Unification of Self-Approval Procedures Under SDoC
In a draft First Report and Order in ET Docket No. 15-170, the Federal Communications Commission proposes to consolidate its two existing self-approval pathways—Verification and Declaration of Conformity (DoC)—into a single unified procedure named Supplier's Declaration of Conformity (SDoC). The Commission determined that test methods for digital devices and personal computer equipment have matured, eliminating the necessity to mandate accredited testing laboratories for devices subject to self-approval.
Under the revised Part 2 rules, responsible parties using SDoC will no longer be mandated to display the FCC logo on product labels, though voluntary placement remains permitted. Responsible parties must supply a compliance information statement with product literature identifying a responsible party located within the United States, and may provide an internet-based contact in lieu of a telephone number. A one-year transition period from the effective date of the rules is established, during which manufacturers may continue to authorize devices under legacy Verification or DoC rules, with previously authorized devices grandfathered for their operational lifetimes.
- Merges Verification and Declaration of Conformity (DoC) into Supplier's Declaration of Conformity (SDoC).
- Eliminates mandatory testing laboratory accreditation requirements for self-approved equipment.
- Removes mandatory FCC logo labeling while allowing voluntary use on compliant devices.
- Requires a compliance statement with product literature identifying a United States responsible party.
- Establishes a one-year transition period for new authorizations while grandfathering existing authorized equipment.
Codification of Electronic Labeling Rules Under the E-LABEL Act
Pursuant to the Enhance Labeling, Accessing, and Branding of Electronic Licenses Act of 2014 (E-LABEL Act), the draft Order adds Section 2.935 to Title 47 of the Code of Federal Regulations, permitting devices with an integrated display or those operating exclusively with an external display to display required regulatory labels electronically. Electronically displayed regulatory information must be accessible in no more than three steps from the device settings menu without requiring special access codes or accessories.
To preserve supply chain and border verification, devices utilizing electronic labeling must include identifying information on their packaging or on a removable label at the time of importation and marketing. The Commission also adopted provisions in Section 2.925 allowing devices that are too small to legibly display an FCC ID in four-point type or larger, and which lack display capabilities, to include the FCC ID in the user manual alongside packaging markings.
- Adds 47 CFR Section 2.935 permitting electronic display of FCC Identifiers, warnings, and compliance statements.
- Limits digital access pathways to no more than three steps starting from the device settings menu.
- Requires temporary external labeling or packaging identifiers for electronically labeled devices during import and sale.
- Permits FCC ID placement in user manuals for small devices unable to accommodate four-point font when no screen is present.
- Excludes specific emergency and maritime safety equipment from electronic labeling, including 406 MHz personal locator beacons and emergency position indicating radiobeacons.
Streamlining Importation Regulations and Trade Show Allowances
The draft Order permanently eliminates the requirement to file FCC Form 740 import declarations with U.S. Customs and Border Protection (CBP) by removing Section 2.1205 and revising Section 2.1203. In place of transactional filings, Section 2.1203(a) is modified to require that the importer, ultimate consignee, or designated customs broker determine compliance prior to importation and retain supporting compliance documentation for submission upon Commission request within one year of entry.
The Commission revised Section 2.1204(a)(4) import limits for trade show demonstrations to permit up to 400 devices of any type without prior written authorization, consolidating previous separate limits of 200 units for licensed and 10 units for unlicensed equipment. In addition, Section 2.1204(a)(7) is expanded to allow individuals to import up to three client or subscriber RF devices for personal use.
- Discontinues FCC Form 740 import declaration submissions and deletes 47 CFR Section 2.1205.
- Amends Section 2.1203(a) to require pre-import compliance determinations and document retention for one year.
- Increases the trade show demonstration import limit to 400 units across all device categories.
- Updates personal use import rules under Section 2.1204(a)(7) to encompass up to three client or subscriber devices.
- Removes the obsolete illustrative list of low-level battery-powered exempt devices under Section 2.1202(a).
Measurement Procedures and Industry Standards Integration
The Commission updated its technical compliance measurement regulations by incorporating direct references to the Office of Engineering and Technology (OET) Knowledge Database (KDB) in Section 2.947(a)(3). A new provision in Section 2.947(g) requires test reports to contain adequate test data or explicit justifications for omitted testing.
The Order amends Section 2.910 and Section 2.1041 to incorporate ANSI C63.26-2015 as an acceptable measurement standard for transmitters used in licensed radio services. Accredited testing laboratories are afforded a two-year transition period from the date of adoption to test to ANSI C63.26-2015 without an explicit expansion of scope from an accrediting body. Additionally, composite system measurement provisions are relocated from Part 15 to general Part 2 rules under Section 2.947(f).
- Amends Section 2.947 to formally reference OET Knowledge Database (KDB) advisory publications.
- Adds Section 2.947(g) mandating comprehensive test data or justified omissions in compliance reports.
- Incorporates ANSI C63.26-2015 by reference for licensed radio service transmitter compliance testing.
- Establishes a two-year transition period for accredited test laboratories adopting ANSI C63.26-2015.
- Moves general composite system testing requirements to 47 CFR Section 2.947(f).