Gary, You are referring to FCC CFR47 Part 2.803 (c)(2)
--- (ii) A radio frequency device that is in the conceptual, developmental, design or pre-production stage may be offered for sale solely to business, commercial, industrial, scientific or medical users (but not an offer for sale to other parties or to end users located in a residential environment) if the prospective buyer is advised in writing at the time of the offer for sale that the equipment is subject to the FCC rules and that the equipment will comply with the appropriate rules before delivery to the buyer or to centers of distribution. (iii) (A) A radio frequency device may be advertised or displayed, (e.g.,at a trade show or exhibition) if accompanied by a conspicuous notice containing this language: This device has not been authorized as required by the rules of the Federal Communications Commission. This device is not, and may not be, offered for sale or lease, or sold or leased, until authorization is obtained. --- It starts out very promising, but then it says: "...and that the equipment will comply with the appropriate rules before delivery to the buyer...". The eval board will *never* comply with the appropriate rules, it's the whole point of the board. But I guess the first part of the sentence is essentially the free-pass I was looking for. I had never payed attention to the fact that this statement actually allows the sale of a developmental device. Always thought that no money exhange was allowed under this section. Thank you! John On Tue, Nov 5, 2013 at 11:12 AM, McInturff, Gary < [email protected]> wrote: > Sorry I don’t have time to look it up, but the FCC regulations do > discuss equipment operation at trade shows and other places while the > product is still under the designers control. The principle restriction was > labeling that was clearing identified that it wasn’t for sale and that no > money could transfer until the unit was approved. Sorry this is really > vague and I took a very brief shot at finding it in the rules but don’t > have time for a real search. But you should be able to find it at least for > the US – obviously the EU doesn’t care about what the FCC would allow. So > depending on where this is going the allowance for pre-approved equipment > in the us may or may not be pertinent anyway. > > > > I can see the labeling in my mind and it even had to be red in color > (colour for my EU friends) but just can’t come up with the actual clause > just now. > > > > Gary > > > > *From:* EMC Guy [mailto:[email protected]] > *Sent:* Tuesday, November 05, 2013 7:44 AM > *To:* [email protected] > *Subject:* Re: [PSES] EMC requirements for developer/evaluation boards > > > > I've been reading through all your answers and comments like through a > good book. I still have no idea how the story will end! > > To follow-up on Gert Gremmen's comments, the kind of eval board I am > adressing here is the kind with a whole bunch of connectors and test points > installed directly on the PCB surface, to monitor clock signals or to > inject voltage biases from external sources while the IC under test is > being investigated. Of course any eval board could be placed inside an > enclosure with shielded connectors for everything, but I've never seen > that. And of course, doing so for an item not intended to be a finished > product would add a lot of design cost that would lead to an unaffordable > price for the eval boards, essentially killing the purpose. > > The purpose of my enquiry was not to find a way to go around directives > and standards to maybe put humans or licensed communications in danger, but > was to find out what was the actual regulatory framework that adresses > these very specific kits. And from all of your generous comments, the only > conclusion I can draw today is: there is none. No authority (in Europe at > the least) has ever published specific guidelines on the subject. So do > what you think is right, but be prepared (with a strong enough legal > department) to defend your decisions. Although I'm really holding on to > Brian Kunde's interpretation of apparatus and end-user as described in the > Guide for the EMC Directive. > > I am suprised at the lack of FCC-sided comments. Is this because you > think FCC Form 740 option 3. "The described equipment is being imported in > limited quantities for testing and evaluation for compliance with technical > requirements or marketing suitability. The equipment will not be offered > for sale or otherwise marketed." is sufficient to go through customs with > an untested eval board? > > John B. > > > > On Tue, Nov 5, 2013 at 9:34 AM, ce-test, qualified testing bv - Gert > Gremmen <[email protected]> wrote: > > Your philosophy is mine but for one thing: > > It's not because a product cannot meet requirements as put on the market > that it should be excluded .. > > > It could for example be sold in an enclosure, so as to meet ESD > requirements. > It's not a absolute requirement for these board to be sold > as a bare PCB. It has consequences for the prices of course but > that is valid for each device, not for development boards only. > > And it is not because you can touch a chip, that it need to be > tested. Standards speak about likely to be touched in normal use. > Connector internal pins on my Ipad are accessible too, but most standards > do > not include them for ESD testing. It may be wise to do so, but that is > another story. > > > BTW did anyone obtain a satisfactorily answer from Farnell or any other > seller ? > > Your opinion about the EC in these, in casu their authors, is not mine. > EC texts do generally excel in quality, what need not be the same as > clear to us, or in line with our needs. Note that they are > addressed to the member states and their legal advisors and not to > the end users. If unclear on a special subject, than it > certainly is the case because the subject is not well enough defined, or > it would open a way to avoid requirements by what i call > smart naming or smart selling. > > > > > > Regards, > > Ing. Gert Gremmen, BSc > > > > [email protected] > www.cetest.nl > > Kiotoweg 363 > 3047 BG Rotterdam > T 31(0)104152426 > F 31(0)104154953 > > P Before printing, think about the environment. > > > > -----Oorspronkelijk bericht----- > > Van: Piotr Galka [mailto:[email protected]] > Verzonden: Monday, November 04, 2013 6:23 PM > Aan: EMC-PSTC; ce-test, qualified testing bv - Gert Gremmen > > Onderwerp: Re: [PSES] EMC requirements for developer/evaluation boards > > Hi Gert, > > > To Piotr: ESD test are normally carried out on enclosure and connector > > shielding, not to internal circuits. > > HCP and VCP discharge are designed for this. > > > > My logic is: > The idea of ESD test is to check possible events which can happen in > normal use of device. > The possible source of ESD are human fingers. > Human fingers touches enclosure and not internal circuits because > enclosure is between fingers and internal circuits. > So ESD is tested on enclosure and on HCP and VCP = all expected ESD that > can happen to and near device. > If device has plastic enclosure than in real ESD to something near device > has higher probability than to device (which is close to 0%). > > If there is no enclosure than human fingers can touch directly internal > circuits so following the idea of testing all possible ESD events in my > opinion ESD should be also tested to internal circuits. I think that for > such device the ESD to internal circuits has much higher probability than > to something near (HCP and VCP). There is no idea to testing something less > probable and not testing something more probable. > > If the prototype board is to be used only in ESD protected environment > than testing ESD to internal circuits can have no sense but testing ESD to > HCP and VCP also has no sense. > > But generally I think that prototype board should be excluded from EMC at > all and it should be written in the first EMC directive version long time > ago. > When I first time read EMC (in 2002 - two years before we (Poland) joined > EU) the question about prototype board was my first thought. > Being not clear solved in directive that subject makes me to have clear > opinion about its authors. > > Best Regards > Piotr Galka > > - > ---------------------------------------------------------------- > 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://www.ieee-pses.org/list.html (including how to > unsubscribe) > 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]> > > > > - > ---------------------------------------------------------------- > > 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://www.ieee-pses.org/list.html (including how to > unsubscribe) <http://www.ieee-pses.org/list.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]> > - ---------------------------------------------------------------- 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://www.ieee-pses.org/list.html (including how to unsubscribe) 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]>
