Reply by CBFalconer October 18, 20042004-10-18
Norm Dresner wrote:
> > I don't think it's been suggested before: > > The ARRL has a good site with a summary of FCC-Rule 15 on Unlicensed > RF devices at > > http://www.arrl.org/tis/info/part15.html > > which goves some information on what can be used without FCC approval.
I just rescued a 1953 ARRL Handbook that my kids wanted to throw out. Do you think that will be helpful :-) -- "I support the Red Sox and any team that beats the Yankees" "Any baby snookums can be a Yankee fan, it takes real moral fiber to be a Red Sox fan"
Reply by Norm Dresner October 18, 20042004-10-18
I don't think it's been suggested before:

The ARRL has a good site with a summary of FCC-Rule 15 on Unlicensed RF
devices at

    http://www.arrl.org/tis/info/part15.html

which goves some information on what can be used without FCC approval.

    Norm

Reply by Dave Houston October 17, 20042004-10-17
valemike@yahoo.com (Mike V.) wrote:

>"Meindert Sprang" <mhsprang@NOcustomSPAMware.nl> wrote in message news:<10mt1v55knofca8@corp.supernews.com>... >> "Mike V." <valemike@yahoo.com> wrote in message >> news:8188616d.0410140403.5887d312@posting.google.com... >> > You sort of answered it, but maybe I can rephrase it. >> > >> If you hook up the approved kits to your device and leave them external, you >> don't have to approve your device as an intentional radiator. If you build >> the kit INTO your device, you most probably have to approve your device or >> state the approval from the RF kit in the manual of your device and on a >> sticker on the device. >> >> It works the same as when you buy Bluetooth modules from TDK, in particular >> their TRBLU20 modules. These modules are approved as an end-product and have >> an FCC ID. With the module comes a sticker, which I have to put on the >> ouside of my device in which I use the BT module. I also have to state the >> FCC ID and the used module in the manual or declaration of conformity and >> that is all I have to do to be compliant with the FCC regulations. >> >> Meindert > >I see, so the way to do it then is to get the module approved as an >"end-product" with an FCC id. Other comments in this thread though say >that the "whole" system needs approval. There seems to be a gray area >on where to draw the line between what is "external", "approved >plug-in", and what is part of the system.
It's not true that the entire system needs to be approved. If your main module is a transceiver with a serial port (or ports), it needs approval. If you are manufacturing the serial plug-in modules, they need also to be tested. If they are made and marketed by others, the testing burden is on them. You can get answers to questions like this from the FCC. Send them an email. You can also get answers from the FCC certified lab that will test the transceiver. Just bear in mind that they have an incentive to increase the number of tests required.
Reply by Mike V. October 17, 20042004-10-17
So does that mean then that an end user who goes out and buys a PCMCIA
Wi-Fi card for his/her laptop, and then goes out and uses it at a
public WiFi hotspot (e.g. airport, Starbucks, hotel, Border's, etc.),
is then fundamentally using a system not approved by the FCC? However,
the user who buys a more recent Dell laptop with integrated Wi-Fi is
not violating because we are pretty sure that Dell's
laptop_with_integrated_wifi complies.

Similiarly, a person who uses his cellphone to connect to his/her ISP
is then also violating FCC rules.

Wow, I never realized that the simplest of wireless products can get
so expensive to release.



Jim Stewart <jstewart@jkmicro.com> wrote in message news:<Ov6dnSzcpPbGUvDcRVn-jQ@omsoft.com>...
> Mike V. wrote: > > > I understand that if I make a device which has in it a wireless Zigbee > > transceiver (or any active wireless transceiver), that I would need > > FCC approval. > > > > However, what if i made a little soapbox-shaped transceiver unit, and > > have some wired serial connection (e.g. i2c, CAN, rs323), would I only > > need FCC approval on that soapbox unit, regardless of what other > > products I connect it to via serial wire? > > > > I guess its analogous to having a Linksys or Netgear wireless router. > > The devices that are connected to it don't have to be FCC-approved. > > > > Basically, I need to know if FCC fees will make Zigbee > > transceiver-integrated embedded systems expensive than just using one > > common FCC-approved Zigbee unit, and wire it to my other products. > > It's a little hard to understand what you're asking. > Most microprocessor-based finished goods need to be > FCC-compliant as "unintentional radiators". If you > have an "intentional radiator" such as a zigbee transmitter > then that probably has to be compliant as well under > a different set of rules. > > As to the test environment, during compliance testing, > your device must be connected and talking to devices > that it would normally be connected to. For example, > a Linksys router would have to be connected and routing > packets to other devices while the emissions tests were > performed. > > I probably didn't answer your question, but I did > the best I could.
Reply by Mike V. October 17, 20042004-10-17
"Meindert Sprang" <mhsprang@NOcustomSPAMware.nl> wrote in message news:<10mt1v55knofca8@corp.supernews.com>...
> "Mike V." <valemike@yahoo.com> wrote in message > news:8188616d.0410140403.5887d312@posting.google.com... > > You sort of answered it, but maybe I can rephrase it. > > > If you hook up the approved kits to your device and leave them external, you > don't have to approve your device as an intentional radiator. If you build > the kit INTO your device, you most probably have to approve your device or > state the approval from the RF kit in the manual of your device and on a > sticker on the device. > > It works the same as when you buy Bluetooth modules from TDK, in particular > their TRBLU20 modules. These modules are approved as an end-product and have > an FCC ID. With the module comes a sticker, which I have to put on the > ouside of my device in which I use the BT module. I also have to state the > FCC ID and the used module in the manual or declaration of conformity and > that is all I have to do to be compliant with the FCC regulations. > > Meindert
I see, so the way to do it then is to get the module approved as an "end-product" with an FCC id. Other comments in this thread though say that the "whole" system needs approval. There seems to be a gray area on where to draw the line between what is "external", "approved plug-in", and what is part of the system.
Reply by Dave Houston October 16, 20042004-10-16
Jim Stewart <jstewart@jkmicro.com> wrote:

>Dave Houston wrote: >> Jim Stewart <jstewart@jkmicro.com> wrote: >> >> >>>Dave Houston wrote: >>> >>>>Jim Stewart <jstewart@jkmicro.com> wrote: >>>> >>>> >>>> >>>>>Dave Houston wrote: >>>>> >>>>> >>>>>>Jim Stewart <jstewart@jkmicro.com> wrote: >>>>>> >>>>>> >>>>>> >>>>>> >>>>>>>wkearney99 wrote: >>>>>>> >>>>>>>much snippage... >>>>>>> >>>>>>> >>>>>>> >>>>>>> >>>>>>>>Any device sold needs to have FCC approval (within the expectations of the >>>>>>>>appropriate class). >>>>>>> >>>>>>>more snippage... >>>>>>> >>>>>>>Just to be pedantic, the FCC does not approve anything. >>>>>>> >>>>>>>To the best of my knowledge this is how it works: >>>>>>> >>>>>>>Your product can be compliant, which means you tested >>>>>>>it and you state that it meets regulations, or it can >>>>>>>be certified, which generally means that a trusted >>>>>>>third-party lab has tested it and found it to be compliant. >>>>>>> >>>>>> >>>>>> >>>>>>To be pedantic and accurate, some devices (including all transmitters) >>>>>>require FCC approval. Test data from an FCC certified lab must be submitted >>>>>>to the FCC. If they approve it, they assign an FCC ID number which must be >>>>>>affixed to each device. >>>>> >>>>>To be pedantic, accurate and bordering on anal, a text >>>>>search of CFR 47, part 15 shows *no* instances of the >>>>>words approval. There are some instances of approved, >>>>>but not in the context of a product being approved by >>>>>the FCC. >>>> >>>> >>>>If the FCC-certified lab certifies that your intentional radiator meets FCC >>>>criteria and you submit said lab-certified data, the FCC will grant you an >>>>equipment authorization (in the form of an FCC ID number). Lacking such >>>>certified test data from an FCC-certified lab, the FCC will not grant you an >>>>equipment authorization. I think anybody who is not well beyond the anal >>>>border will think that constitutes "approval" since you cannot legally >>>>market the device without the equipment authorization. >>>> >>>>The FCC does not usually conduct their own lab tests but they can require >>>>you to submit the device for testing by their personnel in their lab. >>> >>>It's a fine issue of semantics. "Approval" indicates >>>a degree of goodness that regulatory agencies are loath >>>to confer upon products. "Compliance" only indicates >>>that the product complies with regulations with no >>>implicit "goodness" of it's condition. Before you >>>fire off another email, find me a cite in the CFR's >>>stating that the FCC "approves" anything. If you can, >>>I'll concede defeat in this pissing contest. >> >> >> I've sent no emails. And you (or rather JK Microsystems) have already lost. >> I was planning to use one of your embedded PCs in a project. You've fired >> off several emails and even made phone calls pestering me about that >> project. I try to avoid doing business with stupid SOBs like you. > >Wow. 2 issues here. First of all, tell me your >company name and I'll make sure we never contact >you again. Yours is the first complaint I've ever >received indicating that a potential customer was >pestered. If you can send me the copies of the >emails I'd appreciate that too. Feel free to take >this to email if you don't choose to reveal your >company name. > >Secondly, I gave fair warning that this thread was >both pedantic and bordering on anal. I'm sorry that >you got offended. But I don't think that makes >us a bunch of stupid SOB's. > >> From Webster's Unabridged Dictionary (Second Edition)... >> >> approve... >> 1. to like; be pleased with; to admit the propriety of; to think or declare >> to be good, satisfactory, etc... >> >> If the FCC doesn't think your device "satisfactory" under its rules, it will >> not declare it to be satisfactory by granting the equipment authorization. >> >> Come to think of it, I don't recall seeing any documentation that your >> embedded PCs comply with FCC rules for Class A and Class B digital devices. > >Our enclosed products such as the EP and Ether6 have been >tested and are labeled part 15 compliant. Our products >with modems use part 68 certified designs. The EP has >been certified as CE compliant by an independent lab. >EPX compliance is in the works. > >Board products have to be tested in the system that >makes up the final product, so labeling the boards >FCC-compliant is somewhat meaningless. We have and >will continue to assist our customers in FCC compliance >of their final product.
Not anywhere near good enough. Every EPC you've sold is a finished product and should have carried a Declaration of Conformity. You could be facing criminal penalties in the millions for flaunting FCC rules.
Reply by Jim Stewart October 15, 20042004-10-15
Dave Houston wrote:
> Jim Stewart <jstewart@jkmicro.com> wrote: > > >>Dave Houston wrote: >> >>>Jim Stewart <jstewart@jkmicro.com> wrote: >>> >>> >>> >>>>Dave Houston wrote: >>>> >>>> >>>>>Jim Stewart <jstewart@jkmicro.com> wrote: >>>>> >>>>> >>>>> >>>>> >>>>>>wkearney99 wrote: >>>>>> >>>>>>much snippage... >>>>>> >>>>>> >>>>>> >>>>>> >>>>>>>Any device sold needs to have FCC approval (within the expectations of the >>>>>>>appropriate class). >>>>>> >>>>>>more snippage... >>>>>> >>>>>>Just to be pedantic, the FCC does not approve anything. >>>>>> >>>>>>To the best of my knowledge this is how it works: >>>>>> >>>>>>Your product can be compliant, which means you tested >>>>>>it and you state that it meets regulations, or it can >>>>>>be certified, which generally means that a trusted >>>>>>third-party lab has tested it and found it to be compliant. >>>>>> >>>>> >>>>> >>>>>To be pedantic and accurate, some devices (including all transmitters) >>>>>require FCC approval. Test data from an FCC certified lab must be submitted >>>>>to the FCC. If they approve it, they assign an FCC ID number which must be >>>>>affixed to each device. >>>> >>>>To be pedantic, accurate and bordering on anal, a text >>>>search of CFR 47, part 15 shows *no* instances of the >>>>words approval. There are some instances of approved, >>>>but not in the context of a product being approved by >>>>the FCC. >>> >>> >>>If the FCC-certified lab certifies that your intentional radiator meets FCC >>>criteria and you submit said lab-certified data, the FCC will grant you an >>>equipment authorization (in the form of an FCC ID number). Lacking such >>>certified test data from an FCC-certified lab, the FCC will not grant you an >>>equipment authorization. I think anybody who is not well beyond the anal >>>border will think that constitutes "approval" since you cannot legally >>>market the device without the equipment authorization. >>> >>>The FCC does not usually conduct their own lab tests but they can require >>>you to submit the device for testing by their personnel in their lab. >> >>It's a fine issue of semantics. "Approval" indicates >>a degree of goodness that regulatory agencies are loath >>to confer upon products. "Compliance" only indicates >>that the product complies with regulations with no >>implicit "goodness" of it's condition. Before you >>fire off another email, find me a cite in the CFR's >>stating that the FCC "approves" anything. If you can, >>I'll concede defeat in this pissing contest. > > > I've sent no emails. And you (or rather JK Microsystems) have already lost. > I was planning to use one of your embedded PCs in a project. You've fired > off several emails and even made phone calls pestering me about that > project. I try to avoid doing business with stupid SOBs like you.
Wow. 2 issues here. First of all, tell me your company name and I'll make sure we never contact you again. Yours is the first complaint I've ever received indicating that a potential customer was pestered. If you can send me the copies of the emails I'd appreciate that too. Feel free to take this to email if you don't choose to reveal your company name. Secondly, I gave fair warning that this thread was both pedantic and bordering on anal. I'm sorry that you got offended. But I don't think that makes us a bunch of stupid SOB's.
> From Webster's Unabridged Dictionary (Second Edition)... > > approve... > 1. to like; be pleased with; to admit the propriety of; to think or declare > to be good, satisfactory, etc... > > If the FCC doesn't think your device "satisfactory" under its rules, it will > not declare it to be satisfactory by granting the equipment authorization. > > Come to think of it, I don't recall seeing any documentation that your > embedded PCs comply with FCC rules for Class A and Class B digital devices.
Our enclosed products such as the EP and Ether6 have been tested and are labeled part 15 compliant. Our products with modems use part 68 certified designs. The EP has been certified as CE compliant by an independent lab. EPX compliance is in the works. Board products have to be tested in the system that makes up the final product, so labeling the boards FCC-compliant is somewhat meaningless. We have and will continue to assist our customers in FCC compliance of their final product.
Reply by Dave Houston October 15, 20042004-10-15
Jim Stewart <jstewart@jkmicro.com> wrote:

>Dave Houston wrote: >> Jim Stewart <jstewart@jkmicro.com> wrote: >> >> >>>Dave Houston wrote: >>> >>>>Jim Stewart <jstewart@jkmicro.com> wrote: >>>> >>>> >>>> >>>>>wkearney99 wrote: >>>>> >>>>>much snippage... >>>>> >>>>> >>>>> >>>>>>Any device sold needs to have FCC approval (within the expectations of the >>>>>>appropriate class). >>>>> >>>>>more snippage... >>>>> >>>>>Just to be pedantic, the FCC does not approve anything. >>>>> >>>>>To the best of my knowledge this is how it works: >>>>> >>>>>Your product can be compliant, which means you tested >>>>>it and you state that it meets regulations, or it can >>>>>be certified, which generally means that a trusted >>>>>third-party lab has tested it and found it to be compliant. >>>>> >>>> >>>> >>>>To be pedantic and accurate, some devices (including all transmitters) >>>>require FCC approval. Test data from an FCC certified lab must be submitted >>>>to the FCC. If they approve it, they assign an FCC ID number which must be >>>>affixed to each device. >>> >>>To be pedantic, accurate and bordering on anal, a text >>>search of CFR 47, part 15 shows *no* instances of the >>>words approval. There are some instances of approved, >>>but not in the context of a product being approved by >>>the FCC. >> >> >> If the FCC-certified lab certifies that your intentional radiator meets FCC >> criteria and you submit said lab-certified data, the FCC will grant you an >> equipment authorization (in the form of an FCC ID number). Lacking such >> certified test data from an FCC-certified lab, the FCC will not grant you an >> equipment authorization. I think anybody who is not well beyond the anal >> border will think that constitutes "approval" since you cannot legally >> market the device without the equipment authorization. >> >> The FCC does not usually conduct their own lab tests but they can require >> you to submit the device for testing by their personnel in their lab. > >It's a fine issue of semantics. "Approval" indicates >a degree of goodness that regulatory agencies are loath >to confer upon products. "Compliance" only indicates >that the product complies with regulations with no >implicit "goodness" of it's condition. Before you >fire off another email, find me a cite in the CFR's >stating that the FCC "approves" anything. If you can, >I'll concede defeat in this pissing contest.
I've sent no emails. And you (or rather JK Microsystems) have already lost. I was planning to use one of your embedded PCs in a project. You've fired off several emails and even made phone calls pestering me about that project. I try to avoid doing business with stupid SOBs like you. From Webster's Unabridged Dictionary (Second Edition)... approve... 1. to like; be pleased with; to admit the propriety of; to think or declare to be good, satisfactory, etc... If the FCC doesn't think your device "satisfactory" under its rules, it will not declare it to be satisfactory by granting the equipment authorization. Come to think of it, I don't recall seeing any documentation that your embedded PCs comply with FCC rules for Class A and Class B digital devices.
Reply by Jim Stewart October 15, 20042004-10-15
Dave Houston wrote:
> Jim Stewart <jstewart@jkmicro.com> wrote: > > >>Dave Houston wrote: >> >>>Jim Stewart <jstewart@jkmicro.com> wrote: >>> >>> >>> >>>>wkearney99 wrote: >>>> >>>>much snippage... >>>> >>>> >>>> >>>>>Any device sold needs to have FCC approval (within the expectations of the >>>>>appropriate class). >>>> >>>>more snippage... >>>> >>>>Just to be pedantic, the FCC does not approve anything. >>>> >>>>To the best of my knowledge this is how it works: >>>> >>>>Your product can be compliant, which means you tested >>>>it and you state that it meets regulations, or it can >>>>be certified, which generally means that a trusted >>>>third-party lab has tested it and found it to be compliant. >>>> >>> >>> >>>To be pedantic and accurate, some devices (including all transmitters) >>>require FCC approval. Test data from an FCC certified lab must be submitted >>>to the FCC. If they approve it, they assign an FCC ID number which must be >>>affixed to each device. >> >>To be pedantic, accurate and bordering on anal, a text >>search of CFR 47, part 15 shows *no* instances of the >>words approval. There are some instances of approved, >>but not in the context of a product being approved by >>the FCC. > > > If the FCC-certified lab certifies that your intentional radiator meets FCC > criteria and you submit said lab-certified data, the FCC will grant you an > equipment authorization (in the form of an FCC ID number). Lacking such > certified test data from an FCC-certified lab, the FCC will not grant you an > equipment authorization. I think anybody who is not well beyond the anal > border will think that constitutes "approval" since you cannot legally > market the device without the equipment authorization. > > The FCC does not usually conduct their own lab tests but they can require > you to submit the device for testing by their personnel in their lab.
It's a fine issue of semantics. "Approval" indicates a degree of goodness that regulatory agencies are loath to confer upon products. "Compliance" only indicates that the product complies with regulations with no implicit "goodness" of it's condition. Before you fire off another email, find me a cite in the CFR's stating that the FCC "approves" anything. If you can, I'll concede defeat in this pissing contest.
Reply by Dave Houston October 15, 20042004-10-15
Jim Stewart <jstewart@jkmicro.com> wrote:

>Dave Houston wrote: >> Jim Stewart <jstewart@jkmicro.com> wrote: >> >> >>>wkearney99 wrote: >>> >>>much snippage... >>> >>> >>>>Any device sold needs to have FCC approval (within the expectations of the >>>>appropriate class). >>> >>>more snippage... >>> >>>Just to be pedantic, the FCC does not approve anything. >>> >>>To the best of my knowledge this is how it works: >>> >>>Your product can be compliant, which means you tested >>>it and you state that it meets regulations, or it can >>>be certified, which generally means that a trusted >>>third-party lab has tested it and found it to be compliant. >>> >> >> >> To be pedantic and accurate, some devices (including all transmitters) >> require FCC approval. Test data from an FCC certified lab must be submitted >> to the FCC. If they approve it, they assign an FCC ID number which must be >> affixed to each device. > >To be pedantic, accurate and bordering on anal, a text >search of CFR 47, part 15 shows *no* instances of the >words approval. There are some instances of approved, >but not in the context of a product being approved by >the FCC.
If the FCC-certified lab certifies that your intentional radiator meets FCC criteria and you submit said lab-certified data, the FCC will grant you an equipment authorization (in the form of an FCC ID number). Lacking such certified test data from an FCC-certified lab, the FCC will not grant you an equipment authorization. I think anybody who is not well beyond the anal border will think that constitutes "approval" since you cannot legally market the device without the equipment authorization. The FCC does not usually conduct their own lab tests but they can require you to submit the device for testing by their personnel in their lab.