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FCCSDoCUS compliance

# FCC Supplier's Declaration of Conformity (SDoC): Complete Guide

SDoC is the FCC's self-certification route — faster and cheaper than Certification, with no FCC filing required. But it is only available for specific device categories, carries strict record-keeping obligations, and using it for products that require Certification is a federal violation. This guide covers when to use it, what it must contain, and how to avoid the common mistakes.

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Overview

## SDoC vs Certification: the two FCC authorization routes

FCC equipment authorization for Part 15 devices takes one of two forms. **Certification** involves a third-party review by an FCC-recognized Telecommunications Certification Body (TCB). The TCB evaluates test reports and issues a grant of equipment authorization. The device receives an FCC ID and appears in the FCC's online database. Certification is mandatory for intentional radiators — devices that intentionally generate and emit RF energy, including Bluetooth, Wi-Fi, cellular, and Zigbee.

**Supplier's Declaration of Conformity (SDoC)** is a self-certification route. The responsible party commissions testing at an accredited laboratory, reviews the results, and issues the SDoC based on their own determination of compliance. No filing with the FCC occurs, no FCC ID is assigned, and no TCB is involved. SDoC is available for most Part 15 Subpart B unintentional radiators — digital devices that radiate RF as a byproduct rather than as their primary function.

The SDoC route is faster, cheaper, and simpler in terms of administrative process. But the responsible party takes on the full legal accountability. If an enforcement action occurs, there is no TCB behind you. Your test records must be production-ready at all times, because the FCC can request them within 72 hours.

Eligibility

## Which products qualify for SDoC?

### Eligible for SDoC

*   Part 15 Subpart B unintentional radiators — computers, peripherals, switching power supplies
*   Class A digital devices distributed exclusively through commercial channels
*   Class B digital devices for residential and general consumer use
*   TV broadcast receivers and cable system terminal devices
*   Certain low power transmitters under specific Part 15 subparts

### Must use Certification (no SDoC)

*   All intentional radiators: Bluetooth, Wi-Fi, Zigbee, LoRa, cellular, NFC
*   Software-defined radios and cognitive radios
*   Radar systems and transmitters covered by Parts 22, 24, 25, 27, 90
*   Hearing aid compatible devices under specific Part 15 rules
*   Any device where the applicable Part 15 subpart explicitly requires Certification

Documentation

## What your SDoC documentation must contain

01

### Test reports from an accredited laboratory

Conducted and radiated emission measurements must be performed by a laboratory accredited by an FCC-recognized accreditation body — typically A2LA, NVLAP, or an ILAC MRA signatory. The test report must reference the applicable Part 15 limits, show compliance across all measured frequencies, include equipment setup details, and be signed by a qualified test engineer.

02

### The SDoC statement itself

The SDoC must include: product trade name and model number; statement of compliance with applicable FCC rules; the name, address, and phone number of the US responsible party; and a statement that the device complies with Part 15 of the FCC Rules. The SDoC is typically included in the user manual, a separate leaflet shipped with the product, or posted on the manufacturer's website with a reference in the product documentation.

03

### Required labelling

Class B devices must carry the FCC compliance notice — for example: 'This device complies with Part 15 of the FCC Rules. Operation is subject to the following two conditions: (1) this device may not cause harmful interference, and (2) this device must accept any interference received, including interference that may cause undesired operation.' Class A devices carry a modified version with a warning about potential interference in residential settings.

04

### Responsible party records

The responsible party must retain the test records, technical documentation, and SDoC for two years after the product is last manufactured or imported. Records must be producible to the FCC within 72 hours of a request. For products with ongoing production, the record retention clock restarts with each new manufacturing run.

Enforcement risks

## Common SDoC mistakes that attract FCC enforcement

01

Using SDoC for a device that contains an intentional radio transmitter — all such devices must use Certification regardless of whether the radio is the primary function

02

Issuing the SDoC before testing is complete, or issuing it based on test reports that were conducted at a non-accredited lab

03

Failing to retain test records — the FCC can request records within 72 hours, and inability to produce them is an independent violation

04

Not identifying a US responsible party — foreign manufacturers who import into the US must have a US-based responsible party; the overseas entity cannot fulfil this role

05

Certifying product variants that were not tested — if a product line has multiple models with different PCBs or clock frequencies, each model must have its own test evidence

06

Treating SDoC as perpetual — if the product design changes in a way that could affect emissions, a new SDoC and new test evidence are required

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## Frequently asked questions

### What products can use FCC SDoC instead of Certification?

SDoC is available for most Part 15 Subpart B unintentional radiators (digital devices, switching power supplies, computer peripherals) and certain Part 15 intentional radiators operating under limited conditions. Products containing intentional radio transmitters in Part 15 Subpart C — Bluetooth, Wi-Fi, cellular — must use Certification through an accredited TCB. Always check the specific Part 15 subpart for your device type.

### Does an SDoC need to be submitted to the FCC?

No. Unlike Certification, SDoC is not submitted to the FCC. The responsible party retains the SDoC documentation and test records in their files and must make them available to the FCC on request within 72 hours. There is no FCC database entry, no FCC ID, and no grantee code for SDoC-authorized devices.

### Who is the responsible party for an FCC SDoC?

The responsible party is the US-based entity that manufactures, imports, sells, or offers for sale the device. For foreign manufacturers without a US presence, a US importer or their designated US representative must act as the responsible party. The responsible party is legally accountable for ensuring the product meets FCC requirements and for producing test records on demand.

### What must be included in an FCC SDoC document?

The SDoC must include the product name and model number, a statement that the product complies with applicable FCC Part 15 rules, the name and contact information of the responsible party, and an indication of whether it is a Class A or Class B device. The SDoC is typically included in the user manual or as a separate declaration document shipped with the product. The underlying test records that support the SDoC are retained separately.

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Related guides

*   [FCC SDoC Deep DiveA deep dive into FCC SDoC: mixed-mode devices combining unintentional and intentional radiators, responsible-party succession, the 72-hour record production standard in practice, and how SDoC compares to CE self-declaration under Module A.](/guides/fcc-sdoc-supplier-declaration-deep-dive)
*   [FCC Part 15 Class A vs Class BFCC Part 15 Class A vs Class B explained: how to classify your digital device, emission limits, residential vs commercial use, …](/guides/fcc-part-15-class-a-vs-b)
*   [FCC TCB Certification ProcessFCC Certification through an accredited Telecommunications Certification Body (TCB) is mandatory for all intentional radiators.](/guides/fcc-tcb-process)
*   [FCC KDB GuideThe FCC's Knowledge Database (KDB) publishes official guidance on FCC equipment authorization rules and test procedures.](/guides/fcc-kdb-guide)
*   [ISED Canada CertificationComplete guide to ISED (Innovation, Science and Economic Development) Canada equipment certification: IC ID format, RSS standar…](/guides/ised-canada-certification)
*   [FCC ID Label RequirementsThe rules under 47 CFR Part 2 Subpart J and Part 15 for displaying an FCC ID: physical label content and legibility, the e-labeling option, placement on modular transmitters and host devices, and the violations that draw enforcement.](/guides/us-fcc-id-label-requirements)

Educational resource only. FCC rules are product-specific. Verify current Part 15 requirements for your exact device category before issuing an SDoC.