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'Any PIC-based Product NOT require FCC Approval?'
1998\02\18@013545 by Mark Winters

picon face
Hello All,

My apologies for the "newbie" question -- I was hoping someone on this list
might know or could point me to information on how to find out if a product
requires FCC approval before selling it commercially.

Perhaps a couple of examples would help to clarify the question:

1. If I were to build a *very* simple 12C508-based, 3v circuit that simply
flashes an LED at some varying rate, would I require FCC approval to sell it
(assuming, of course, that anyone wants to buy it :-) ?  If I installed this
same simple circuit into two different plastic "toys", would I need to get
separate approval on each form of the toy, even though the internal circuits
are identical?

2. What if I'm working with a single customer that needs a few "custom" PIC-
based circuits installed to, say, enhance their warehouse security system.
Each circuit may or may not be the same as the others. Would I need to get FCC
approval on these before I could sell and install them?

Sorry if this has already been covered. Thanks in advance for any pointers!

Mark Winters

1998\02\18@100347 by Brian Schousek

picon face
Mark:

I would refer you to title 47,part 15 of the code of federal regulations.
15.103 lists exempted devices and 15.103h shows that 'digital devices in
which both the highest frequency generated and the highest frequency used
are both less than 1.705 MHz and which do not operate from the AC power
lines or contain provisions for operation while connected to the power
lines' are exempt. My from the hip reaction to your blinker would be that if
you used a low frequency external RC to generate timing (so that no
harmonics approaching 1.705 were existant for all practical purposes) you
would have no problem whatsoever. Note that a digital device is by
definition an unintentional radiator so you can't cheat and have a battery
powered 1 MHz transmitter under this exemption. Of course under this
exemption you are required to shut the device down if it is found to cause
interference. I would assume the security system operates or at least can
operate off of AC so you start to have to pay more attention.

To wander a bit, this reminds me of a story I heard about the early
pple ][ days. The RF modulator which allowed the machine to be hooked up to
an ordinary TV of course violated some of the intents and letters of the FCC
regulations which allowed for relatively easy certification of the computer
itself. If Apple sold the RF modulator, it would cause the entire system to
fall under the stricter rules. So instead, they inserted some verbage in the
documentation to the effect of: 'hey, sorry we can't help you with the RF
modulator, but we have heard of this guy that makes one and you might want
to call him.' He had originally, as I understand it, agreed to build and
sell these devices just to help his friends along with their new business
but as history unfolded, he ended up making quite a pretty little penny with
this product.

Brian

Disclaimer: for all legal intents and purposes, a squirrel broke into my
office and typed this note. Neither me nor my employer bear any
responsibility.
-----Original Message-----
From: Mark Winters <spam_OUTMarkwintTakeThisOuTspamAOL.COM>
To: .....PICLISTKILLspamspam@spam@MITVMA.MIT.EDU <PICLISTspamKILLspamMITVMA.MIT.EDU>
Date: Wednesday, February 18, 1998 1:35 AM
Subject: Any PIC-based Product NOT require FCC Approval?


>Hello All,
>
>My apologies for the "newbie" question -- I was hoping someone on this list
>might know or could point me to information on how to find out if a product
>requires FCC approval before selling it commercially.
>
<snip>

1998\02\18@105413 by Mauro, Chuck

flavicon
face
Mark,

If you develop a widget that generates and uses radio frequency energy
(e.g. a PIC running at 4 MHz), and intend to sell that widget
commercially, then you need the proper agency certification of
compliance (e.g. FCC).  The type and nature of your widget, and the
market you target dictates the class of device you've designed, and
determines the level of compliance you'll need (e.g. Class B or C
computing device).  While this may sound utterly ridiculous for a $2 LED
flasher, especially if you intend to sell a very small volume,
compliance with FCC regs is still, to the letter of Federal law,
required.

If you also intend to embed the device into "toys" (I make no judgment
of the inference to the nature of said toys - the fact that you quoted
the word leads me to believe that it's not a stuffed animal), you need
to also obtain the proper safety agency certification if the target
audience includes children.  If the widget is installed into two
separate and distinct toys, then both need to be tested.  (I know it
doesn't seem very reasonable, but that's the way of it.)

The practicality of the situation for small enterprises is that such
testing is a pain, is often very costly, and if you intend to produce a
very low volume, can make the venture seem totally unworthy of your
efforts and returns and can put you off of the whole project.

As to your second question - I'll leave that for someone else to answer
(if anyone would care to).

There are many people who don't bother to gain certification for their
low volume products, or take the risk they will never be caught.  It's
really your call.

When it comes to one or two widgets, especially if it's not for profit,
it doesn't seem very feasible.  But, I make no judgments,
recommendations or opinions.  It's your call.  You should talk to a
compliance testing lab and obtain further advice as to the nature of
your product.

Chuck Mauro

> {Original Message removed}

1998\02\18@111749 by Mark A. Corio

flavicon
face
Mark,
If you are selling components or subsystems it is the responsibility of the
company selling the final product to get any FCC approvals. There are
exemptions from approval requirements for instruments and other types of
devices. You can find the information on the web under the Code of Federal
Regulations (FCC regulations are in the first sections). I think section 15
is the one you want.

http://www.access.gpo.gov/cgi-bin/cfrassemble.cgi?title=199647

Good luck.

Mark A. Corio
Rochester MicroSystems, Inc.
200 Buell Road, Suite 9
Rochester, NY  14624
Tel: (716) 328-5850
Fax: (716) 328-1144
e-mail: .....rmiKILLspamspam.....frontiernet.net
http://www.frontiernet.net/~rmi/
****** Designing Electronics for Research and Industry ******

----------
From: Mark Winters <EraseMEMarkwintspam_OUTspamTakeThisOuTAOL.COM>
To: PICLISTspamspam_OUTMITVMA.MIT.EDU
Subject: Any PIC-based Product NOT require FCC Approval?
Date: Wednesday, February 18, 1998 1:33 AM

Hello All,

My apologies for the "newbie" question -- I was hoping someone on this list
might know or could point me to information on how to find out if a product
requires FCC approval before selling it commercially.

Perhaps a couple of examples would help to clarify the question:

1. If I were to build a *very* simple 12C508-based, 3v circuit that simply
flashes an LED at some varying rate, would I require FCC approval to sell
it
(assuming, of course, that anyone wants to buy it :-) ?  If I installed
this
same simple circuit into two different plastic "toys", would I need to get
separate approval on each form of the toy, even though the internal
circuits
are identical?

2. What if I'm working with a single customer that needs a few "custom"
PIC-
based circuits installed to, say, enhance their warehouse security system.
Each circuit may or may not be the same as the others. Would I need to get
FCC
approval on these before I could sell and install them?

Sorry if this has already been covered. Thanks in advance for any pointers!

Mark Winters

1998\02\18@114933 by Mauro, Chuck
flavicon
face
Brian,

Thanks for contributing the quote from title 47, part 15.  As to your
Apple ][ story - you are mostly right.  I worked at Apple when this was
going on.  The RF modulator was actually designed at Apple by Rod Holt
- our analog guru.  At the time (76-80), the FCC wasn't really busting
our but for the Apple ][ radiating as an unintentional radiator.  The
modulator was of course an (HF) RF oscillator, and was not a
particularly tight design.  It's true that Marty Spergel manufactured
the devices, but they never had Apple's name on them, and the company
kept it's working relationship with Marty (M&R Enterprises) at a safe
distance.  Marty never certified the thing (that's the kind of guy he
was - risks never bothered him), didn't seem to care, and sold them to
the market (with Apple's unofficial help) by the boatloads - until TV's
as a display device went away when low cost RGB monitors hit the
scene...

But - Marty was in it for Marty more than he was in it for Apple.
Riding on another business's coat tails was his way.  I know - I was
once one of his most serious competitors after I left Apple (no - I
didn't sell RF mod's , but that's another story).

I just thought I'd share a little history.

Ciao,

Chuck Mauro

> {Original Message removed}

1998\02\18@122922 by Harold Hallikainen

picon face
       A reminder that I have hyperlinked FCC rules at
http://hallikainen.com/FccRules  .

Harold

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