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RFID Device Suppliers: Beware the FCC's New Authorization, Marketing and Importation Rules

The Federal Communications Commission has voted to approve new rules impacting how RF equipment, manufacturers, vendors, importers and distributors may conduct business.
By Ronald E. Quirk

New Rules Are Just the Beginning of Equipment Regulatory Changes
The rules put forth in the R&O are only the start of many new regulatory changes for RF equipment suppliers. Rule changes affecting the following topics will be addressed in subsequent FCC proceedings: modular component certification, responsible parties for refurbished devices, software and firmware security requirements, and confidentiality of information contained in RF equipment certification applications.

"Self-Approval" Authorization for Non-Transmitting RF Devices

Current Rules
Most non-transmitting RF devices (unintentional radiators) are "self-authorized" by one of two procedures, depending on the specific type of the device: verification and declaration of conformity (DoC). These procedures are very similar, wherein the responsible party (RP) submits a prototype to a lab for testing for compliance with FCC technical rules. If the device passes, it is labeled and marketed. Nothing is submitted to the FCC unless audited. The main differences are that with a DoC, the RP must use an FCC-accredited testing lab, include a "compliance information statement" with each device, and include the FCC logo on the device's label.

New Rules
1. The elements of DoC and verification are now combined into a single procedure, known as the supplier's declaration of conformity (SDoC).

2. The FCC-accredited lab requirement for any device subject to SDoC has been eliminated.

3. The FCC logo is no longer required.

4. All devices subject to SDoC must contain lengthy compliance statements.

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