Are you confused by the Federal Communications Commission’s (FCC) new streamlined Declaration of Conformity (DoC) authorization procedure, Report and Order in ET Docket No. 95-19? If so, you may not be alone.
The intent of this procedure is to help manufacturers and importers of digital devices get their products to market in a more timely manner. It is truly a helpful document. But because of the vast amount of information needed to make it worthwhile, your introduction to this material could overwhelm you.
Before the procedure became effective on Aug. 19, 1996, the FCC required all personal computers and associated peripherals to be certified by filing an application with the Commission. It generally took more than 30 days for the Commission to act upon the application and cost $845 in fees. The manufacturer was not allowed to sell the product until a grant of authority was issued.
The most important aspect of the new procedure is the time-to-market savings of at least 30 days per product. This procedure does not reduce the requirements or obligations of the manufacturer. The manufacturer or importer, if the device is foreign made, must still determine whether the product complies with the requirements.
Some of the important points of the procedure include the compliance information statement and the DoC. It also defines the obligation of the person signing the DoC.
A product is tested the same as in the past, except that an accredited test lab is required. At this time, accreditation means NVLAP or A2LA. The laboratory must be located in the United States or a country having a mutual recognition agreement (MRA) with the United States. Until Aug. 19, 1997, the FCC is permitting labs with pending accreditation requests to perform DoC testing.
Responsible Party
Section 2.909 of the FCC rules defines the responsible party and how the party is responsible for the compliance of radio frequency equipment with the applicable standards. For equipment that requires a grant of equipment authorization from the Commission, the responsible party is the entity to whom that authorization is granted (referred to as the grantee).
In the case of equipment subject to authorization under the verification procedure, the manufacturer (or in the case of imported equipment, the importer) is the responsible party. When the equipment is subject to authorization under the DoC procedure, the responsible party is:
The manufacturer or, if the equipment is assembled from modular components that were subject to a DoC and the resulting system is subject to authorization under a DoC, the assembler.
The importer if the equipment, by itself, is subject to a DoC and that equipment is imported. Remember, if a product is imported, the importer is the responsible party, not the foreign manufacturer.
Obligations
According to the FCC Rules for self-certification of a product using the DoC, the manufacturer has the following obligations:
Compliance Information Statement—A statement must be shipped with each product. This can be accomplished either as a separate document shipped with the product or as part of the instruction manual accompanying the product.
The choice of address and phone number listed on the compliance information statement is very important. The FCC expects this party to respond in 14 days if there is a problem.
Retention of Records—Except for equipment authorized using modular components that were individually subject to a DoC (see 2.1077(b) of the FCC Rules), for each product subject to a DoC, the responsible party (as shown in Section 2.909 of the FCC Rules) must maintain the following records:
The record of the original design drawings, specifications and all changes that have been made which might affect compliance with the requirements.
A record of the procedure used for production inspection and testing (if additional tests are performed) to ensure conformance.
Record of measurements made on an appropriate test site that demonstrates compliance with the regulation. The record of measurements should contain:
a) The actual date or dates testing was performed.
b) The name of the test laboratory, company or individual performing the testing. The Commission may request additional information regarding the test site, the test equipment or the qualifications of the company or individual performing the tests.
c) A description of how the device was actually tested, identifying the measurement procedure and test equipment that was used.
d) A description of the equipment under test (EUT) and support equipment connected to, or installed within, the EUT.
e) The identification of the EUT and support equipment by trade name and model number and, if appropriate, by FCC identifier and serial number.
f) The types and lengths of connecting cables used and how they were arranged or moved during testing.
g) At least two photographs showing the test setup for the highest line-conducted emission and the test setup for the highest radiated emission. These photographs must show enough detail to confirm other information contained in the test report.
h) A description of any modifications made to the EUT by the testing company or individuals to achieve compliance with the regulations.
I) All of the data required to show compliance with the appropriate regulations.
j) The signature of the individual responsible for testing the product along with the name and signature of an official of the responsible party, as designated in Section 2.909 of the FCC Rules.
k) A copy of the compliance information, as described in Section 2.1077 of the FCC Rules, required to be provided with the equipment.
All records should be in English.
The records (technical file containing the DoC and the compliance information statement) must be retained for at least two years after manufacturing has been discontinued or after the conclusion of an investigation or a proceeding involving the equipment.
The technical file and test data must be provided within 14 days of delivery of a request from the FCC. (This would not normally be requested.)
Testing—Testing of your product must be performed at an accredited testing laboratory located in the United States or a country having an MRA with the United States.
Labeling Requirements
Besides preparing the records in support of the DoC, you also must supply the label (Section 15.19) (Figure 1). For products authorized, based on assembly using separately authorized components and the resulting product is not separately tested, a different label is required.
The label must be located in a conspicuous location on the device and must contain the unique identification. Devices subject only to a DoC must be identified by the responsible party. This identification must not be of a format which could be confused with the FCC identifier required on certified, notified, type-accepted or type-approved equipment.
The responsible party must maintain adequate records to facilitate positive identification for each device. Basically, use the label with a unique trade name and model number and have each device contain a serial number.
When a device is constructed in two or more sections connected by wires and marketed together, the label is required to be affixed only to the main control unit.
When the device is too small or when it is not practical to place the statement specified on it, the required information may be placed in a prominent location in the instruction manual or pamphlet supplied to the user or be placed on the container in which the device is marketed. However, the FCC identifier such as the logo and unique identification (trade name and model number) must be displayed on the device.
The label must not be a stick-on paper label. The label on these products must be permanently affixed to the product and be readily visible at the time of purchase. “Permanently affixed” means that the label is etched, engraved, stamped, silk-screened, indelibly printed or otherwise permanently marked on a permanently attached part of the equipment or on a nameplate of metal, plastic or other material fastened to the equipment by welding, riveting or a permanent adhesive. The label must last the expected lifetime of the equipment in the environment in which the equipment may be operated and must not be readily detachable.
Information to the User
This statement must be placed in the User’s Manual or Instruction Manual (Section 15.21): “The user is cautioned that any changes or modifications not expressly approved by the party responsible for compliance could void the user’s authority to operate the equipment.”
For a Class B digital device or peripheral, the instructions furnished to the user shall include this statement, placed in a prominent location in the text of the manual (Section 15.105):
“Note: This equipment has been tested and found to comply with the limits for a Class B digital device, pursuant to Part 15 of the FCC rules. These limits are designed to provide reasonable protection against harmful interference in a residential installation. This equipment generates, uses and can radiate radio frequency energy and, if not installed and used in accordance with the instructions, may cause harmful interference to radio communications. However, there is no guarantee that the interference will not occur in a particular installation. If this equipment does cause harmful interference to radio or television reception, which can be determined by turning the equipment off and on, the user is encouraged to try to correct the interference by one or more of the following measures:
Reorient or relocate the receiving antenna.
Increase the separation between the equipment and receiver.
Connect the equipment into an outlet on a circuit different from that of the receiver.
Consult the dealer or an experienced radio/TV technician for help.
If shielded cables were used to show compliance, the following statement must also be added (Section 15.27 of the FCC Rules): “Note: This unit was tested with shielded cables on the peripheral devices. Shielded cables must be used with the unit to ensure compliance.”
Acknowledgment
The author thanks David Hilliard of Wiley, Rein & Fielding, Washington, D.C., for his help in reviewing this article.
Disclaimer
D.L.S. Electronic Systems and/or its employees are not and cannot give legal counsel on this information. This article is intended to assist anyone needing instructions and a simplified direction.
About the Author
Donald Sweeney is the owner of D.L.S. Electronic Systems. He is a graduate of the University of Illinois Department of Electrical Engineering and is a certified EMC engineer through NARTE. Currently, Mr. Sweeney teaches at the University of Wisconsin, serves on the Board of Directors of the IEEE EMC Society, chairs the Chicago Chapter of the EMC Society and is founding chairman of USCEL. D.L.S. Electronic Systems, 1250 Peterson Dr., Wheeling, IL 60090-6454, (847) 537-6400.
DoC box
This device, trade name____________, model number__________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.
I have determined and warrant that the above described device has been shown to comply with the requirements of the FCC Part 15, by having a device tested at an accredited testing laboratory. Each unit marketed is identical to the device as tested. Compliance assumes no unauthorized changes will be made to the equipment and it will be maintained and operated properly. A test report has been generated. A technical file containing the test report will be maintained for a period of at least 2 years after manufacturing ceases. It is also understood that any changes to the device which could adversely affect the emission characteristics of this equipment will require retesting.
_______________________for
Title
Company Name
Street Address
City, State, Zip, Country
Telephone Number
Note: This is to be in the test report.
Statement
This device, trade name_____________, model number___________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.
The responsible party for this device compliance is:
Company Name
Street Address
City, State, Zip, Country
Telephone Number
Note: This is to accompany the product either as a loose sheet in the box or in the instruction manual supplied with the product.
Copyright 1996 Nelson Publishing Inc.
November 1996
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