The Declaration of Conformity process in the US has two different options for personal computers.

The first is used if the PC was tested for compliance with the FCC limits for radiated and conducted emissions.  This testing must have been performed in an accredited laboratory physically located in a country acceptable to the FCC.  In the US there are 4 acceptable accrediting bodies to choose from.  These are the American Association for Laboratory Accreditation (A2LA), the National Institute of Standards and Technology National Voluntary Laboratory Accreditation Program (NIST NVLAP), ACLASS and the Laboratory Accreditation Bureau (LAB).  The list of accredited labs on the FCC’s web site shows labs in the US, Australia, Canada, EU, Hong Kong, Israel, Japan, Singapore, South Korea and Taiwan.

Once the manufacturer or importer has data from such a laboratory showing compliance the approval marking may be placed on the product and the product sold in the US.  The mark looks like the following:

FC 1

The Trade Name and Model Number are provided by the vendor (manufacturer or importer) and commonly may be located elsewhere on the product label.  I have seen an example where the manufacturer duplicated this label exactly with the words “Trade Name” and “Model Number”.  This isn’t correct.

The second option for a personal computer is to assemble the computer from authorized parts.  Under this option the completed system is not tested.  The documentation for each part requiring authorization is gathered into a file to be kept by the integrator and a different form of label is placed on the product.  This label indicates that the system was assembled from approved parts and that the complete system was not tests.  This label looks like the following:


Again, note that a Trade name and Model number must be provided by the integrator.

It should be noted that the person signing the Declaration of Conformity associated with either of these options must be located in the US.  It is not permissible under the FCC Rules for this person to be located outside the US.

What other information must be provided with the product when approved under the Declaration of Conformity process?

Title 47 of the Code of Federal Regulations, Part 15.19(a)(3) requires that the following text be placed in the user manual for products approved via the Declaration of Conformity process:

“This device complies with Part 15 of the FCC Rules.  Operation is subject to the following two conditions: (1) this device may not cause harmful interference, and (2) this device must accept any interference received, including interference that may cause undesired operation.”

Note that this is one of the very few places in the FCC Rules that deals with immunity to interference on the part of Part 15 devices.  And the FCC isn’t providing any protection against interference to such devices.  Also, this same text would appear on the product (not in the manual) for products approved under the Verification or Certification processes.

Title 47 of the Code of Federal Regulations, Part 15.105(b) requires another statement in the user manual for class B devices (which includes all products which may be authorized under the Declaration of Conformity process.  This statement is to be provided in the user manual and states:

“This equipment has been tested and found to comply with the limits for a Class B digital device, pursuant to Part 15 of the FCC Rules.  These limits are designed to provide reasonable protection against harmful interference in a residential installation.  This equipment generates, uses and can radiate radio frequency energy and, if not installed and used in accordance with the instructions, may cause harmful interference to radio communications.  However, there is no guarantee that interference will not occur in a particular installation.  If this equipment does cause harmful interference to radio or television reception, which can be determined by turning the equipment off and on, the user is encouraged to try to correct the interference by one or more of the following measures:

—  Reorient or relocate the receiving antenna.

—  Increase the separation between the equipment and receiver.

—  Connect the equipment into an outlet on a circuit different from that to which the receiver is connected.

—  Consult the dealer or an experienced radio/TV technician for help.”

Note that this statement provides the user with some basic suggestions about what to do if interference from the product is suspected.  When this statement was first provided in the FCC Rules in the late 1970s I suspect that there were far more experienced radio/TV technicians available to the public that there are today, but this is a valid suggestion.

There is one more bit of information that must be provided to the user.  Title 47 of the Code of Federal Regulations, Part 15.21, requires:

“Information to user. – The users manual or instruction manual for an intentional or unintentional radiator shall caution the user that changes or modifications not expressly approved by the party responsible for compliance could void the user’s authority to operate the equipment.”

Note that this does not provide specific text, but does provide the message that is to be conveyed to the user by the manufacturer.  Don’t make changes to the product that weren’t authorize by the responsible party or you could be forced to stop using the product.