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Guidance Released by FCC for Radio Frequency Device Imports

Apr 25, 2018

The Federal Communications Commission (FCC) issued guidance on using a Supplier’s Declaration of Conformity (SdoC) when importing radiofrequency (RF) devices.

There are two current means used to show conformity with FCC requirements:

  1. FCC Certification is required for intentional radiator containing a radio transmitter.
    Examples include radio transmitters, scanning receivers, radar detectors, and access broadband over power lines (Access BPL).
  2. Supplier’s Declaration of Conformity (SDoC) are used for unintentional radiators using digital circuitry, and not containing a radio transmitter
    Examples include computer peripherals, microwave ovens, switching power supplies, light emitting diode (LED) light bulbs, and TV interface devices.

Party Responsible for FCC Compliance:

  • When using FCC Certification, the party responsible for compliance is the party to whom the grant of certification was issued.
    If the goods are modified by any party other than the grantee, who is not working under the grantee’s authorization, the party performing the modifications is responsible for FCC compliance.
  • When using a SdoC, the party responsible for compliance must maintain a presence in the U.S.
    The manufacturer, the assembler, or the importer is the normally the responsible party, but U.S. retailers or original equipment manufacturers (OEMs) may enter agreements with foreign manufacturers, assemblers, or importers, not located in the U.S., but must take on the liabilities of guaranteeing FCC compliance of the equipment.

A SDoC is not required to be submitted to the FCC, or filed with U.S. Customs and Border Protection (CBP) at entry, but the responsible party is required to provide any compliance information, such as test reports and equipment samples at no cost to the FCC, when requested by them.

The FCC will be updating the Harmonized Tariff Schedule (HTS) flags to aid importers in identifying FCC subject goods, but there will be no Automated Commercial Environment (ACE) filing requirements.
If you have any questions regarding the updated FCC requirements for imports of RF devices, Livingston can help! Please contact either your Livingston account manager or our regulatory affairs group at [email protected].