John, one of the issues is when does something stop being a component/module
that is not required to be tested and becomes a product that must be tested?
The module/device does not have a complete enclosure, nor did it include
power supplies, but it did include an antenna. The device with the antenna
is something that they will be selling to others, not just us, which is why
I called it off the shelf. 

The vendor sold us a "Development Kit" to use in the process of integrating
it into our printers. For us to buy such an item is no big issue as we do
have an engineering department and do have RF test capability up into the
10's of Ghz (including a 3 meter site). As they had a development kit, I was
asked if we could do the same. We have already told the vendor they must
certify the device, so we can base our certifications off of theirs. 

Thanks, for the article reference. We did have one of the TCB's request an
audit of one of our wireless products earlier this year and have been
audited by foreign governments in the past.

Jim


From: John Shinn [mailto:[email protected]]
Sent: Thursday, November 20, 2003 5:35 PM
To: 'Jacob Schanker'; 'Jim Bacher'; 'Emc-Pstc (E-mail)'
Subject: RE: RFID Demo Equipment and the FCC / Industry Canada


I'm not sure what you mean by a develpment kit.  Does that mean a prototype
unit with the intent 
to replace it later some time in the future?  Also, you used the phrase "off
the shell" - did you mean 
"off the shelf" and if so, why is an "of the shelf" device not complete with
the appropriate 
certifications?

As Jacob said, the FCC Rules are clear and trying to get around them by
trying to change 
the wording is not a safe way to go. 

Be realistic.  How do you know the unit will comply in the forseeable
future.  You may end 
up with products out there that cannot ever work at a reasonable cost.  Then
you would have to 
buy the products back from your customers, and maybe any equipment that is
no longer 
usable due to not having your printer and associated device legal.  

See Conformity, November 2003, Volume 8, No. 10, Page10, right column, and
then do it right. 

Regards, 

John Shinn, P.E.
Manager, Lab Operations
San Jose, CA


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