FCC Certification, CE DoC vs FCC SDoC

Ellpee

Registered
Hi!

I've recently started working as a compliance engineer for a startup company manufacturing 3D-printers in Europe. I've received close to 0 handover from previous compliance engineers, and I'm now working on understanding how things have been done here before, and at the moment I'm looking at the FCC certification of the product.

So how previous compliance engineers claimed to be FCC compliant was that they CE certified the product, and then asked the EMC testing house used to also perform the EMC testing mandated by FCC 47 CFR Part 15 Subpart B. It then seems like that with the CE DoC and the EMC test report testing the FCC 47 CFR Part 15 Subpart B requirements, they claimed to have fulfilled the requirements of FCC certification and placed the FCC mark on the product.

However, when I'm reading up on FCC certification I don't really see how this could be a valid approach? I assume that our product would be classified as an RF Device that is an Unintentional Radiator. Reading section 15.103 of FCC, Part B it doesn't seem like our product can be considered to be an Exempted Device.

Maybe I just haven't read the correct paragraph, or I've missed something, but I don't see how there would any way around needing to have either a Supplier's Declaration of Conformity (SDoC) or a Certification from FCC?

To me it seems like the most reasonable approach would be to have a Supplier's Declaration of Conformity, but I assume that the CE DoC can not be used as a SDoC for FCC?
 
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