Introduction and Regulatory Overhaul
In a Report and Order adopted on May 9, 1996, and released on May 14, 1996, under ET Docket No. 95-19 (FCC 96-208), the Federal Communications Commission amended Parts 2 and 15 of its rules to streamline equipment authorization requirements for personal computers and personal computer peripherals.
The Commission established a new Declaration of Conformity (DoC) procedure, allowing manufacturers and suppliers to authorize computing products based on a declaration of compliance with FCC technical standards without prior FCC Laboratory approval. The Commission also established provisions allowing personal computers assembled from separately authorized modular components to be marketed without retesting the complete assembly. This action operates under new authority provided in Section 403(f) of the Telecommunications Act of 1996, which amended Section 302 of the Communications Act of 1934.
- Docket: ET Docket No. 95-19 (FCC 96-208)
- Adopted Date: May 9, 1996
- Released Date: May 14, 1996
- Terminated Docket: GEN Docket No. 90-413
Declaration of Conformity Framework and Responsibilities
Under the newly established DoC process, equipment must be tested by an accredited laboratory to ensure compliance with radio frequency (RF) emission limits. Once testing confirms compliance, marketing may begin immediately. The responsible party—defined as the U.S. manufacturer, assembler, or importer—must include a compliance information statement with the product literature or user manual.
The compliance information statement must include product identification (trade name and model number), a statement attesting compliance with Part 15 of the FCC Rules, and the name, address, and telephone number of the responsible party located within the United States. If requested by the Commission via certified mail, the responsible party must furnish documentation and test reports within 14 days of delivery. All compliance records must be retained for two years after product manufacturing or assembly is permanently discontinued.
- 14-day turnaround requirement for submitting compliance data upon FCC request.
- 60-day turnaround for submitting test sample units upon FCC request (or not less than 14 days for harmful interference or safety matters).
- Mandatory two-year record retention period following the permanent discontinuance of manufacturing or assembly.
- Option to continue using the traditional certification route on an indefinite basis alongside the DoC procedure.
Labelling Requirements and Compliance Logos
The Commission eliminated the traditional FCC ID labelling requirement for devices authorized solely under a DoC, replacing it with a standardized label format and compliance logo. Labels must be permanently affixed, readily visible to purchasers, and include unique product identification.
The Commission specified two distinct label designs: one for completely tested products/systems, and one for systems assembled from separately tested components without full-system testing.
- Tested products must state: 'Tested To Comply With FCC Standards FOR HOME OR OFFICE USE' along with the Trade Name and Model Number.
- Assembled systems must state: 'Assembled From Tested Components (Complete System Not Tested) FOR HOME OR OFFICE USE' along with the Trade Name and Model Number.
- Warning statements regarding interference resolution must be placed in the user manual rather than directly on the external equipment label.
Test Laboratory Accreditation Requirements
To ensure compliance without direct FCC pre-approval, all laboratories testing personal computer equipment under the DoC procedure must be accredited by an authorized accreditation body based on ISO/IEC Guide 25. Accreditation bodies themselves must meet ISO/IEC Guide 58 standards and be approved by the FCC Office of Engineering and Technology (OET).
The Commission recognized the National Voluntary Laboratory Accreditation Program (NVLAP) administered by the National Institute of Standards and Technology (NIST) and the American Association for Laboratory Accreditation (A2LA). The Chief of OET was delegated authority to approve additional accreditation bodies. Accreditation applies equally to independent and manufacturer-affiliated laboratories. Accreditations of foreign laboratories are accepted only from countries maintaining a mutual recognition agreement with the United States.
- Accreditation standards: ISO/IEC Guide 25 for laboratories and ISO/IEC Guide 58 for accrediting bodies.
- Accepted domestic programs include NIST NVLAP and A2LA.
- Foreign test laboratory data accepted strictly under mutual recognition agreements.
Authorization Rules for Modular Components and Personal Computer Assemblers
The Report and Order established specific rules under Section 15.32 and Section 15.102 for Central Processing Unit (CPU) boards and internal power supplies. A CPU board is defined as a circuit board containing a microprocessor or frequency-determining circuitry whose primary function is executing user-provided programming, excluding dedicated controllers or secondary microprocessors.
CPU boards must undergo radiated emission testing installed in a typical enclosure with the cover removed (circuitry exposed on top and at least two sides), permitting emissions to exceed Section 15.109 limits by up to 3 dB. If emissions fall within 3 dB, a second test must be conducted with the enclosure cover closed to verify full compliance. Power supplies must be tested installed in a representative operating personal computer system.
Enclosures are not subject to separate shielding authorizations. Assemblers who build personal computers entirely from separately authorized CPU boards, power supplies, and other compliant components are not required to test the final assembled system, provided they follow all manufacturer installation instructions, supply the assembled DoC statement, and affix the assembled-system compliance label.
- CPU board radiated testing: open-enclosure testing with a 3 dB margin allowance prior to closed-case verification.
- Power supplies must be tested under representative system configurations.
- Components requiring soldering, wire alterations, or complex circuit changes cannot be authorized as user-modular components.
- 12-month transition deadline for CPU board and power supply manufacturers and importers from the date of publication in the Federal Register.