Peter,

 

There are three different approval processes used for digital devices under
the FCC Rules.  Verification, Certification and Declaration of Conformity. 
Which one you use depends on the product.  See FCC Rules 15.101a for a table
showing what process applies to what type of product.

 

Verification is a simple process where you use any lab that you, the
manufacturer, are convinced meets the requirements in Part 2 of the FCC Rules.
 Basically, is the lab equipped to perform the tests or not.  Once you have
data showing compliance you put the required label on the product, put the
required text in the user documentation and sell the product.  Verification is
used for class A devices (devices not marketed to the public for use in the
home – think servers and mainframes) and some limited class B devices (not
PCs or their peripherals).  

 

Certification is more complicated.  You must use an FCC Listed laboratory.  To
be Listed the lab submits paper to the FCC showing details of the test
facility demonstrating that they are equipped to do the testing.  Nothing said
about quality of processes or people, just the facility.  Once you have a test
report from the Listed lab, you submit an application to a 3rd party who
processes the paperwork for the FCC.  Costs you time and money.  Once approval
is granted you label the product, put the required text in the user
documentation and sell the product.  Certification may be used for class B
devices and is required for intentional radiators (like the WiFi unit in my
laptop).

 

Declaration of Conformity is the simplest for the manufacturer and the most
complicated for the lab.  You have your product tested in an accredited lab
located in a country acceptable to the FCC.  The lab must be accredited to
ISO/IEC 17025:2005 by A2LA or NIST NVLAP in the US or the accrediting body in
the country in which it is located.  Once you have data showing compliance,
you label the product, put the necessary text in the user documentation and
ship, much like Verification.  Different label, of course.  No submittal, wait
or fees as are required for Certification.  DoC is used for class B devices,
such as personal computers and their peripheral devices.

 

So, to answer your latest question, it depends.  Is your lab accredited to
ISO/IEC 17025:2005 and is it located in a country acceptable to the FCC?  If
so, data from it may be used for the DoC process.  If not, it cannot.  Is your
lab FCC Listed?  If so, the report may be used for the Certification process. 
If not, it cannot.  Finally, does your lab meet the requirements in Part 2 of
the FCC Rules?  If so, the data may be used for Verification.  If not, well I
think you get the idea.  From your original message it sounds like your lab is
FCC Listed.  In that case, it is good for Verification or Certification, but
not Declaration of Conformity.

 

I hope this helps.  A bit more long winded that some of the other replies, but
this isn’t a simple question suitable for a one sentence answer.  And, no, I
don’t work for a lab and I’m not trying to drum up business for our
in-house labs.  Best of luck to you.

 

Ghery S. Pettit

EMC Regulatory Compliance Manager

Corporate Product Regulations and Standards

Intel Corporation

 

Caveat – the opinions expressed in this message are my own and not
necessarily those of my employer.  Any errors will be blamed on ‘evil
spirits’ between my keyboard and the internet.  J

 

 

 

From: [email protected] [mailto:[email protected]] On Behalf Of
[email protected]
Sent: Friday, October 09, 2009 12:50 PM
To: [email protected]; [email protected]
Cc: [email protected]; [email protected]; [email protected]
Subject: Re: FCC site registration

 

Thanks guys for the info, but I guess my question is that what benefit this
site registration gives me if I can not test our product in our newly
registered site? I am bit confused between self delcration and DoC. Are they
different? and bottom line, can I use my own test data toclaim compliance?



From: [email protected]
To: Larry Stillings <[email protected]>
Cc: 'Grasso, Charles' <[email protected]>; [email protected];
[email protected]; [email protected]
Sent: Fri, Oct 9, 2009 12:20 pm
Subject: RE: FCC site registration

Plus accreditors that are part of the ILAC (?) MRA.

Barry C. Quinlan
Certification Manager
Bureau Veritas Consumer Products Services

Tel: +1 (978) 698 6155
Mobile: + 1 (978) 340 2547
Fax: +1 (978) 486 8828
Email: [email protected]
Web: www.cps.bureauveritas.com <http://www.cps.bureauveritas.com/> 
Address: Littleton Distribution Center,
One Distribution Center Circle#1, Littleton,
MA 01460, USA

[email protected] wrote on 10/09/2009 03:08:14 PM:

> I believe their are three accreditation bodies now for testing 
> laboratories, NVLAP, A2LA & ACLASS, that can be used for the DoC Process
>  
> Larry Stillings
> Compliance Worldwide, Inc.
> 
> From: Grasso, Charles [mailto:[email protected]] 
> Sent: Friday, October 09, 2009 2:58 PM
> To: [email protected]; [email protected]
> Subject: RE: FCC site registration

> The DoC process requires the use of an accredited (NVLAP) lab.
>  
> Best Regards
> Charles Grasso
> Compliance Engineer
> Echostar Communications
> (w) 303-706-5467
> (c) 303-204-2974
> (t) [email protected]
> (e) [email protected]
> (e2) [email protected]
> 
> From: [email protected] [mailto:[email protected]] On Behalf Of 
> [email protected]
> Sent: Friday, October 09, 2009 12:54 PM
> To: [email protected]
> Subject: FCC site registration
>  
> Hello Group,
>  
> Can someone let me know what does "Declaration of Conformity" means 
> in terms of FCC? We make simple ITE products without any radio. We 
> go to a 3rd party lab, get our product tested and get a report and 
> based on that we put the FCC mark on our product. Most of our 
> products are Class A stuff any way.
>  
> We now want to do this testing in-house using our own facility which
> was registered by FCC recently. The letter from FCC states that the 
> site is not authorized to perform testing under DOC process. What 
> does this means? Cannot we test our own product using our own lab 
> and self declare?
>  
> Thanks
> Peter
> -
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