In the U.S., devices that emit radio frequencies, whether intentionally (i.e., transmitters) or unintentionally (i.e., digital circuitry) must be evaluated to ensure they remain below the emissions limits set by the Federal Communications Commission (FCC) in an effort to reduce instances of electromagnetic interference. The original rules have undergone changes over time, most recently with new rules proposed in 2015, which became mandatory as of November 1, 2018.
According to the FCC, the purpose of the new rules was to “simplify and reduce burdens associated with the equipment authorization process.” It is important to note that the Certification process itself remains unchanged. However, there are several key changes, including: 1) alterations to the manner of declaring conformity or verifying compliance with the FCC rules by combining two existing processes; 2) adoption of a new test method standard for licensed radio testing; and 3) rules for electronic labelling.
Prior to the new rules being published, the FCC had two different approval processes for digital devices, each with different requirements and labelling, and similar devices sometimes fell into different categories. This made it easy to mistakenly apply the incorrect approval process and bring a product to market with incorrect labelling. By combining the two existing processes into one new process that incorporates elements of both, with one set of labelling and information to user requirements, the FCC has now streamlined the approval process for digital devices and reduced the likelihood of errors occurring.
To make this happen, the FCC proposed, in July 2015, modifications to its approval processes. Its Notice of Proposed Rulemaking (NPRM) 15-170 combined the Verification and Declaration of Conformity approval methods that were in use at the time into one single process called Supplier’s Declaration of Conformity (SDoC). The new rules were officially released in November of 2017 under Report and Order 17-93 and immediately took effect. This allowed the new SDoC process to be used right away. Approvals under the previous processes continued to be available through November 2018, providing a one-year transition period. After November 1, 2018, the new SDoC process fully replaced both the Verification and the Declaration of Conformity processes.
Devices approved under the old processes may continue to be imported into the U.S. and its territories and may continue to be sold using their existing approvals and labelling. But, moving forward, approvals for new devices or approvals intended to address modifications of existing devices must be done under either the SDoC or the Certification processes and must meet their requirements.
Specifically, except when otherwise stated in a rule, an intentional radiator (transmitter) must be approved using the FCC Certification procedure. Unintentional radiators (digital circuitry) can be approved using either the SDoC procedure or the Certification procedure. Many modern connected devices such as mobile phones, notebook computers, tablet computers, and smart TVs are a combination of both transmitters and other digital circuitry, and therefore require both the Certification and the SDoC procedure. The exception is in those rare cases in which the digital circuitry has no function other than operating the radio. Since the SDoC procedure applies to non-radio digital electronics, the changes affect nearly every type of device that is subject to FCC approval.
The FCC requires certification for all devices containing an intentional radiator—or transmitter—although the agency no longer processes certifications itself. Instead a third-party telecommunications certification body (TCB) reviews and processes certification requests. The process for product certification includes three steps: testing, submission of documentation, and review by the TCB.
The product must now be tested at an FCC-accredited testing laboratory. Devices will be tested for electromagnetic compatibility (EMC) and telecom compliance according to the applicable FCC standards. Upon completion of the testing, reports of the testing results are added to the documentation compiled for certification.
The testing report is one of several required exhibits in the certification process. Additionally, there are several forms manufacturers will need to complete and submit as a part of the procedure:
- Form 731: Application for Equipment Authorization, approximately two pages in length and covering the contact information and equipment identification information, as well as any other requirements based on the product in question. It is used to determine compliance of the proposed equipment with FCC rules and requirements.
- Letter of Agency: A document authorizing an agent to act on behalf of the applicant/grantee contact of record (i.e., the manufacturer). The Letter of Agency is required only if an agent is used during the certification process, and it must be signed by the official grantee code contact of record.
- Request for Confidentiality: As suggested by the name, this portion of the application requests that information and materials submitted to the FCC be withheld from the public. Applicants must state the reasons for this request, and the document must be signed by the official grantee code contact of record.
- Authorization to Sign: Similar to the Letter of Agency, this authorizes another employee of the applicant other than the identified official contact of record to sign any documents as required by the FCC or TCB instead.
- Modular Attestation: This declares that the manufacturer is seeking FCC approval for a product acting as a limited or full modular transmitter. It cites the specific FCC rule to which the device adheres as well as all the requirements met under the rule and describes how the requirements are met. This exhibit is not required if the radio is not a module.
- Exhibits: These include additional documentation that describes how the product complies with the relevant FCC Rule requirements. Exhibits include:
- Test reports: Includes all data related to the device testing, including results.
- RF exposure information: Indicates the amount of radio frequency (RF) energy generated by the product to which users and other may be exposed.
- Test setup photos: Illustrate how the tests were
set up and conducted, to accompany the test
- Schematics: Representations of the elements of the electrical system and/or circuits. Schematics can be deemed confidential without requesting special approval.
- User manual: The proposed manual that end-users receive upon purchasing the product for use.
- Photos: Both internal and external photos of
- Block diagram: Diagram illustrating parts, components and or functions of the radio. Must show the frequency of each block and the intermediate frequencies between blocks. Can
be deemed confidential without requesting special approval.
- Radio operational description: Details how the radio functions within the device, the ground system and antenna, and should include tune-up information for licensed radios. Can be deemed confidential without requesting special approval.
- Label location and text: Illustrates where the label will appear on the product, as well as the included text.
TCB Review and Certification
All of the above documents, exhibits and related pieces of information are submitted to the TCB for review. The TCB reviews all the materials and, if it determines that the requirements have been met, the TCB issues a Grant of Authorization, certifying the product, after which it can be marketed and sold in the U.S. Note that approvals from other agencies may be required. Modifications can also be filed, called “Permissive Changes,” which only require a partial set of documentation covering the changes.
Certified products must bear a label affirming compliance with FCC requirements. The label includes the product’s FCC identifier, which is comprised of two parts: 1) the grantee code, made of 3 or 5 alphanumeric characters representing the applicant, or grantee, and which are the same for all filings; and 2) the product code, assigned by the grantee and made up of up to 14 alphanumeric characters, including dashes or hyphens. Sometimes, the label may include compliance language indicating with which FCC rule the product complies, depending on the rule part under which the device was approved.
Supplier’s Declaration of Conformity
The major change to the FCC approval process is found in the requirements applicable to devices or components that act as unintentional radiators, that is, non-radio electronics. Previously, this process varied, requiring either: a) a Declaration of Conformity for PCs, PC peripherals, certain industrial/scientific/medical devices, TV interface devices such as VCRs or Blu-Ray players, and various types of receivers; or b) a Verification, for all other devices. Now, all devices, regardless of type, are subject to the SDoC process.
In making this move, the FCC has simplified the process for self-declarations used for unintentional radiators. They have eliminated confusing questions related to which procedure a manufacturer or importer must follow. They have also simplified the process and, in most cases, retained the less burdensome requirements. These types of products are eligible for self-declaration because they present a low risk of interference compared to transmitters. The idea of self-declaration was to simplify the process for all involved, and it has been simplified even more with this singular approach.
The SDoC Process
Under the old Declaration of Conformity process, testing had to be performed by an accredited testing laboratory. This was not necessary for Verification, which could be tested at any lab that met the requirements in section 2.948 of the FCC rules. These labs were known as “2.948 listed labs” and had to be registered with the FCC. With the new SDoC process, laboratory accreditation is not required, and while the lab must still meet the requirements in section 2.948, it no longer has to register with the FCC.
Manufacturers can request the 2.948 compliance information from labs in order to verify that they are able to perform FCC testing. As with the certification process, the product will be evaluated for EMC compliance with the applicable standard, based on the product type. The test report must be kept on file and made available to the FCC upon request.
After completing the testing, the responsible party (manufacturer or importer) must prepare a compliance information statement to be included with the product. The statement must identify the product with a unique identifier that corresponds to the one that appears on the product, such as a model number or part number, list applicable compliance statements and identify the responsible party and their contact information. The responsible party must be located within the U.S. or its territories. This information must be supplied with the product in a manner consistent with the expectations of a typical user, such as in a manual, insert or electronic media, or provided online.
The responsible party must also prepare a label for the device that uniquely identifies it (product name, identification number and/or description). The party may also choose to apply an FCC logo, though this is not required under the SDoC process. It should be noted that, if the device is both an intentional and unintentional transmitter, such as a mobile phone or tablet, it will require an FCC ID for its FCC certification.
Once all the requirements for testing, marking and user information have been met, the responsible party can then legally market and sell the product in the U.S.
While the changes to self-declaration are the biggest changes to this process, the FCC has also adopted new guidance in other areas, notably for marking and labelling.
The FCC Logo
The FCC mark is now optional for any product subject to the SDoC process. Previously, it could only be used for devices approved under the Declaration of Conformity process, which caused a lot of confusion about when it was allowed and disappointing those parties who wanted to use it but couldn’t. This problem has now been eliminated by combining the processes and making the logo optional.
The FCC now allows electronic labelling (E-label) to be used instead of external product labelling for devices with integrated displays or which can only be operated in conjunction with a device that has a display. The information must be accessible within three steps (not including the device login). The responsible party must also include instructions on how to access regulatory information at the time of purchase. Examples would include a user manual, operating instructions, packaging materials or quick guide insert. The E-label must be programmed by the responsible party and secured so that third parties are unable to modify it. A temporary label that can be removed by the customer must be on the device or packaging at the time of sale, or the information may also be included in the user manual. If a temporary label is used, it must be able to survive the shipping process and must contain the label and regulatory information.
The following information can be electronically captured within an E-label:
- FCC ID and/or FCC Logo, if applicable
- Compliance statements to Rule 15.19
- Warning statements according to Rules 15.21 and 15.105
- Model number/Unique identifier
Information specifically required by a rule to be displayed on the product, packaging or signage cannot be electronic. For example, Rule 20.19(f) requires the display of a mobile handset’s hearing aid compatible (HAC) rating appear on the packaging. As such, this information cannot be provided electronically since the consumer would not be able to read it until after the product had been purchased.
In today’s world, electronic devices are everywhere, and both the risk and the impact of interference grows as more and more devices are manufactured and deployed. Proper regulation of the spectrum allows us all to enjoy the benefits of these innovative devices in our daily lives. As devices proliferate, the need for streamlined compliance solutions increases. The FCC rules changes are a step in this direction. A trusted partner with knowledge of the industry can help with the successful launch of products in this important market.
Nicholas Abbondante serves as chief EMC engineer at Intertek. In more than 18 years with the company, he has been involved in testing a wide range of radio and electronic equipment to EMC requirements for regulatory domains around the world, specializing in transmitters. He is a member of the TCB Council and participates in multiple ANSI C63 radio standards writing committees. He has a bachelor’s degree in physics from the Worcester Polytechnic Institute (WPI). Nicholas can be reached at firstname.lastname@example.org.
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