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 94403hpoppe@scdpyr.UUCP (Herb Poppe) (11/18/87)
In article <19164@amdcad.AMD.COM>, rpw3@amdcad.AMD.COM (rpw3) writes: >... > 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. >... 1) Is every "device" used in the home that contains a "computer" (micro- processor, microcontroller, etc.) consider a "Class B computing device"? Is that fancy microwave oven, washing machine or toaster(?) containing a single-chip micro have to be certified by the FCC? If not, what are the rules associated with allowing such devices to be exempted. 2) A micro is just a (relatively) high speed digital circuit. Certainly other high speed digital circuits that are not "computers" also generate RF energy that could interfere with radio/TV reception. If such circuits appear in products used in the home must they be certified as Class B computing devices? If so, what is considered "high"? 3) How is the "hobbyist" affected by the rules? Can I "homebrew" a system and be legal? If so, can I make systems for my friends? Can I describe such a system in the hobby press and be legal? If so, can I offer "kits" for the described project at cost? for a profit? -- Herb Poppe NCAR INTERNET: hpoppe@scdpyr.UCAR.EDU (303) 497-1296 P.O. Box 3000 CSNET: hpoppe@ncar.CSNET Boulder, CO 80307 UUCP: hpoppe@scdpyr.UUCP
rpw3@amdcad.UUCP (11/19/87)
I'm not a lawyer, nor do I do FCC certifications for a living, but based on what I have read (including a copy of part 15 Subpart J, some time ago), I'll try to answer best as I know. In article <221@scdpyr.UUCP> hpoppe@scdpyr.UUCP (Herb Poppe) writes: +--------------- | 1) Is every "device" used in the home that contains a "computer" (micro- | processor, microcontroller, etc.) consider a "Class B computing device"? +--------------- Yes. Notice that it doesn't have to be a computer. The definition is (approx.) "any device which generates or uses radio-frequency energy" not otherwise covered in some other specific FCC rule. "Radio-frequency" in Part 15 Sub J includes digital pulses at a rate of 10 KHz or higher. +--------------- | Is that fancy microwave oven, washing machine or toaster(?) containing | a single-chip micro have to be certified by the FCC? If not, what are | the rules associated with allowing such devices to be exempted. +--------------- Yes, unless there are specific Parts or Sections in the FCC Rules which take precedence. For example, wristwatches (which typically use 32 KHz crystal oscillators) are specifically exempted from Subpart J (but not from Subpart C and other Parts). +--------------- | 2) A micro is just a (relatively) high speed digital circuit. Certainly | other high speed digital circuits that are not "computers" also generate | RF energy that could interfere with radio/TV reception. If such circuits | appear in products used in the home must they be certified as Class B | computing devices? If so, what is considered "high"? +--------------- Yes. "High" is anything over 10 KHz. For example, that includes such things as the vast majority of infrared remote control units, since they use digital techniques and >10 KHz pulses. (Even though the IR *light* is not covered by the FCC Rules, the LED *driver* circuit is.) +--------------- | 3) How is the "hobbyist" affected by the rules? Can I "homebrew" a system | and be legal? +--------------- There are other Subparts of Part 15 which concern what you can build and use "for yourself". Part 15.C is (I think) if for what have been traditionally called "Part 15 devices", that is, short-range radios, radio-control, and the like. I think you may be able to use 15.C for home-built devices, but don't hold me to this one... Part 15.J is for "computing devices" (broadly defined), and because they are more likely (due to their manufacturing volume) to cause interference, the radiation limits are more stringent than for 15.C devices. (It may even apply to home-built "computing devices", but better check the regs.) The Class B radiations limits are (roughly), measured at a distance of 3 meters from the device: 30-88 MHz: less than 100 uV/m 88-216 MHz: less than 150 uV/m 216-1000 MHz: less than 200 uV/m and no more than 250 uV conducted into the power lines (0.45-30MHz). In any case, the ultimate test is that thou shalt not cause harmful interference to other services or to your neighbors. (Really, even these limits aren't too stringent! You often can't listen to a weak radio station a few feet from a Class B device.) +--------------- | If so, can I make systems for my friends? +--------------- I don't THINK so... ;-} ;-} But check the regs. (They're easy to get. Call the U.S. Government Printing Office and say you want a copy of the "FCC Rules and Regulations, Part 15 Subpart J". They'll sell you whatever's the enclosing volume of the Rules which contains 15.J. You may want to look at *all* of Part 15...) +--------------- | Can I describe such a system in the hobby press and be legal? +--------------- Sure. You're not "building" anything. Anyone can publish information (within broad First Amendment limits). Look at magazines like Modern Electronics or Hands-On Electronics, which run several construction projects per issue. "Ciarcia's Circuit Cellar" in Byte does this. It WOULD be polite to provide a warning to potential builders that they are liable for the consequences of any violations... +--------------- | If so, can I offer "kits" for the described project at cost? for a profit? +--------------- Wups! Now we're back to manufacturing! I think it's "No", and "No". UNLESS... you have the whole think FCC type approved for "home construction" (as Heathkit and some others do for some of their computer kits). Such is possible, but not cheap. I know, it sounds like the FCC suddenly became "bad guys". (NOTE! Way back in 1982, when this finally went into full enforcement!) But for years before, they'd been getting increasing numbers of complaints about interference with radio & TV from folks whose neighbors had small computers, etc. (Some of the early Apple-II's and S-100 systems would wipe out low-numbered TV channels!) They decided to study the expected growth in home electronics, and to set rules that would insure that they wouldn't have to be in the middle of millions of interference complaints and enforcement actions (which the FCC is simply NOT staffed for!). The proposed Subpart J rules were circulated for several years, and even after they went into effect, several computer companies (including Apple) were able to get exceptions/extensions for a couiple more years, on the grounds that compliance would cost too much. By now, most everyone is up the learning curve on how to build Class B confoming systems, and it's no big deal... except for the raelly little guy such as yourself. (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 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.*
parnass@ihuxz.UUCP (11/20/87)
x Herb Poppe asks questions about FCC Part 15 standards: | 1) Is every "device" used in the home that contains a "computer" (micro- | processor, microcontroller, etc.) consider a "Class B computing device"? | Is that fancy microwave oven, washing machine or toaster(?) containing | a single-chip micro have to be certified by the FCC? If not, what are | the rules associated with allowing such devices to be exempted. Yes, those fancy home appliances that use microprocessors as control elements are computing devices if they meet FCC's definition. FCC Part 15J (Technical Standards for Computing Equip- ment) defines a COMPUTING DEVICE as any electronic device or system that generates and uses timing signals or pul- ses at a rate in excess of 10,000 pulses (cycles) per seconds and uses digital techniques. A CLASS A device is a computing device that is marketed for use in a commercial, industrial, or business environ- ment. A CLASS B device is a computing device that is marketed for use in a residential environment notwithstanding its use in commercial, business, and industrial environment. Class B standards for radiated are stricter than Class A. | 2) A micro is just a (relatively) high speed digital circuit. Certainly | other high speed digital circuits that are not "computers" also generate | RF energy that could interfere with radio/TV reception. If such circuits | appear in products used in the home must they be certified as Class B | computing devices? If so, what is considered "high"? The rules apply to end products and peripherals (I/O dev- ices), not to subassemblies and components. TABLE 1. FCC Part 15 Subpart J Limits for Radiated Emis- sions _________________________________________________ | | Class A Class B | | Freq(MHz) Dist(m)| uV/m uV/m uV/m uV/m| |____________________|___________________________| | 30-88 3 | 300 49.5 100 40 | | 88-216 3 | 500 54 150 150 | | 216-1000 3 | 700 56.9 200 46 | | | | | 30-88 30 | 30 29.5 | | 88-216 30 | 50 34 | | 216-1000 30 | 70 36.9 | |____________________|___________________________| If the device is connected to an AC power line, it must also meet FCC standards for conducted emissions. TABLE 2. FCC Part 15 Subpart J Limits for Conducted Emis- sions __________________________ | Class Freq(MHz) uV | |_________________________| | A 0.45-1.6 1000| | 1.6-30 3000| | | | B 0.45 30| |_________________________| | 3) How is the "hobbyist" affected by the rules? Can I "homebrew" a system | and be legal? If so, can I make systems for my friends? | Can I describe such a system in the hobby press and be | legal? If so, can I offer "kits" for the described project at cost? for a | profit? FCC rules don't specify what articles you can write in the hobby press. If you offer "kits" for sale, they must comply with the FCC Part 15. Keep in mind that even if a device complies with Part 15 standards, but still causes harmful interference, the user may be required to stop operation. -- ===-===-===-===-===-===-===-===-===-===-===-===-===-===-===-===-===-===-===-=== Bob Parnass, Bell Telephone Laboratories - ihnp4!ihuxz!parnass - (312)979-5414