Dear list members,

 

Being an independent testing facility, we have received a question from a
costumer regarding FCC classification. 

The consumer’s product is a small portable device for use with a musical
instrument. When the product is used normally, it is attached to the
instrument by audio Jack cables. The product is battery powered, but can be
powered by a general purpose adaptor. The product has a build-in
microprocessor and therefore clock frequencies that requires a
classification with regards to FCC (47 cfr part 15, §15.101).

For software update, programming purpose , and under these circumstances
also sometimes powering, the product has a MINI-B USB connector – depending
on variant, the product can either be supplied with or without the USB cable
in the shipping box.

 

Question is

– Is this product considered a “Class B Computer Peripheral” – which require
a DoC, and an accredited test report from an NVLAP accredited test lab and
appropriate FCC logo markings (DoC or certification procedure) ?

or 

– is the product considered  “Other Class B digital device - - “ – which
require only a verification and no FCC logo marking (Verification procedure)
?

 

Our costumer states that in their point of view the users only operates the
device with a computer connected, when they are putting the device into
operation initially or for reconfiguration, software upgrade or similar.
Therefore they claims it should not be considered Computer Peripheral since
the use of the product is very different from the use of typical computer
Peripherals like keyboard, mouse or printer.

 

Is having a USB connector enough to classify the product as a “Class B
Computer Peripheral”? Or is the use of the USB connector of importance<+

 

Does anyone in here have experience from similar cases?

 

Regards,

Niels

Niels Hougaard

Bolls ApS

Ved Gadekæret 11F

DK-3660 Stenløse

Denmark

 

T: +45 48 18 35 66

F: +45 48 18 35 30

 <mailto:[email protected]> [email protected]

 <http://www.bolls.dk/> www.bolls.dk

 

 

 


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