Jon,
According to FCC Part 15 Subpart B clause 103, an unintentional
radiator such as the one you've described can be exempted from the
requirements of compliance if (f)the device's power consumption is
less than 6nW, and (h)the highest frequency generated and/or used in
the device is less than 1.705MHz and if the device does not operate
from the AC power lines. Only if this device of yours meets all of
these conditions, then FCC Part 15 compliance is not required.
As the intended environment is residential, then the Class B
requirements must be met. CISPR 22 can be used in lieu of FCC Part 15
for testing requirements. Please note that compliance to FCC Part 15
involves both radiated and conducted emissions.
As the FCC has now allowed self declaration for Class B devices
(similar to the CE scheme in Europe), testing and supporting test
reports are still necessary to validate the self declaration. In
allowing this declaration scheme, the FCC has freed up some of its
resources to engage in enforcement activities. It is likely that a
complaint would have to occur before it reached the FCC's attention,
however, there are other methods of enforcement.
If it was discovered that your device did not bear any marking and
found not comply with the requirements, you will likely be forced to
fix the problem, upgrade units already sold and on the shelves and
likely face some legal/financial wranglings with the US government
(not a pleasant prospect), not to mention the blemish to your
commercial reputation which will likely occur in such a case.
Of course, the decision of compliance or non-compliance is yours and
the risks associated therein.
Bear in mind that using a one-of-a-kind product in your own home is
one thing, but offering the device for sale to others is quite another
in terms of commercial and legal responsibility.
I hope this helps. Is there anything anyone would like to add.
The above constitutes only my opinion(s).
Best regards,
Ron Pickard
[email protected]
______________________________ Reply Separator _________________________________
Subject: FCC Questions.
Author: "Jon Bertrand" <[email protected]> at INTERNET
List-Post: [email protected]
Date: 2/20/98 9:13 AM
Hello Everyone,
A lot of "budding midnight designers" ask these questions on the
microcontroller newsgroups so I thought I'd ask them here - and learn
something :)
(If I've missed some FAQ that covers this please let me know.)
1) Say I'm building some microcontroller based widget in my home
business that runs model trains (or whatever). It's not an intential
transmitter, its typically used in the home. And I want to sell them.
Do I need some FCC approval.
Specifically do I need to:
1.a) Spend money having someone test emissions.
1.b) File some paperwork with the FCC.
2) If I don't have the money for testing - but I really do know how
to keep my microcontroller quiet (i.e I know loop area, di/dt, and
maybe even have done lots of other 'approved' products) - and a
little in-home testing shows it doesn't bother the rabbit ears or
show-up on the AM or FM radio. Would I be in violation of some law if
I just sold the darn thing.
2.a) Would I be in violation if it really was quiet to CISPR (i.e.
would have passed). (i.e. is there now a CE mark like compliance that
lets me self declare and assert who's responsible).
3) How does the FCC verify that I don't pollute the EM band - do they
random sample train widgets or wait for someone to complain.
Thanks,
Jon Bertrand
[email protected]
