Mark, A composite device as yours will be subject to FCC certification for the wireless device, and DoC if it can be used as a Class B Computer Peripheral device. All labeling and information to the user pursuant to both certification and DoC is required. >From FCC Part 15: Peripheral device. An input/output unit of a system that feeds data into and/or receives data from the central processing unit of a digital device. Peripherals to a digital device include any device that is connected external to the digital device, any device internal to the digital device that connects the digital device to an external device by wire or cable, and any circuit board designed for interchangeable mounting, internally or externally, that increases the operating or processing speed of a digital device, e.g., "turbo" cards and "enhancement" boards. Examples of peripheral devices include terminals, printers, external floppy disk drives and other data storage devices, video monitors, keyboards, interface boards, external memory expansion cards, and other input/output devices that may or may not contain digital circuitry. This definition does not include CPU boards, as defined in paragraph (bb) of this section, even though a CPU board may connect to an external keyboard or other components.
Bill Stumpf D.L.S. Electronic Systems, Inc. EMC Testing & Consulting 166 South Carter Street Genoa City WI, 53128 262-279-0210 This e-mail and any attachments may contain confidential material for the sole use of the intended recipient. If you are not the intended recipient, please be aware that any disclosure, copying, distribution or use of this e-mail or any attachment is prohibited. If you have received this e-mail in error, please contact the sender and delete all copies. Thank you for your cooperation ________________________________ From: [email protected] [mailto:[email protected]] On Behalf Of Pettit, Ghery Sent: Thursday, November 26, 2009 11:52 AM To: peter merguerian; [email protected]; Mark Gandler Subject: RE: Composite device per FCC 15.31 And it doesn’t really matter, anyway. Certification is still a legitimate way to authorize a digital device, so you don’t have to issue a DoC. I’d be careful about the TCB and lab. Ghery Pettit From: [email protected] [mailto:[email protected]] On Behalf Of peter merguerian Sent: Thursday, November 26, 2009 8:06 AM To: [email protected]; Mark Gandler Subject: Re: Composite device per FCC 15.31 Mark, My reading of 15.31 (k) is that a composite device is a " system that incorporates different devices contained within a single enclosure or in separate enclosures connected by wire opr cable". As such, your product is not considered a composite device. As you know, you can always get a ruling from the FCC. Best Regards, Peter --- On Wed, 11/25/09, Mark Gandler <[email protected]> wrote: From: Mark Gandler <[email protected]> Subject: Composite device per FCC 15.31 To: [email protected] Date: Wednesday, November 25, 2009, 9:21 PM Hi, In publication 584157 in FCC OET database, FCC states if you have composite device, which consist of devices under Certification and DoC, you must pursue both, including labeling, FCC logo and Warning text/ID. One of our test labs insist (they claim this comes from TCB) what we should treat wireless router/gateway as composite device, meaning Intentional radiator (wireless portion) done through certification and Ethernet/cable ports are treated as PC's peripheral, hence require DoC and logo on the label. In my opinion it does not make sense to treat wireless router/gateway as composite device. It is standalone device which performs multiple functions, but I do not see how can you treat Eth or cable port as separate device. Would be interested to hear some opinions. Happy Thanksgiving, Mark ________________________________ Windows 7: It works the way you want. Learn more. <http://www.microsoft.com/Windows/windo s-7/default.aspx?ocid=PID24727::T:WLMTA L:ON:WL:en-US:WWL_WIN_evergreen:112009v2> - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. 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