Bottom line:
- When a US buyer asks for FCC, an FCC ID or SDoC, they want equipment authorisation before a radio-frequency device is imported or marketed in the United States. CE, RED, a Trade Assurance order and a Verified audit will not write that sentence.
- The FCC has two paths. Certification is tested at a recognised lab and issued by a TCB; the database holds an FCC ID. SDoC keeps test records with a US-based responsible party; it is not listed and does not receive an ID. The official path is FCC Equipment Authorization.
- Opening a Hong Kong store does not issue an FCC ID. The SDoC responsible party must be in the United States. Testing and certification follow the lab and the TCB quote. There is no official US-dollar price.
The inquiry says: “Need FCC certificate before PO.” Sales staples a CE, a RoHS sheet and a Trade Assurance screenshot. The buyer replies that none of that is American. The shop floor asks whether to print “FCC” on the carton or retest the whole unit.
How a California warning is written is on Prop 65. Who stands as importer at CBP is on IOR. The Union safety contact is on GPSR Responsible Person. The US radio box is the one that stops this order: which authorisation path, where the number comes from, and whose name is the responsible party.
1. The “certificate” they want may not be a certificate
47 CFR Part 2 requires applicable radio-frequency devices to complete equipment authorisation before they are imported into or marketed in the United States. The Office of Engineering and Technology runs two procedures. The phrase “FCC certificate” in a buyer email often stacks both paths onto one sheet.
| What they say | What it is | Issued with a Hong Kong store? |
|---|---|---|
| FCC ID | The number a TCB writes into the FCC database after Certification | No. Intentional radiators take this path |
| FCC / SDoC / Supplier DoC | A supplier’s declaration for unintentional radiators; the responsible party must be in the US | No. Not listed, and no FCC ID |
| CE / RED / DoC | EU product-safety and radio directives | No. They will not fill a US authorisation box |
| Trade Assurance / Verified audit | Order terms and a factory system | They do not authorise radio equipment for the US |
The FCC states that, unless a rule says otherwise, an intentional radiator (a transmitter) takes Certification and an unintentional radiator (digital circuitry) takes SDoC. A phone, a wireless card or a notebook with Wi-Fi often has both functions and both procedures. Split the unit: does it transmit, and on which band, before you decide whether the buyer wants an ID or a statement.
2. Only Certification receives an FCC ID; SDoC does not
Certification is the stricter path. Testing is done at an FCC-recognised accredited laboratory. The application goes to an FCC-recognised Telecommunication Certification Body. After a grant, technical parameters and a description appear in the Commission’s public database. The FCC ID on the device can be checked at FCC ID search. When a buyer asks for a “certificate,” the database page and the grant file travel better than a homemade PDF.
SDoC does not require an application to the Commission or a TCB, so the equipment is not listed and does not receive an FCC ID. The responsible party must ensure the equipment meets the technical standards and must produce a test report and other records if the Commission asks. A device that may use SDoC can instead take Certification. A transmitter that must take Certification cannot be replaced by a homemade declaration.
An SDoC lab need not be FCC-recognised, but it must keep measurement-facility records and measurement records under the rules. Retitling a CE test report usually misses the measurements the FCC wants.
3. The responsible party must be in the United States
The FCC writes the responsible party as the manufacturer, the assembler, or, on import, the importer. That party must maintain a United States presence. A US retailer or OEM may take the liability in writing and become the new responsible party. The compliance information shipped with the equipment must name the responsible party, a United States address, and a telephone or internet contact.
The import path is FCC Equipment Authorization – Importation. Under SDoC the importer becomes the responsible party, must be in the United States, and must leave contact details on the end-product papers. Under Certification the responsible party is the grantee; an importer may rely on a foreign manufacturer’s grant, but a compliance problem can still land on the grantee.
Opening Alibaba.com on a Hong Kong company does not create a US-based responsible party. A forwarder’s US address, a buyer warehouse and a forwarded mailbox are not names you print on the product. Who stands as importer is on IOR. A DDP quote does not issue an FCC ID and does not appoint a US responsible party.
4. How a shop-floor report answers the buyer form
Ask first whether the unit transmits: Bluetooth, Wi-Fi, cellular, remote control and a wireless-charging coil can all push the device onto Certification. A switch-mode supply and digital circuitry with no transmit function more often take SDoC. For a wearable, a lamp controller or a small appliance, finish the radio question before the transport question. Transport is on batteries.
Certification: the lab must sit on the FCC-recognised list. Reports, photos, circuit notes and the label drawing follow the TCB list that day. The FCC ID format and placement follow the rules. Do not hand-write “FCC” next to a CE mark.
SDoC: keep the test report, the compliance information statement, and the US responsible party’s name and address. The Commission may request samples and records. The file travels with the goods. Do not leave it in a sales inbox.
A changed antenna, a changed module or a changed main board may take the grant out of coverage. A module that already has an FCC ID still leaves the host to show how it uses that module. If the buyer wants “the same report as last year,” match the hardware version before you forward the old PDF.
5. Authorisation is due before import or marketing, not after arrival
The FCC has said applicable devices must meet the technical rules and complete authorisation before they are imported or marketed in the United States. Form 740 stopped in 2017; the authorisation itself did not. Evaluation and trade-show imports have their own conditions under § 2.1204 that day. A sample carton is not a retail authorisation.
A Trade Assurance order that ships to the US is not an equipment authorisation. A Verified audit looks at the factory system; it does not measure radio. Prop 65 answers a California warning; that page is Prop 65. All four can sit on one PO. The files still travel in separate folders.
A CBP hold or a buyer refusal often means: the device needed an FCC ID and only had CE; the SDoC responsible party was a Hong Kong address; or the claimed ID was not in the database. The fix is the correct procedure, not a printed number that does not exist.
6. How the inquiry can be answered
| They write | A usable reply | Do not write |
|---|---|---|
| Send FCC certificate / FCC ID. | Please confirm whether this unit transmits. If it does, it takes Certification; after a grant the FCC ID can be checked in the FCC database. Digital circuitry with no transmit function takes SDoC: no FCC ID, and the responsible party must be in the United States. | Retitle a CE declaration as an FCC certificate. |
| You have CE/RED, so it can sell in the US. | CE / RED is the EU path. Import or marketing in the United States needs FCC equipment authorisation. Two labs, two files. | CE means ready for the US. |
| Put our company as FCC ID holder on your store. | An FCC ID sits on the person who received Certification. An SDoC responsible party must be in the United States. A buyer’s name cannot fill a Hong Kong seller’s showcase as already authorised. | Borrow the customer’s number for now. |
| DDP; FCC is in the freight. | DDP says who clears and pays duty. Equipment authorisation is a condition before import or marketing. It is not an official freight line. Lab and TCB charges follow their quotes. | DDP includes every US certificate. |
Do not write “FCC passed” or “US certified” on a showcase. You can say the seller is a Hong Kong company, that radio functions are described by model, that files follow Certification or SDoC, and that the US responsible party follows the import arrangement.
7. If you already replied “we have FCC”
- Tell sales the same day: prices that say “ready for the US / certified” stop.
- Open this US order: does it transmit, does the buyer want an FCC ID or SDoC, and who is the importer.
- Keep CE, Prop 65, IOR and transport papers as their own files. Do not merge and retitle.
- If you will take Certification: use an FCC-recognised lab and a TCB. Do not hand the master account to an intermediary. If you will take SDoC: name the US-based responsible party first.
- If the goods are already moving: send the authorisation or statement that matches. Do not invent an FCC ID to pass a review.
The membership still buys the file and the showcases. Wire it to ALIBABA.COM HONG KONG LIMITED. Corpable does not file FCC applications, sit as the US responsible party or pay lab fees. What the Commission samples, and whether a TCB grants, follows their process that day. Do not write a penalty figure into the contract.
Questions teams actually ask
Do CE and RED count as US FCC?
No. CE answers conformity under EU directives. A radio-frequency device must complete FCC equipment authorisation — Certification or a Supplier’s Declaration of Conformity — before it is imported or marketed in the United States. Two rulebooks, two lab paths.
Does opening Alibaba.com on a Hong Kong company issue an FCC ID?
No. The membership buys showcases, not a US equipment authorisation. An FCC ID appears only on the Certification path. An FCC-recognised Telecommunication Certification Body issues it, and it can be checked in the FCC database.
Does every electronic product need an FCC ID?
No. Intentional radiators generally take Certification and receive an FCC ID. Unintentional digital circuitry usually takes SDoC: no database entry, no FCC ID. A machine with Wi-Fi may need both.
Can the SDoC responsible party be the Hong Kong company?
No. The FCC requires the SDoC responsible party to be located in the United States. On import, the importer typically becomes that party and leaves a US address and contact on the product papers.
Can the showcase say “FCC passed / ready for the US”?
Not without a matching FCC ID or an SDoC responsible-party file. Lab quotes follow the model and the tests. There is no site-wide official US-dollar price. Writing “certified” will be screenshotted back at you.
Can Corpable file FCC for us, or guarantee a US order will clear?
No. An advisor can help you see whether the buyer wants an FCC ID or an SDoC statement. We do not file with a TCB, sit as the US responsible party or promise a customs or buyer review. Membership fees still wire to ALIBABA.COM HONG KONG LIMITED.
Related reading
- UL: CE is not a US workplace mark
- Prop 65: a CE file will not write that warning
- FDA: food and cosmetics have no such certificate
- US duty-paid: the forwarder is not the importer
- EU Responsible Person: a Hong Kong address is not enough
- Batteries: the transport gate
- Contact Corpable · info@aliad.hk
Written by Corpable Marketing Limited for Alibaba.com Hong Kong-channel sellers. Not legal, tax, or audit advice. Platform, customs, bank, and auditor outcomes follow the latest official notices. Membership fees go to ALIBABA.COM HONG KONG LIMITED. Corpable does not collect them.