FCC Equipment Authorization for Importers: Part 15, SDoC vs Certification, FCC ID and Duty

FCC equipment authorization is the approval a radio frequency device needs before it can be marketed in the United States, and under the FCC’s rules marketing includes importation for sale. Almost every product a consumer electronics, LED lighting or electronics assembly importer brings in is a radio frequency device: anything with a clock signal, a switching power stage, Wi-Fi or Bluetooth. Part 15 of 47 CFR sets the technical limits, and Part 2 sets the two approval routes, Supplier’s Declaration of Conformity (SDoC) and Certification.

The import rule is short and puts the decision on the buyer’s side. Under 47 CFR 2.1203, no radio frequency device may be imported unless the importer, the ultimate consignee or their customs broker determines that it meets one of the entry conditions in 47 CFR 2.1204, and that party has to produce the documentation on request for a year after entry. Since November 2017 there is no FCC Form 740 to file. That makes the FCC file an internal record the importer must be able to hand over, not a form that a broker submits and forgets.

Part 15 Intentional vs Unintentional Radiators

Part 15 sorts devices by how they produce radio frequency energy, and the category decides the approval route. Under 47 CFR 15.3, an intentional radiator intentionally generates and emits RF energy by radiation or induction: a Wi-Fi speaker, a Bluetooth headset. An unintentional radiator generates RF energy for use inside the device, or sends it by conduction over wiring, without being designed to radiate it: a monitor, a USB hub, a switching power supply. An incidental radiator, such as a dc motor or a mechanical light switch, generates RF energy without being designed to produce it at all.

A digital device is a type of unintentional radiator that uses timing signals above 9,000 pulses per second and digital techniques. Part 15 then splits digital devices by market. Class A devices are marketed for commercial, industrial or business use and not to the general public; Class B devices are marketed for residential use, even if they are also used in offices. Class B limits are stricter, and the classification follows how the product is marketed, so an importer that sells a Class A device through consumer channels has a compliance problem regardless of the test report.

An LED driver with a switching power stage generates RF energy for use within the device, which is the 15.3 definition of an unintentional radiator. A smart LED fixture with a Wi-Fi or Bluetooth radio is both: an intentional radiator for the radio and an unintentional radiator for the rest of the electronics.

SDoC vs Certification: Which Devices Need Which

The two routes differ in who signs off. Under 47 CFR 2.906, SDoC is a self-declaration: the responsible party has the device measured, keeps the records and does not file anything with the FCC unless asked. Under 2.907, Certification is a grant issued by the FCC or by a Telecommunication Certification Body based on test data, and it produces an FCC ID listed in the FCC’s database.

The rules assign the route by device type. Section 15.201 requires Certification for intentional radiators, with narrow SDoC exceptions such as carrier current systems and certain low-frequency devices. For unintentional radiators, the table in 15.101(a) allows SDoC or Certification for most categories, including Class B personal computers and peripherals, Class B external switching power supplies, Class A digital devices and “all other devices”; scanning receivers, radar detectors and Access Broadband over Power Line need Certification.

Two Covered List points override the table. Equipment produced by an entity on the Covered List cannot use SDoC and must go through Certification under 2.906(d), and SDoC test records must include a signed certification that the equipment is not produced by a Covered List entity as of the date of first importation or marketing under 2.938(b)(2). Which entities and product types are on the list, and what is banned at import, is covered in our guide to the FCC covered list.

Who the Responsible Party Is When You Import

For Certification, the responsible party is the grantee. For SDoC, 47 CFR 2.909(b) makes the manufacturer responsible, or the assembler of a system, and if the equipment is imported, the importer. The SDoC responsible party must be located in the United States. That is the rule importers most often miss: a foreign factory’s declaration does not make the factory the responsible party for U.S. purposes, and under 2.1077 the compliance information statement supplied with the product at importation has to name a U.S. party with an address and a phone number or internet contact. Our article on the importer of record explains how that role is set on the customs side.

Records follow the responsible party. Section 2.938 lists what an SDoC test report must contain, from test dates and lab identity to setup photographs and the signature of an official of the responsible party, and sets retention: for certified equipment, one year after marketing of the product permanently ends, and a two-year period for the other records the section requires.

PCBAs, Modules and Subassemblies

Electronics assembly importers get the most relief from the rules and the most confusion. Under 15.101(d)(1), no authorization is required for a peripheral or subassembly sold to an equipment manufacturer for further fabrication; that manufacturer must authorize the finished product before it markets it. Under 15.101(e), subassemblies to digital devices, including non-PC CPU boards sold without an enclosure or power supply and switching power supplies marketed solely for use inside a device other than a personal computer, are not subject to the Part 15 technical standards unless marketed as part of a system. PC power supplies and CPU boards that are not separately authorized can be imported and sold only to a PC manufacturer that has said in writing it will authorize the computer.

Radio modules work differently. A host product built around a certified Wi-Fi or Bluetooth module relies on the module’s grant, and under 15.212 the host must carry an exterior label such as “Contains FCC ID” followed by the module’s FCC ID when the module’s own label is not visible. The host’s digital circuitry still needs its own SDoC or Certification as an unintentional radiator.

The FCC Import Conditions (47 CFR 2.1204) and What CBP Sees

Section 2.1204(a) lists the conditions under which a radio frequency device may be imported. Most commercial shipments rely on the first two: the device holds a valid FCC equipment authorization, or it does not need one and complies with the technical and administrative rules. The others cover specific situations, and each has limits an importer has to be able to prove.

Under 2.1204(b), the ultimate consignee must be able to document compliance with the condition it selected and the basis for selecting it, and under 2.1203(c) that documentation must be produced on request made within one year of entry. When the conditions are not met, 2.1203(b) lists the consequences: refused entry, refused withdrawal for consumption, required redelivery to the port and other administrative, civil and criminal remedies. The FCC eliminated the Form 740 import declaration in its November 2, 2017 order, so the rules no longer require a separate FCC declaration for each shipment. The determination and its evidence stay with the party that made it, and an FCC or CBP inquiry after release goes back to that party. At the port, an examination checks what is physically on the goods: the label, the packaging and whether the product matches the description.

• Testing and evaluation: up to 4,000 units for compliance testing, product development or market suitability, not for sale; larger quantities need written approval from the FCC’s Office of Engineering and Technology.
• Trade shows: up to 400 units for demonstration, not for sale.
• Import solely for export, U.S. Government use, repair, and up to three devices for personal use.
• Pre-sale activity for devices on the Certification track: up to 12,000 units with the same FCC ID, only after testing at an FCC-recognized accredited lab and submission of the application to a TCB, with a temporary removable label stating the device cannot be delivered to end users until certified, a retrieval process if certification fails, and records of every recipient kept for 60 months.

Labeling, FCC ID and E-Labeling

Certified devices carry an FCC ID. Under 47 CFR 2.925, the label shows the identifier preceded by “FCC ID” in capital letters, permanently affixed and readily visible to the purchaser, in type that need not exceed eight-point. If a device is too small for four-point type and has no display, the FCC ID goes in the user manual and on the packaging or a removable label.

Devices under SDoC or Certification also carry the Part 15 compliance statement in 15.19(a)(3): the device complies with part 15, may not cause harmful interference and must accept interference received. SDoC products ship with the compliance information statement required by 2.1077, which can sit in the manual or on a separate sheet.

E-labeling under 2.935 lets a device with an integrated screen, or one that works only with a device that has a screen, show the FCC ID and statements electronically, reachable in no more than three steps from the settings menu. The packaging still has to carry the FCC ID or information that identifies the device at importation, marketing and sale, which is the label a customs examination or a retailer audit will check.

Retail channels are tightening too. Under 2.803(c), online marketplaces will have to display a valid FCC ID at the point of sale for devices subject to Certification: from March 1, 2027 for marketplaces that hold title or physical possession, and from June 1, 2027 for the others, with exclusions for older unchanged listings, low-volume sellers and used devices. Sellers on those platforms should expect listings without an FCC ID to be challenged.

Tariff Lines for Common Electronics and LED Drivers

FCC authorization does not affect duty, but the same products sit on lines where origin swings the landed cost. The table shows typical lines with the MFN rate from the Harmonized Tariff Schedule and the additional duties our engine applies as of October 28, 2026: China Section 301 list duties and the Section 301 forced labor duty in effect since July 24, 2026, with its note 52(b) exemptions. Taiwan goods fall under a 10% floor: where the MFN rate is below 10%, the forced labor heading 9903.05.76 sets the duty at 10%. See our guides to Section 301 forced labor tariffs and Taiwan, or run your own lines in the China to US tariff calculator.

Notes on the Table

Totals are MFN plus additional duties and exclude antidumping and countervailing duties and product exclusions. The List 4A entry for subheading 8517.62.00 excludes statistical numbers 8517.62.0010 and 8517.62.0020, so the 10-digit number matters. Whether a given LED driver, PCBA or module belongs on these lines depends on its function and the machine it is built for, which is why classification and FCC review are best done together at the sample stage.

LED drivers and external power supplies can also fall under Department of Energy efficiency rules at import; see our article on DOE energy efficiency rules. For importers moving consumer electronics at volume, our licensed customs brokerage team can record the 47 CFR 2.1204 import condition you select with each entry.

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