Supplier’s Declaration of Conformity will replace previous VoC and DoC equipment authorization procedure entirely when 1 year transaction period coming to an end on November 2, 2018. New Requirements of SDoC procedure regarding Responsible party, Labelling requirements, Compliance Information and Testing Laboratory are addressed.

SAFEGUARDS | Electrical & Electronics NO. 091/18

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Equipment that does not contain a radio transmitter and contains only digital circuitry – such as computer peripherals, microwave ovens, ISM equipment, switching power supplies, LED light bulbs, radio receivers, and TV interface devices – is subject to approval using the SDoC procedure with an option to use the certification procedures.

For equipment that contains both unintentional radiators (e.g. digital logic circuitry) within an end product and intentional radiators, the unintentional radiator portion can be generally authorized under either SDoC or certification while the intentional radiator element (e.g. radio transmitter) contained in the equipment is typically required to be certified.

Where a responsible party optionally chooses to certify the equipment subject to SDoC, as allowed by Section 2.906(c), Appendix B provides further information for the use of equipment class codes with applications for certification.


The responsible party is typically one of the following: the manufacturer, the assembler (if the equipment is assembled from individual component parts), or the importer (if the equipment is imported). This party is responsible for the compliance of the equipment with the applicable standards and must maintain a United States presence. A US retailer or original equipment manufacturer (OEM) may enter into an agreement with the responsible party (manufacturer, assembler, or importer) to assume the liabilities of guaranteeing compliance of the equipment and become the new responsible party for the purposes of the Commission’s rules. In all cases, the compliance information provided with the equipment must identify the responsible party by name, United States-based address, and telephone number or internet contact information.

Although supporting records are not required to be maintained within the United States, the responsible party, located within the United States, is required to be able to provide any compliance information, such as test reports and equipment samples at no cost to the FCC, when requested by the Commission.

In determining compliance for devices subject to SDoC, the responsible party warrants that each unit of equipment marketed under an SDoC will be identical to the unit tested and found acceptable within the standards, and that the records maintained by the responsible party continue to reflect the equipment being produced under the SDoC within the variation that can be expected due to quantity production and testing on a statistical basis.

Next step:

A transition period is provided in the rules allowing use of the former DoC or verification procedures, whichever was previously applicable for a device, until November 2, 2018.

Equipment approved prior to November 2, 2018 using the former DoC or verification procedures is grandfathered; it is not necessary to re-test or apply the SDoC procedure.

If any changes are made to equipment previously approved using either DoC or verification after November 2, 2018, then the procedures for SDoC apply for the modified equipment.

SGS is committed to providing information about development in regulations for consumer products as complimentary services. Through a global network of laboratories, SGS provides a wide range of services including physical/mechanical testing, analytical testing and consultancy work for technical and non-technical parameters applicable to a comprehensive range of consumer products. Please do not hesitate to contact us for further information.

For enquiries, please contact:

Jing Song
Certification Executive
t: 86 755 2532 8659

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