Clarification of FCC reporting rules for administrative product change

The US Federal Communications Commission (FCC) is the federal agency responsible for implementing and enforcing USA’s communications law and regulations. The agency regulates communications by radio, television, wire, satellite, and cable across the country.

Under their FCC Equipment Authorization Program, FCC has authorized a number of Telecommunication Certification Bodies, TCBs (including Nemko) to perform third-party certification of equipment subject to the FCC requirements.

Certification is required for products with high potential to cause harmful radio interference. It entails an equipment authorization issued by a TCB based on evaluation of the supporting documentation and test data submitted by the responsible party (e.g. the manufacturer or importer). The testing must be performed by an FCC-recognized testing laboratory.

E.g. mobile phones, notebook computers and tablets contain radio transmitters and hence require certification and authorization.

For product types considered less critical, Supplier’s Declaration of Conformity (SDoC) is an option for parties located in USA.

There has been some uncertainty about what changes to certified/authorized products need to be reported to the FCC/TCB for their records. Changes to products are regulated under FCC’s Permissive Change Rules.

It should be noted that under these rules, administrative changes to the certified/authorized products, such as change of model name (without changes to the product design), is regarded as a Class I Permissive Change and does not require a filing to amend the existing FCC ‘Grant of Authorization’.

One must ensure, however, that one’s internal records are kept updated accordingly

For further information, please contact Vina.Kerai@nemko.com  

(Article is based on text provided by Vina Kerai, edited by T.Sollie)