FCC Authorization of Digital Devices

Digital devices are everywhere. From mobile phones to tablets, cameras to smartwatches, audio to gaming, billions of digital devices are in use worldwide. 

In the United States, nearly all digital devices must be authorized under the Federal Communications Commission’s (FCC) rules prior to being marketed or imported into the country. The FCC’s rules mitigate the potential for harmful interference between devices and ensure the devices meet certain other requirements, including those related to RF exposure limits.

The FCC has two equipment authorization pathways - Supplier’s Declaration of Conformity (SDoC) and Certification. Generally, devices that intentionally transmit a wireless signal are subject to the Certification requirement. Devices that unintentionally emit RF as a function of their internal operations are typically able to be authorized under the SDoC procedure (although devices subject to SDoC may opt for the Certification procedure). Certain devices may be subject to more than one authorization procedure. Each device should be evaluated individually for the proper compliance route.  

Certification – Certified devices undergo testing by an FCC-recognized accredited test laboratory and are issued an authorization by third-party Telecommunication Certification Bodies (TCBs) recognized by the FCC. Devices authorized under the Certification procedure receive an FCC ID, and information regarding the device is available online in the FCC’s public Equipment Authorization database. 

Supplier’s Declaration of Conformity (SDoC) – SDoC is a less burdensome authorization procedure available primarily to devices that do not intentionally radiate an RF signal and are thus viewed as having a lower potential for interference. SDoC devices are not required to be tested at accredited labs, are not issued authorizations by TCBs, and do not receive FCC IDs. SDoC devices also are not identified in the FCC’s Equipment Authorization database.  

Instead, SDoC requires the responsible party, who must be located in the United States, to conduct compliance tests and maintain the results in the event they are requested by the FCC.  

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For more information, please contact Greg Kunkle; kunkle@khlaw.com; 202.434.4178.