[comp.sys.amiga] FCC req for electronic kits

crb@raybed2.UUCP (CHRIS BURTTON) (11/13/87)

	I'm interested in building some interface boards for my
	Amiga.  If they work properly, I might market them.  My   
	question is:  Do kits have to pass FCC certification?  If
	so, does that mean that any electronic equipment I build will
	have to meet FCC even if only used by me?

	I would suspect that ALL equipment has to pass FCC.  I would expect
	the FCC to stop anyone from interfering with a radio or TV  
	broadcast with home brew equipment.  But alot of prototype equipment
	doesn't pass FCC and isn't required to until it is shipped as
	a product.  So where does the FCC draw the line of what has to
	meet it's specifications?  I called the FCC, but the people weren't
	very helpful.  I'll get a copy of the regulations, but I expect
	that it will be in legalese and I might not understand it.

	Sorry that this tends to ramble. 

			Chris Burton

	All opinions and confusions are mine! mine! mine!!!

grr@cbmvax.UUCP (George Robbins) (11/14/87)

In article <1080@raybed2.UUCP> crb@raybed2.UUCP (CHRIS BURTTON) writes:
> 
> 	I'm interested in building some interface boards for my
> 	Amiga.  If they work properly, I might market them.  My   
> 	question is:  Do kits have to pass FCC certification?  If
> 	so, does that mean that any electronic equipment I build will
> 	have to meet FCC even if only used by me?
> 
> 	I would suspect that ALL equipment has to pass FCC.  I would expect
> 	the FCC to stop anyone from interfering with a radio or TV  
> 	broadcast with home brew equipment.  But alot of prototype equipment
> 	doesn't pass FCC and isn't required to until it is shipped as
> 	a product.  So where does the FCC draw the line of what has to
> 	meet it's specifications?  I called the FCC, but the people weren't
> 	very helpful.  I'll get a copy of the regulations, but I expect
> 	that it will be in legalese and I might not understand it.

The exact rules and interpretation are subject to change at the FCC's whims,
but in general, expansion board that plug into a certified device and which
*do not* have any external connections (memory cards, etc) do not have to
be certified.  Later this was changed so that coprocessor boards or performance
enhancement devices, i.e. things that change the basic operation characteristics
of the machine are also required to be certified.

Note that this only addresses the certification issue. You are still responsible
for insuring that your device, when used in conjunction with the certified
device does not violate the applicable emission limits.  If you are planning
on selling these devices, you would be well advised to have have done some
testing and have the results on file, lest the FCC should change their rules
or investigate a complaint about your device.

Disclaimer:  This is only my understanding of the current situation.  Please
	     review the actual FCC documents and consult whatever experts
	     you need to.

-- 
George Robbins - now working for,	uucp: {ihnp4|rutgers|allegra}!cbmvax!grr
but no way officially representing	arpa: out to lunch...
Commodore, Engineering Department	fone: 215-431-9255 (only by moonlite)

cgs@umd5.umd.edu (Chris Sylvain) (11/15/87)

In article <1080@raybed2.UUCP> crb@raybed2.UUCP (CHRIS BURTTON) writes:
>	I'm interested in building some interface boards for my
>	Amiga.  If they work properly, I might market them.  My   
>	question is:  Do kits have to pass FCC certification?  If
>	so, does that mean that any electronic equipment I build will
>	have to meet FCC even if only used by me?
>
>	I would suspect that ALL equipment has to pass FCC.

The FCC requires that the _Line Interface_ must be registered under Part 68.
A commonly used method of avoiding the FCC Registration hassles by smaller
manufacturers is to use a Line Interface that is already FCC Registered, and
drive it [the Line Interface] with their own circuits.

For example: Cermetek Microelectronics, Inc. in Sunnyvale, CA makes a model
 CH1811 Line Interface that can be used for voice and data and is Pre-
registered under FCC Part 68. It is shipped with a registration sticker to
be placed on your equipment. Call them for more information, if you wish,
at (408) 752-5000. I have no connection with them, I just read trade journals
like EDN and Electronic Design regularly.
-- 
--==---==---==--
.. the Jabberwock, with eyes of flame, ..
   ARPA: cgs@umd5.UMD.EDU     BITNET: cgs%umd5@umd2
   UUCP: ..!uunet!umd5.umd.edu!cgs

wtm@neoucom.UUCP (11/17/87)

<< Do electronic kits have to pass fcc certification? >>

I don't have the full FCC regualations here, so I don't know
precisely what the ruling is.  I've built some stuff from Heathkit
and others that comes with a little sticker that you're supposed to
sign and stick on the back when you're finished with the kit.
is my impression that anything you have in your possesion is
supposed to comply with the emission characteristics and limits
stated in FCC part 15, whether you built it, it was a kit, or you
bought it assembled.

The lagnuage was something to the effect:  "I ______________ certify
that I have assembled this kit, which is a class B computing
device, in such a way that it that it complied with FCC part 15,
subpart J."

Sorry if I got the rule part numbers wrong.  This was on a Heath
digital Oscilloscope that I assembled for a person here.  Heathkit
might just be doing a cover your tail maneuver; I don't know.  It
is my impression that anything you have in your possesion is
supposed to comply with the emission characteristics and limits
stated in FCC part 15, whether you built it, it was a kit, or you
bought it assembled.

It would be better to be safe than sorry, and have the Amiga option
board kit tested.  Unfortunately that costs $$$, which is difficult
for a start-up company to come up with *before* it has income
from selling the product.  Catch 22.
Bill

rpw3@amdcad.AMD.COM (rpw3) (11/18/87)

(*Sigh*) "Life's not what it used to be in the good ol' days"...

If the equipment your kits run in is *NOT* ever used in the home
(factory, office, "industrial" use only), then the system (combination
of your kit plus the computer it plugs into) only has to meet "Class A"
standards, and you only have to have the test results on file if the FCC
ever comes a'calling.

(Oh yes, you also have to post the applicable Class A sticker on the back:
"This equipment generates...R/F energy...Has been tested and found to comply...
Class A computing device pursuant to Subpart J of Part 15 of FCC Rules...
Operation of this equipment in a residential area is likely to cause
interference in which case the user at his own expense will be required
to take measures to correct the interference." ...like, turn it off.)

There are various testing companies out there these days who know how to
conduct such tests. They ain't cheap! (...partly because you have to test
the total system in its "maximum" configuration for compliance.)

On the other hand, the FCC considers that computers under $3000 are likely
to be used in the home, no matter what their "target" market is, and such
equipments (and add-on devices for them) must be certified to the Class B
standards. If your device appears to be (in THEIR view) oriented to the
"consumer" EITHER in application OR in price OR in marketing (like, if you
advertise in a "consumer" magazine like Byte or PC World), then you have
to meet the Class B standards.

Now to begin with, the radiation limits for Class B computing devices are
a factor of 10 more stringent than for Class A, since Class B devices must
not interfere with a next-door neighbor's radio or TV in an old, high-density
apartment complex. (No, you CANNOT tell the neighbor to get cable TV!)

Secondly, it is not sufficient for you to merely have a copy of the test
results on file, as it would be for Class A. For Class B, you must get FCC
"type approval" *before* you can sell your equipment. This means you gotta
go through "the system", which is bucks and time, especially since you
have to provide THEM with samples not only of your product, but also of
the computers it plugs into (in a "maximal configuration"), since the
radiation limit applies to the total system.

My suggestion to you is to try to sell your invention to some outfit
that already sells into the add-on market, and let THEM take the heat
of testing, etc. (Of course, your product's value to them is lessened
considerably if you haven't done the testing for them, but that's show
biz. Sorry.)


Rob Warnock
Systems Architecture Consultant

UUCP:	  {amdcad,fortune,sun,attmail}!redwood!rpw3
ATTmail:  !rpw3
DDD:	  (415)572-2607
USPS:	  627 26th Ave, San Mateo, CA  94403

ddl@husc6.UUCP (11/20/87)

In article <19164@amdcad.AMD.COM>, rpw3@amdcad.AMD.COM (rpw3) writes:
> Now to begin with, the radiation limits for Class B computing devices are
> a factor of 10 more stringent than for Class A, since Class B devices must
> not interfere with a next-door neighbor's radio or TV in an old, high-density
> apartment complex. (No, you CANNOT tell the neighbor to get cable TV!)

	Does anyone have a few more details on this?  I own many computers
from various manufacturers.  Most are certified Class B; ALL of them cause
(what I would describe as) severe interference with television and radio
in all rooms in my ranch-style house.  I'm sure that distances between
some pairs of rooms are comparable to distances between "high-density"
apartments and by "severe" interference I mean video noise sufficient to
cause modern color televisions to lose sync from time to time.  This
is really anoying because I would like to leave at least one machine
running all the time but I don't want to pay for cable TV either.
Yes, I have tried various combinations of line filters but the problem
seems quite general and consistent.  Maybe one of those tempest-certified
micro-VAXen they were showing at DEC world...

					Dan Lanciani
					ddl@harvard.*