[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:n...@bolls.dk n...@bolls.dk 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 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
Re: [PSES] Concerning FCC classification of digital devices
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:n...@bolls.dk] Sent: 14 March 2014 14:05 To: EMC-PSTC@LISTSERV.IEEE.ORG 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:n...@bolls.dk n...@bolls.dk 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 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) 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 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
Re: [PSES] Concerning FCC classification of digital devices
In message 007001cf3f8e$5b16a3b0$1143eb10$@dk, dated Fri, 14 Mar 2014, Niels Hougaard n...@bolls.dk writes: ? 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) ? Why does FCC make this fine distinction, with such different regulatory requirements? -- OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk Nondum ex silvis sumus John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - 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
Re: [PSES] Concerning FCC classification of digital devices
In my opinion the customer's analysis is correct - and he's ultimately responsible for the decision right or wrong. I have had a similar experience. It was battery powered and could be programmed at the factory through a USB hub - factory only customers can't use the connection to program or download anything. The connection was purely for battery charging from a post-production user capability. The imager could not be used for its intended purpose during charging - it could only charge the batteries. Nor could the device download images to the computer or otherwise interact with the computer for data manipulation etc. The imager was also sold with a wall wart charger. For reason's I won't go into the client wanted an ITE definition and the legal staff concluded that it was in fact a computer peripheral because of the USB connection. I countered that if that was the determining factor it was then also a wall wart power supply since the same connection could is used with the wall wart. The unit is now classified as a thermal imager not a computer peripheral. During emission testing however the power was tested in its normal operation - changing infrared to visible light, charging while on the wall wart, and charging while attached to a computer - which in this case was a test support peripheral not the other way around. It is the customers obligation to know and classify the device per their analysis, and the labs to advise but proceed accordingly to the customer's directions. Given that any competent lab has lots of experience with many products and test methodologies it is foolish for a customer to not listen to recommendations, but ultimately it is the manufacturers responsibility to meet the requirements and to choose a lab that is accomplished in the measurements and calibrations etc. and who can help, not hinder them in reaching the marketplace. Gmac From: Niels Hougaard [mailto:n...@bolls.dk] Sent: Friday, March 14, 2014 7:05 AM To: EMC-PSTC@LISTSERV.IEEE.ORG 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 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 n...@bolls.dkmailto:n...@bolls.dk www.bolls.dkhttps://urldefense.proofpoint.com/v1/url?u=http://www.bolls.dk/k=b2vlTQszY8VIpYRvaG%2By2A%3D%3D%0Ar=wfHsZjj2K46njWikwK7lPtcx6a6MPoEnW107Er86quU%3D%0Am=yG0NrwErNzXpOexlcW4xeph5NjWwF8CieSYCrfR%2FXAQ%3D%0As=1c36248ab6388ad64553e932e9dab4a885350aba714c2daa40a1df60ad1afff0 - 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.orgmailto:emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.htmlhttps://urldefense.proofpoint.com/v1/url?u=http://www.ieee-pses.org/emc-pstc.htmlk=b2vlTQszY8VIpYRvaG%2By2A%3D%3D%0Ar=wfHsZjj2K46njWikwK7lPtcx6a6MPoEnW107Er86quU%3D%0Am=yG0NrwErNzXpOexlcW4xeph5NjWwF8CieSYCrfR%2FXAQ%3D%0As=9e7c3f1ba6fe0653e70d25cfa0fe0a9851911a082006e51b40a68332bb3bf551 Attachments
Re: [PSES] Concerning FCC classification of digital devices
HI Neils Your client should understand that it is not his point of view that matters, it is what the FCC says about the device and what they say needs to be done in order for the device to be authorized. The simple fact that it can, at any time, connect to a PC and download software makes this a Computer Peripheral. It does not matter how often it can be done, nor how many times it is actually done, the fact that it can be done and that it is a consumer device makes this device a Class B Computing Device Peripheral subject to DoC or Certification, depending on how the grantee wants to address the authorization. Thanks Dennis Ward Senior Certification Engineer PCTEST This communication and its attachments contain information from PCTEST Engineering Laboratory, Inc., and is intended 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 attachment(s) are free from computer virus or other defect. Thank you. From: Niels Hougaard [mailto:n...@bolls.dk] Sent: Friday, March 14, 2014 7:05 AM To: EMC-PSTC@LISTSERV.IEEE.ORG 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:n...@bolls.dk n...@bolls.dk 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 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) 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 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
Re: [PSES] Concerning FCC classification of digital devices
An on-board header is much less an issue; connecting only the power pins on a micro-USB connector eliminates data transfer as a defining capability. Cortland Richmond On 3/14/2014 12:08 PM, Dward wrote: The simple fact that it can, at any time, connect to a PC and download software makes this a Computer Peripheral. It does not matter how often it can be done, nor how many times it is actually done, the fact that it can be done and that it is a consumer device makes - 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
Re: [PSES] Concerning FCC classification of digital devices
That's correct Cortland. If the USB is only used for charging (not data transfer), then it does not count as a 'peripheral' and therefore Verification as Digital Device can be used. Michael. Michael Derby Regulatory Engineer ACB Europe From: CR [mailto:k...@earthlink.net] Sent: 14 March 2014 18:38 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Concerning FCC classification of digital devices An on-board header is much less an issue; connecting only the power pins on a micro-USB connector eliminates data transfer as a defining capability. Cortland Richmond On 3/14/2014 12:08 PM, Dward wrote: The simple fact that it can, at any time, connect to a PC and download software makes this a Computer Peripheral. It does not matter how often it can be done, nor how many times it is actually done, the fact that it can be done and that it is a consumer device makes - 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) 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 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
