The designer is flat wrong. 15.27 makes it clear that if such a 'special accessory' is required for compliance of a device the they either must be provided with the device or they must ensure a method such that the special accessory is provided to the user of the device without additional charge and at the time of purchase. And, while these special accessories must either be provided or made available at the time of purchase at no additional charge, the manual must give adequate instructions on how to install and use the special accessory. A statement that ferrites is needed does not meet this requirement as it would incur additional expense on the part of the user as ferrited cables cost more.
The actual wording from 15.27 is as follows: "(a) Equipment marketed to a consumer must be capable of complying with the necessary regulations in the configuration in which the equipment is marketed. Where special accessories, such as shielded cables and/or special connectors, are required to enable an unintentional or intentional radiator to comply with the emission limits in this part, the equipment must be marketed with, i.e., shipped and sold with, those special accessories. However, in lieu of shipping or packaging the special accessories with the unintentional or intentional radiator, the responsible party may employ other methods of ensuring that the special accessories are provided to the consumer, without additional charge, at the time of purchase. Information detailing any alternative method used to supply the special accessories shall be included in the application for a grant of equipment authorization or retained in the verification records, as appropriate. The party responsible for the equipment, as detailed in ยง2.909 of this chapter, shall ensure that these special accessories are provided with the equipment. The instruction manual for such devices shall include appropriate instructions on the first page of the text concerned with the installation of the device that these special accessories must be used with the device. It is the responsibility of the user to use the needed special accessories supplied with the equipment. In cases where the manual is provided only in a form other than paper, such as on a computer disk or over the Internet, the information required by this section may be included in the manual in that alternative form, provided the user can reasonably be expected to have the capability to access information in that form. Thanks Dennis Ward This communication and its attachements contain information from PCTEST Engineering Laboratory, Inc., and I sintended for the exclusive use of the recipient(s) named above. It may contain information that is confidential and/or legally privileged. Any unauthorized use that may compromise that confidentiality via distribution or disclosure is prohibited. Please notify the sender immediately if you receive this communication in error, and delete it from your computer system. Usage of PCTEST email addresses for non-business related activities is strictly prohibited. No warranty is made that the e-mail or attachments(s) are free from computer virus or other defect. Thank you. -----Original Message----- From: Rudd, Adam [mailto:adam.r...@ncr.com] Sent: Thursday, September 4, 2014 5:03 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] FCC EMI Test and Ferrites on Cables It's all in Part 15, spread about. 47CFR15.27 47CFR15.31(j) -----Original Message----- From: Scott Douglas [mailto:sdouglas...@gmail.com] Sent: Thursday, September 04, 2014 2:31 AM To: EMC-PSTC@listserv.ieee.org Subject: [PSES] FCC EMI Test and Ferrites on Cables Fellow List persons... Please help refresh a tired brain. A designer of a product tells us that he passes FCC emissions testing if he puts ferrite sleeves (beads?) on the four HDMI cables connected at the rear panel of the product. He tells us that all he needs to do is add a statement in the user manual to the effect that the HDMI output cables must have ferrite sleeves (beads?) on them. He says he does not need to specify manufacturer name and part number of the ferrites. He says he does not need to provide the ferrites with the product. He also does not plan to include the HDMI output cables with the product because every installation will have different length HDMI cables needed. Now, my old brain thinks the above is not acceptable and that the FCC says that anything special needed to pass FCC testing must be provided with the product. And I am thinking that ferrites are special as you can't get them at Walmart or Radio Shack or Ace Hardware. And not all ferrites are the same. Can anyone confirm my memory and maybe give a pointer to the part of the FCC Rules that clarify this? Or have the rules changed over the years and I just missed that part? Thank you in advance for any and all comments, on list or off. Best regards, 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 <emc-p...@ieee.org> 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 <emcp...@radiusnorth.net> Mike Cantwell <mcantw...@ieee.org> For policy questions, send mail to: Jim Bacher: <j.bac...@ieee.org> David Heald: <dhe...@gmail.com> - ---------------------------------------------------------------- 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 <emc-p...@ieee.org> 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 <emcp...@radiusnorth.net> Mike Cantwell <mcantw...@ieee.org> For policy questions, send mail to: Jim Bacher: <j.bac...@ieee.org> David Heald: <dhe...@gmail.com> - ---------------------------------------------------------------- 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 <emc-p...@ieee.org> 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 <emcp...@radiusnorth.net> Mike Cantwell <mcantw...@ieee.org> For policy questions, send mail to: Jim Bacher: <j.bac...@ieee.org> David Heald: <dhe...@gmail.com>
