FCC SDoC vs. Certification: Rule Parts, Requirements, and Exceptions
The Federal Communications Commission (FCC) requires radiofrequency (RF) equipment to comply with applicable technical requirements and follow the required equipment authorization procedure.
The two primary authorization procedures are Supplier’s Declaration of Conformity (SDoC) and certification. Under 47 CFR § 2.906, SDoC allows the responsible party to establish compliance without obtaining an FCC certification grant. Under § 2.907, certification requires an application and approval by the FCC or an authorized Telecommunications Certification Body (TCB).
The appropriate procedure depends on the device classification and the applicable FCC rule part.
FCC SDoC vs. Certification: Rule-by-Rule Comparison
| FCC rule part or device category | SDoC permitted? | Certification requirement | Applicable rule |
| Part 15B: Most unintentional radiators, including digital electronics and computer peripherals | Yes | Optional | 47 CFR § 15.101 |
| Part 15B: Scanning receivers, radar detectors, and Access BPL equipment | No | Required | 47 CFR § 15.101(a) |
| Part 15C: Most intentional radiators, including Wi-Fi and Bluetooth transmitters | Generally no | Required unless an exception applies | 47 CFR § 15.201(b) |
| Part 15: Certain qualifying intentional radiators | Yes, where specified | Depends on the applicable provision | 47 CFR § 15.201(a) |
| Part 18: Consumer ISM equipment, unless otherwise specified | Yes | Optional | 47 CFR § 18.203(a) |
| Part 18: Qualifying consumer ultrasonic equipment operating below 90 kHz and generating less than 500 W | Required | Not the prescribed route | 47 CFR § 18.203(b) |
| Part 18: Non-consumer ISM equipment | Required | Not the prescribed route | 47 CFR § 18.203(b) |
This table covers common equipment categories. Manufacturers must review the specific rule provisions and exceptions applicable to their products.
1. FCC Part 15B: SDoC or Certification for Unintentional Radiators
Under 47 CFR § 15.101, most unintentional radiators may use either SDoC or certification. These include many computers, digital devices, and peripherals that generate RF energy as a consequence of their operation.
However, scanning receivers, radar detectors, and Access Broadband over Power Line (Access BPL) equipment identified in § 15.101(a) require certification.
Choosing SDoC does not eliminate the requirement to demonstrate compliance with applicable Part 15 emissions limits.
Does Part 15B Require an FCC ID?
An FCC ID is associated with equipment authorized through certification. A device authorized solely through SDoC generally does not receive an FCC ID for that authorization. Products containing separately certified radio modules may display the module’s FCC ID subject to applicable labeling requirements.
2. FCC Part 15C: Why Wi-Fi and Bluetooth Generally Require Certification
Under 47 CFR § 15.201(b), intentional radiators generally require certification unless a specified exception applies.
Section 15.201(a) identifies limited exceptions for certain intentional radiators, including qualifying carrier-current systems and devices operating under specified sections of Part 15. It also provides an exception for devices operating below 490 kHz whose emissions meet the stated attenuation criteria.
These exceptions do not create a general SDoC option for Wi-Fi or Bluetooth transmitters. Manufacturers must also evaluate applicable frequency, power, unwanted-emissions, and RF exposure requirements.
Products combining digital electronics and wireless transmitters must meet the authorization requirements applicable to each function.
3. FCC Part 18: Consumer and Non-Consumer ISM Equipment
Part 18 establishes a separate authorization framework for Industrial, Scientific, and Medical (ISM) equipment.
Under 47 CFR § 18.203(a), consumer ISM equipment generally may use either SDoC or certification, unless otherwise specified.
Section 18.203(b) requires SDoC for qualifying consumer ultrasonic equipment that operates below 90 kHz and generates less than 500 W, as well as non-consumer ISM equipment.
Manufacturers should consult the current rule text, particularly when relying on older compliance documentation or guidance.
4. Products Combining Part 15 and Part 18 Functions
Products that combine wireless power transfer (WPT) and communications may need to comply with both Parts 15 and 18, depending on their design and operating modes.
For example, a wireless charging system may fall under Part 18 for power transfer while its data transmission function is subject to Part 15. The required authorization procedure must be determined separately for each applicable function.
5. Can a Manufacturer Choose Certification Instead of SDoC?
Yes. Under 47 CFR § 2.906(c), a responsible party may apply for certification for equipment otherwise eligible for SDoC.
However, SDoC cannot replace certification when the applicable rules require certification. Manufacturers must also consider the Covered List restrictions under § 2.906(d) and § 2.907(c), which may restrict the authorization procedures available to certain equipment.
6. Who Is Responsible for SDoC Compliance?
Under 47 CFR § 2.909, the responsible party depends on the circumstances of the equipment’s manufacture and importation and any applicable arrangements assigning responsibility.
The responsible party must ensure compliance through appropriate measurements or other procedures accepted by the FCC. Although test reports are not routinely submitted to the FCC for SDoC, supporting evidence must be maintained and may be requested by the Commission.
For certification, the applicant submits the required application information and supporting technical documentation, and the FCC or an authorized TCB issues the grant.
7. How to Determine the Correct FCC Authorization Procedure
Before selecting SDoC or certification, manufacturers should:
- Identify the product’s RF functions and applicable FCC rule parts.
- Determine whether the product is an intentional radiator, unintentional radiator, ISM device, or a combination.
- Review the applicable authorization rules for mandatory certification, SDoC eligibility, or exemptions.
- Check for Covered List restrictions and other applicable exceptions.
- Identify the required testing, documentation, labeling, and responsible-party information.
Conclusion
The appropriate FCC equipment authorization procedure depends on the product classification and applicable rule provisions. Manufacturers should verify the applicable FCC rules before selecting an authorization procedure. MiCOM Labs can help identify regulatory requirements, define testing scope, and support the equipment authorization process.
Related MiCOM Labs resources
FCC Part 15C vs. Part 15E · FCC unintentional radiator testing