FCC Part 15 — Unintentional Radiators (Supplier's Declaration of Conformity)

Electronic products with digital circuitry that are not designed to transmit radio signals (unintentional radiators) must be authorised before marketing in the US, in most cases via the Supplier's Declaration of Conformity (SDoC): a US-based responsible party tests the product against the FCC emission limits and self-declares compliance, with no FCC filing. Certification through a TCB may be used instead, and is mandatory for a few device types.

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Applies to

Unintentional radiators — devices that intentionally generate radio frequency energy for use within the device or send RF signals by conduction to associated equipment, but are not intended to emit RF energy by radiation or induction (47 CFR 15.3(z)). This covers most digital devices (electronics using timing signals above 9,000 pulses per second, 47 CFR 15.3(k)), such as computers, peripherals and other non-radio electronics. Exemptions exist under 47 CFR 15.23, 15.103 and 15.113, and only receivers tuning 30-960 MHz, CB receivers and radar detectors are subject among receivers (47 CFR 15.101(b)).

Key obligations

01Authorise before marketing: except as exempted, unintentional radiators must be authorised via SDoC or certification under 47 CFR Part 2 Subpart J before marketing. The table in 47 CFR 15.101(a) allows "SDoC or Certification" for most device types; scanning receivers, radar detectors and Access BPL equipment require certification.source
02Have a US-based responsible party: for SDoC, the party responsible for compliance (the manufacturer or assembler, the importer for imported equipment, or a retailer/OEM that assumes responsibility by agreement) must be located in the United States (47 CFR 2.909(b)).source
03Test the device against the applicable technical limits for its class — conducted limits on AC-mains ports are in 47 CFR 15.107 and radiated emission limits in 47 CFR 15.109, with separate limits for Class A and Class B devices (the numeric limits are set out in those sections).source
04Supply a compliance information statement with the product at the time of marketing or importation, identifying the product, stating compliance (e.g. the 47 CFR 15.19(a)(3) statement), and giving the name, address and telephone number or internet contact of the US-based responsible party (47 CFR 2.1077).source
05Label the device with the Part 15 compliance statement in a conspicuous location (47 CFR 15.19(a)(3)), with a manual/packaging alternative for devices too small to label (47 CFR 15.19(a)(5)).source
06Include the required user-manual statements: the Class A or Class B interference statement from 47 CFR 15.105 (as applicable to the device's class), and the 47 CFR 15.21 caution that unauthorised changes or modifications could void the user's authority to operate the equipment.source

Conformity routes

Supplier's Declaration of Conformity (SDoC)Default route for most unintentional radiators. The US-based responsible party makes measurements or completes other acceptable procedures to ensure compliance; no submission to the FCC is required unless specifically requested (47 CFR 2.906). Testing does not have to be at an FCC-recognised accredited laboratory, per FCC OET guidance.source
Certification via a Telecommunication Certification Body (optional or mandatory)The responsible party may always choose certification instead of SDoC (47 CFR 2.906(c)). Certification is mandatory for scanning receivers, radar detectors and Access BPL (47 CFR 15.101(a)), and for equipment produced by entities on the FCC's Covered List, which are prohibited from using SDoC (47 CFR 2.906(d)).source

Documentation

Compliance information statementIncluded in the user manual or as a separate sheet supplied with the product (electronic provision permitted under the conditions in 47 CFR 2.1077(c) and 2.935). Must identify the product, state compliance, and identify the US-based responsible party.source
Test records and description of measurement facilitiesThe testing laboratory must compile a description of the measurement facilities (retained by the party responsible for authorisation and provided to the FCC on request, 47 CFR 2.948(b)); the FCC's OET guidance states the responsible party maintains all documentation demonstrating compliance.source
Device identification recordsThe responsible party must maintain adequate identification records to facilitate positive identification of each device subject to SDoC (47 CFR 2.1074(a)).source

Marking requirements

Part 15 compliance statement (47 CFR 15.19(a)(3)) for most devices: "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."source
Unique identification: devices subject only to SDoC must be uniquely identified by the party responsible for marketing or importing them, but the identification must not use a format that could be confused with the FCC Identifier used on certified equipment (47 CFR 2.1074(a)).source
Optional FCC logo: SDoC devices may voluntarily be labelled with the FCC logo as a visual indication of compliance; using the logo does not remove the requirement to provide the 47 CFR 2.1077 compliance information statement (47 CFR 2.1074(b)).source

Testing standards

Harmonised and designated standards lists change over time: confirm the currently cited version before testing.

ANSI C63.4-2014

Key dates

2017-11-02Current Supplier's Declaration of Conformity rules added to 47 CFR Part 2 — Federal Register publication 82 FR 50825, as shown in the eCFR source notes for 47 CFR 2.906 and 2.1071-2.1077.source

Penalties

Marketing devices that lack the required equipment authorisation can lead to FCC Enforcement Bureau investigation and enforcement action, which may include monetary penalties (forfeitures) and injunctive directives. Forfeiture amounts change over time (including inflation adjustments), so check current FCC enforcement guidance rather than relying on fixed dollar figures.sourceUnverified — check source

Further guidance

https://www.fcc.gov/engineering-technology/laboratory-division/general/equipment-authorization

Frequently asked

What counts as an unintentional radiator?+

A device that uses radio-frequency energy internally (for example digital circuitry with clocks above 9 kHz) or sends RF signals over its wiring, but is not designed to transmit radio signals over the air. Most ordinary electronics without a radio — computers, monitors, power supplies, appliances with digital controls — fall in this category.

What is the difference between Class A and Class B?+

Class A digital devices are marketed for use in commercial, industrial or business environments; Class B devices are marketed for residential use (personal computers, calculators and similar consumer electronics). Class B limits are the ones that matter for consumer products, and each class has its own emission limits and required user-manual statement.

Does an SDoC product get an FCC ID?+

No. FCC IDs are only issued through certification. An SDoC device must instead carry a unique identification chosen by the responsible party — in a format that cannot be confused with an FCC ID — plus the Part 15 compliance statement, and it must ship with a compliance information statement identifying the US responsible party.

I'm a foreign manufacturer — can I use SDoC?+

Only through a responsible party located in the United States. For imported equipment that is normally the importer, and a retailer or OEM can also assume responsibility by written agreement. If you have no US party willing to take that role, certification through a TCB is the alternative route.

Do I have to test at an FCC-recognised accredited lab for SDoC?+

No. The FCC's guidance states that equipment approved using SDoC must be tested, but it is not necessary to use an FCC-recognised accredited testing laboratory — although the lab must keep the required records of its measurement facilities and measurements. Certification, by contrast, does require an FCC-recognised accredited lab.

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