Hello Niels,
Sorry to disappoint your customer but this is a computer peripheral. They would connect it to their computer for updating software, etc. Regardless of how rarely they do it the fact is, they do it. Its like a mobile phone, or a GPS Sat Nav., or a camera, etc. It is not normally used while connected to a laptop, but connection to a laptop (or computer) is one of its modes. So, yes, it is a computer peripheral. If they wish to DoC as a computer peripheral; it needs to be tested at a lab which is accredited and also has its details shown on the accredited section of the FCCs website. https://apps.fcc.gov/oetcf/eas/reports/TestFirmSearch.cfm (Search accredited, not 2.948 listed) They would then need a DoC and that FCC Logo. Alternatively, if their lab is not on that accredited list, then they can get a certification with a TCB using equipment class JBP. Thanks, Michael. Michael Derby Regulatory Engineer ACB Europe From: Niels Hougaard [mailto:[email protected]] Sent: 14 March 2014 14:05 To: [email protected] Subject: [PSES] Concerning FCC classification of digital devices Dear list members, Being an independent testing facility, we have received a question from a costumer regarding FCC classification. The consumers 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 - ---------------------------------------------------------------- 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]>
