Composite devices or systems operating under the provisions in Part 15 are subject to the approval requirements in Section15.31(k). If a composite device is subject to both Certification and DoC approval, the Certification filing should indicate that the device will also be DoC approved. The exhibits for the label in the Certification filing should show compliance with the Certification labeling requirements and the DoC labeling requirements. Additional DoC requirements, such as the compliance information in Section 2.1077 are normally not required, but may be requested at anytime by the FCC or a TCB.

Changes in the name, address, owership or control of grantee are subject to the requirments in 47 CFR 2.929. The grantee of a piece of equipment may make arrangements with different companies to manufacture that equipment, as long as it is identical to the unit which was approved and is labeled with the same FCC ID. The grantee remains responsible for the compliance of the device. Additional testing may be desirable to ensure that the device continues to comply.

The following information is a synopsis of confidentiality as it applies to an equipment authorization. More specific information on confidentiality processes may be found in the four attachments to this publication.
Confidentiality of Pending Application Exhibits:
When an application for equipment authorization of an RF device is filed with the FCC (or with a Telecommunications Certification Body (TCB) acting on behalf of the FCC) all of the information related to that application is confidential until the equipment authorization has been approved, and a grant of authorization to market is issued. Only the applicant, the applicant's agent (if applicable), and the FCC (or TCB) can access the information, using the combination of FCC ID and a randomly generated FCC Form 731 Confirmation Number.
If an application is filed with the FCC, an applicant may request deferral of the grant of authorization (See Section 0.457(d)(1)(ii)). Pending application information is not available for public inspection; therefore, the information related to the application will effectively be held confidential until the requested deferred grant date.
Confidentiality of Granted Application Exhibits:
Upon applying for an equipment authorization, there are two types of confidentiality that may be requested for certain exhibits within the application - permanent / long-term confidentiality which is intended to safeguard trade secrets in accordance with Sections 0.457(d) and 0.459 of the FCC rules; and short-term confidentiality which is intended to allow for the preparation of marketing of devices without disclosure of sensitive information to the public prior to actual sale of the devices. A table that describes the confidentiality requests accepted for both long-term and short-term confidentiality is attached.
Any exhibit not granted confidentiality is viewable on the Office of Engineering and Technology (OET) equipment authorization Web site as soon as a grant is issued. Applicants filing for an equipment authorization should be aware of the public availability of exhibits not marked confidential following the issuance of a grant of equipment authorization. Before a grant of equipment authorization is issued the applicant should ensure that (1) a sensitive exhibit is approved as confidential and (2) no confidential information is included in any non-confidential exhibit.
An FCC filed application requires only one confidentiality fee regardless of the number of exhibits requested held confidential, and regardless of whether the application contains a request for both Long-Term Confidentiality and Short-Term Confidentiality. There is no confidentiality fee payable to the FCC for an application filed with a TCB.
Attachment List:
726920 D01 Exhibit Confidentiality Table v01
726920 D02 Confidentiality Procedures Detail v01
726920 D03 Confidentiality FCC Submitted Apps v01
726920 D04 Confidentiality TCB Submitted Apps v01

Sections 2.1071 & 2.1077 contain the FCC Rules for a product subject to DoC.

Per Section 2.948 (d) and (e) of the FCC rules, in order for a DoC test report to be acceptable for a product to be marketed in the U.S., the testing must be performed at an ISO/IEC 17025 accredited test firm that is recognized by the FCC.
A list of recognized test firms appears on the FCC website at: https://fjallfoss.fcc.gov/oetcf/eas/reports/TestFirmSearch.cfm Select the "accredited" option to search for FCC recognized accredited test firms. For test firms that choose the "non-contract" option for their test site, the information regarding the FCC recognition is not publicly available.
For test firms outside the U.S., recognition is only possible for those test firms located in countries with which the U.S. has an operational Mutual Recognition Agreement (MRA).
For a test firm that has multiple facilities, the specific test facility used for the DoC testing must be a location assessed as part of the ISO/IEC 17025 accreditation, and the facility must be recognized by the FCC. Test facilities located in countries where the U.S. does not have an operational Telcom MRA are not recognized by the FCC. Therefore a test firm with facilities located in a country without an operational Telcom MRA may not use the facilities in the non-MRA country for DoC testing to FCC requirements.

Multiple FCC IDs for essentially the same equipment is permissible under 47 CFR 2.933 - Change in identification of equipment. The same equipment may be certified with different identification either under one applicant?s grantee code (three character prefix of the FCC ID assigned to an applicant) or for other applicants with different grantee codes, as long as all parties enter into an agreement. There are, however, no provisions for a change in FCC ID for equipment changes when only trade names or model numbers are changed.

Changes to certified equipment are subject to the permissive change requirements in 47 CFR 2.1043, which lists three types of permissive changes.
1. Class I: Equipment changes that do not degrade the data reported to the Commission.
2. Class II: Equipment changes that do degrade the data reported to the Commission.
3. Class III: Changes in software for Software Defined Radio Equipment.
Except for minor cosmetic changes, most changes to certified equipment require testing to determine whether the change is a Class I, Class II or Class III permissive change. Class II and Class III permissive changes must be reported to the Commission. The requirements for modification of equipment marketed under the Declaration of Conformity (DoC) program are contained in Section 2.1073(d). Retesting is also required for modification of the equipment.

Verification - Section 2.902 is a procedure where the manufacturer makes measurements or takes the necessary steps to ensure that the equipment complies with the appropriate technical standards. Declaration of Conformity - Section 2.906 is a procedure where the responsible party makes measurements or takes other necessary steps to ensure that the equipment complies with the appropriate technical standards. Certification - Section 2.907 is an equipment authorization issued by the Commission, or on behalf of the Commission, based on representations and test data submitted by an applicant. Specific guidance for filing an application for authorization under the certification procedure may be found Section 2.1033.

Section 2.1033(e) allows for the submittal of an application for Certification under multiple FCC Rule Parts.


back to FAQ page.