The FCC released several changes in rules four years ago impacting laboratories all over the world that perform testing of electronic devices subject to the Declaration of Conformity (DoC) and Certification approval procedures. One of the planned rule changes stated that after 12th July 2017, Telecommunications Certification Bodies (TCBs) would only be able to accept test reports from laboratories accredited to ISO/IEC 17025 by the FCC, or a designating authority which is recognized by the FCC through a Mutual Recognition Agreement (MRA). This meant that testing performed in support of Declaration of Conformity (DoC) and certification activity would be needed to have been ISO17025 accredited, and testing performed in non-MRA countries would not be accepted by Telecommunications Certification Bodies (TCB).
However, on June 14th 2016, a Memorandum Opinion and Order, FCC 16-74, was adopted which stated that laboratories already listed will be recognized for a further year, until 12th July 2017. This was intended to give sufficient time for eligible 2.948 laboratories to become accredited, so that the equipment development and manufacturing process would not be disrupted. Furthermore, FCC Docket 16-74 directed the FCC to publish a KDB with procedures for recognizing accreditation bodies and accredited testing laboratories in non MRA countries. KDB publication 974614 D02 contains the details. Testing laboratories in non-MRA countries must be assessed by an FCC recognized Test Firm Accrediting Body (TFAB). A TFAB must submit a request to the FCC to be recognized for each country that they want to assess labs in.
At this time, two US TFABs, A2LA and NVLAP have been granted FCC recognition to accredit laboratories in the People’s Republic of China, India, Philippines, and Thailand, who are testing in support of FCC Declaration of Conformity (DoC) and Certification. Therefore labs in the aforementioned counties would need to be accredited by A2LA or NVLAP and have their lab(s) recognized by the FCC and listed on the FCC Test Firms website as Accredited by the transition date (13th July 2017) in order for their FCC testing/reports to be acceptable from 13th July 2017. The FCC have stated that an FCC accredited lab cannot subcontract FCC testing to a non-FCC accredited laboratory if the testing is for Certification or DoC authorization purposes. FCC testing for Certification or DoC must be carried out in a laboratory location which is FCC accredited and listed on the FCC website.
What should manufacturers do?
The FCC actively enforces its own rules and penalties can be severe. Manufacturers should ensure that the laboratories they are using for FCC Certification and DoC testing are FCC accredited by the 12th July 2017 deadline. If you are in doubt about the FCC rules, seek guidance from a company experienced in dealing with FCC matters, such as TÜV SÜD.
Globally TÜV SÜD are able to support customers from the US, Canada, Europe, Japan, Singapore and China. Multiple TÜV SÜD laboratories in China have been successfully audited in 2016 by US TFABs in preparation for these new rules and are most ready to provide continued FCC services with the aim of being listed as FCC accredited laboratory locations for FCC testing in the near future.
If you have questions about how the new rules and pending deadline will impact your exiting approvals or future testing needs, please contact us. With experts at over 850 locations Worldwide TÜV SÜD is prepared to offer advice and solutions.