to severe losses such as goods detention and fines later. For professional certification consulting services, contact BLUEASIA at +86 13534225140.
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