SAFEGUARDS | Electrical & Electronics NO. 131/17

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The US Federal Communications Commission (FCC) is combining two separate self-approval procedures into one, the Supplier’s Declaration of Conformity.

In July 2017, the US Federal Communications Commission (FCC) announced that it is launching a new Supplier’s Declaration of Conformity (SDoC). This new process combines two separate self-approval procedures into one, which will help to reduce confusion as to which process applies to any given product.

Currently, there are two different procedures for effecting equipment authorization by what amounts to self-approval by the responsible party. “Verification” is the process used for RF equipment that has a well understood testing methodology, poses a low interference risk, and has a high compliance rate. The party responsible for verification must take the necessary steps (testing or analysis) to ensure that the equipment complies with the appropriate technical standards. A Declaration of Conformity (DoC) was later instituted, primarily for personal computer equipment, at a time when test procedures were not fully established. Testing required heightened technical expertise, and the equipment could pose an elevated risk of causing harmful interference if it was not tested properly. Accordingly, the DoC has added requirements to have compliance testing performed by an accredited testing laboratory, as well as inclusion of a written compliance statement from the manufacturer, a “Declaration of Conformity”, with the literature furnished to the user and use of a specific FCC logo on the equipment identification label that signifies that the equipment meets the Commission’s regulations. These self-approval processes are distinguished from the more rigorous certification process, third type of equipment authorization procedure, which generally is used for equipment that employs new technologies, involves complex testing procedures, or has a high risk of causing harmful interference.

The FCC will adopt its own proposal to replace the two existing self-approval procedures (DoC and verification) with a single process, the new "Supplier’s Declaration of Conformity" (SDoC). The FCC observe that the test procedures for personal computer equipment and other devices currently subject to the DoC procedure have long been finalized and are well understood, such that there is no longer a need to require accreditation of test laboratories. Without the requirement for laboratory accreditation, the DoC and verification procedures are quite similar. Replacing these two processes with one will provide a unified process for the authorization of those RF devices that are well-suited for self-approval, i.e. equipment that has a strong record of compliance and for which there is minimal risk of harmful interference. In this action, the FCC will reduce the burden of self-approval authorizations by applying the less rigorous verification testing requirements to all devices under the SDoC. The FCC will also eliminate the requirement for displaying the FCC logo on all equipment approved under SDoC, currently imposed only on DoC devices. The FCC will maintain the requirement for displaying a compliance statement and the identity of the responsible party, and apply it to all self-approved devices, but permit it to be included with other information provided to the user instead of being displayed on the device itself. This compliance statement will represent a new requirement for verified devices, but should not increase the burden as it replaces the requirement for a verified device to display a label on the device itself as testament to the device’s compliance. These changes represent not only a reduction in the burden warranted by current circumstances, but also provide a welcome simplification of the rules.


The FCC proposes to make all of the rule changes proposed in the NPRM effective immediately upon their publication in the Federal Register (unless subject to approval by the Office of Manegement and Budget). Further, it proposes to permit manuafacturers to continue to self-approve products using the existing DoC or verification procedure for up to one year from the effective date of the rules, if they so choose.

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