Hello John, In reply to your query of 21 July, where you asked:
> While understanding the difference between Class A and Class > B digital devices as explained in FCC part 15 (basically business > versus residential use), I am interested in any rules or controls > that must be implemented by a company with respect to distribution. > I am looking for clarification of the terms "marketed for use in a > commercial, industrial or business environment..." and "marketed for > use in a residential environment ...". What must a company do to > ensure from the FCC's viewpoint that the Class A device is > "marketed" only for use in a business environment. I think the key is if your product is marketed in a channel where consumers shop. For example, while businesses may shop in stores like Staples or Office Max, consumers do too (as evidenced by the "back to school" sales they hold every August). Consequently, I would think these stores are clearly in the consumer channel. You would probably find it helpful to review the applicable parts of FCC Bulletin OET-62, "Understanding the FCC Regulations for Computers and Other Digital Devices," available at: http://www.fcc.gov/Bureaus/Engineering_Technology/Documents/bulletins/oet62/oet62rev.pdf On page 3 of OET-62 it says "Class A digital devices are ones that are marketed exclusively for use in business, industrial and commercial environments. Class B digital devices are ones that are marketed for use anywhere, including residential environments." And in later clarification of this point (page 8), "If a digital device is sold or offered for sale to any residential users (including commercial or industrial companies that could employ the equipment in a residential environment) then it is a Class B digital device regardless of its price or application." > What are the consequences/requirements of marketing an aftermarket > antenna upgrade for an 802.11b wireless product? Are there > retest requirements? Labeling issues? This one is easier - Section 15.203 of the FCC rules requires that unlicensed transmitters such as 802.11b devices be designed so that only the antenna furnished with the device can be used. In other words, after-market antennas are not permitted under Part 15. The FCC clearly wants manufacturers to make it difficult-to-impossible for anyone to attach an external or user-supplied antenna because the result may present an RF exposure hazard or have different measured parameters than those submitted with the certification application. Changing the antenna will require a new test and a new certification. And of course, the new certification number will generate a new label. If you want to explore this further, the TCB Council has been working with the FCC OET Lab to address, collect, and make available responses to questions of this sort. Some of this may be available from the TCB Council web site (www.tcbcouncil.org), but when last I looked this appeared to be "under construction." You might find it easier to contact your favorite TCB instead. You might also try contacting the FCC directly. I believe Ray Laforge or Joe Dichoso at the OET Lab are probably the most knowledgeable persons there on this issue. Best regards, -- Scott Roleson --------------------------------------------------------------------- Scott Roleson, PE (MS-61U74) | E-mail: [email protected] Telecom & EMC Engineer | http://www.roleson.com Corporate External Standards | Telephone: +1-858-655-4809 Hewlett-Packard Company | FAX: +1-858-655-5931 16399 W. Bernardo Drive | Amateur Radio: KC7CJ San Diego, CA 92127-1899 USA | Any opinions are my own, not HP's. ---------------------------------------------------------------------
