Brian,

> Our products also comply to the FCC class B requirements but we do not 
>     wish to go through the added cost and time to obtain an FCC grant or 
>     to have our products tested to an accredited test lab.
>     
>     I know I can self declare to FCC-A but would like to self declare to 
>     class B.  I have a problem with the last sentence in the required 
>     class A text; "Operation of this equipment in a residential area is 
>     likely to cause harmful interference in which case the  user will be 
>     required to correct the interference at their own expense". THIS WOULD 
>     BE A LIE because my product meets the class B requirements. If I self 
>     declare to class A, can I omit or change the last sentence to be more 
>     correct or reflex the fact that my product meets class B?

A matter of semantics but you do not self-certify against Class A, merely 
Verify.

There are certain class B devices that do not require certification and 
only require verification.  Section 15.101 details the requirements for 
various products. 
If your device does need certification then there are only two options:  
Declaration of Conformity (Accredited test lab report) or submittal. 
Unfortunately for you the wording requirements for user-manuals are 
directly related to the equipment authorization requirements.  You can 
only use the Class B wording IF you follow the Class B certification 
procedures or Class B verification procedures.  

>     
>     Why can't I self declare FCC class B? I'm not stating anything that is 
>     not true. Has anyone out there tried self declaring to FCC class B 
>     using test data from your own lab? If so, any suggestions on labeling 
>     and user manual text?
>   

Basically, you cannot self-declare that you meet Class B because CFR47 
Parts 2 and 15 do not allow you to do so.  What you could do is add a 
paragraph in your manual to include your European DoC showing you believe 
the unit meets Class B limits.  Anyone who actually needs to know the 
emissions levels from your unit will be able to see that you meet Class B.

Mark Briggs


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