Section 15.103(b) CFR 47 (Exempted devices) exempts "A digital device used exclusively as an electronic control or power system" ... "in an industrial plant" from complying with the technical requirements of Subpart B. This means you don't have to do any testing and you do not need to label your product. You are however still subject to Part 15, specifically section 15.5 which requires you to correct any interference to licensed radio transmissions that your product causes in the field. Also, under section 15.29 you will need to comply with any commission request to evaluate your product (extremely unlikely, bordering on winning the lottery without betting).
The legal issues aside, you may still wish to test your products for marketing reasons. You may find compliance with the FCC limits to be a selling feature for your equipment. If you are meeting the European requirements, compliance with the FCC limits should be almost automatic, in fact the same test data can usually used to show compliance with both the FCC and European specs. Finally, the FCC reevaluates the exemptions on about a ten year cycle. Right now they "recommend" that your class of products comply with the technical requirements. Someday the FCC might extend coverage to your equipment. Jon D. Curtis, P.E. Director of Engineering email: [email protected] Curtis-Straus LLC phone: (508) 263-1897 409 Massachusetts Avenue fax: (508) 263-4164 Acton, MA 01720 http://world.std.com/~jdc/ USA On Wed, 24 Apr 1996 [email protected] wrote: > We're a manufacturer of industrial equipment. The equipment > goes into what the European EMC directive would classify as a > heavy industrial environment. We use a lot of electronics--PCs, > PLCs, sensors, etc--in our controls that are built into this > equipment. > > Question: do we have to comply with the FCC regs, Title 47 CFR > 15, subpart A (b), as an unintentional radiator? > > thanks! > Mike Sherman > Product Safety Engineer > FSI International > (612) 361-8140 > [email protected] >
