As I’ve always interpreted that sentence both John and Scott are correct, sort of. Scott is correct in the translation of the sentence. John is correct in the ramification. But since a device has no requirements it can’t technically fail the requirements. The common terminology on contracts for subassemblies that are purchased to be included in a device that does have a requirement is something on the order of “…. Must allow end unit to meet the requirements of XYZ specification….” The phrase is important because if purchased under those conditions then if they can lay the blame at your feet you get to pay for making the hardening the component so that the end unit may in fact meet the requirements and you will likely be billed for testing to verify that your improved device does allow for end unit compliance. If it isn’t purchased with such a requirement the end result may be even less agreeable to you. A component that doesn’t allow the end unit to meet its goals is replaced with on that does and not purchased.
Bottom line is that I don’t think you have any obligations you may want as a minimum set up tests to determine that an end user won’t run into a problem. Your pretty close to a cable assembly but you actively do things with the signals generated by others. This is the kind of information you get for free ☺ Gary From: John Shinn [mailto:[email protected]] Sent: Wednesday, July 17, 2013 9:47 PM To: [email protected] Subject: Re: [PSES] EMC Required? Scott: I think you are correct, but for the wrong reasons. As I understand your product, it apparently is a small IR detector circuit (board?) which will be sold to an OEM for incorporation into their product such as a TV for use in changing channels, etc.. In all probability, the power for your unit is provided by the OEM, so you unit is sold without a power supply or battery. Therefore, you would not need to have an EMC Certification on the unit itself. However, you may be required to make sure it does not cause the OEM’s product to NOT comply with the applicable EMC Requirements. Hopefully I have described your product and your marketing position sufficiently. Regards, John Shinn, P.E. Retired From: Scott Douglas<mailto:[email protected]> Sent: Wednesday, July 17, 2013 7:43 PM To: Grace Lin<mailto:[email protected]> Cc: Bill Owsley<mailto:[email protected]> ; [email protected]<mailto:[email protected]> Subject: Re: EMC Required? Grace and Bill, Here is an excerpt from the FCC Rules: 15.3 Definitions (k) Digital device. (Previously defined as a computing device). An unintentional radiator (device or system) that generates and uses timing signals or pulses at a rate in excess of 9,000 pulses (cycles) per second and uses digital techniques; Semantic argument coming. My device previously described does not generate the pulses. It may transform these pulses but does not generate (create) them. Reading the sentence above the operative terms are generates AND uses. And, because of the AND, since we do not generate then it makes no difference if we use the signals. My translation is we do not generate therefore Part 15 does not apply to this specific product. Okay, Kevlar donned, looking for arguments. Best to all, Scott On 7/15/2013 4:38 AM, Grace Lin wrote: Bill and Scott, Since the operating frequency is higher than 9 kHz, FCC Part 15, Subpart B-Unintentional Radiators applies. It is my understanding that an IR device doesn't need certification. I hope this helps. Best regards, Grace Lin On Fri, Jul 12, 2013 at 9:51 PM, Bill Owsley <[email protected]<mailto:[email protected]>> wrote: For the USA, any electrical signal above 9 kHz meets the requirement to be tested. I think we will find similar for the EU. EN 300 330, or 300 440, or something like that. It has power and a switch and generates frequencies above the lower limit - it gets tested. ps. that means the device will need to be activated into its operating condition for testing. But if there is an exclusion list... I'm very interested! ________________________________ From: Scott Douglas <[email protected]<mailto:[email protected]>> To: "[email protected]<mailto:[email protected]>" <[email protected]<mailto:[email protected]>> Sent: Friday, July 12, 2013 9:47 AM Subject: EMC Required? Hi folks, Consider a simple circuit. IR diode, a transistor or two, some resistors and caps. Receives input from IR remote, converts to electrical and sends down a wire. No clock in the thing so you could call is passive. But does it need EMC testing for US or EU? The IR signal will be in the 35-50 kHz range so pulses down the wire will be the same. Does this make it fit within the realm of EMC required? The device is sold by itself without other products, but is always connected to something else in use. Something else could be a wide variety of anything. I think of it like a stand-alone audio speaker. Purely a passive device that is driven by signals that fall within the EMC required realm. So do you do EMC or not? Looking forward to your opinions on this. Scott - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <[email protected]<mailto:[email protected]>> All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <[email protected]<mailto:[email protected]>> Mike Cantwell <[email protected]<mailto:[email protected]>> For policy questions, send mail to: Jim Bacher: <[email protected]<mailto:[email protected]>> David Heald: <[email protected]<mailto:[email protected]>> - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <[email protected]<mailto:[email protected]>> All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <[email protected]<mailto:[email protected]>> Mike Cantwell <[email protected]<mailto:[email protected]>> For policy questions, send mail to: Jim Bacher <[email protected]<mailto:[email protected]>> David Heald <[email protected]<mailto:[email protected]>> - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <[email protected]<mailto:[email protected]>> All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <[email protected]<mailto:[email protected]>> Mike Cantwell <[email protected]<mailto:[email protected]>> For policy questions, send mail to: Jim Bacher <[email protected]<mailto:[email protected]>> David Heald <[email protected]<mailto:[email protected]>> - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <[email protected]<mailto:[email protected]>> All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <[email protected]<mailto:[email protected]>> Mike Cantwell <[email protected]<mailto:[email protected]>> For policy questions, send mail to: Jim Bacher <[email protected]<mailto:[email protected]>> David Heald <[email protected]<mailto:[email protected]>> - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <[email protected]> All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <[email protected]> Mike Cantwell <[email protected]> For policy questions, send mail to: Jim Bacher: <[email protected]> David Heald: <[email protected]>
