FCC Certification ...

I note that Farnell UK declares very strong policy statements, which include:

Statement of Quality Policy (part) [my highlighting]

 

All employees will be appropriately trained so they understand fully the importance of meeting customer as well as statutory and regulatory requirements. All training will be recorded.

Top management support will be given at all levels of the business to ensure that sufficient resource is available to realise customer expectations, to ensure legal compliance and to see that the requirements of any relevant national or international standards are satisfied.

That sounds very professional, and it doesn't leave much room for misinterpretation.

So why is there so much difficulty in locating and supplying the relevant certifications that were obtained by Raspberry Pi?  Or does the above Statement of Quality Policy apply only to Farnell UK?

I note that Farnell UK declares very strong policy statements, which include:

 

Statement of Quality Policy (part) [my highlighting]

 

All employees will be appropriately trained so they understand fully the importance of meeting customer as well as statutory and regulatory requirements. All training will be recorded.

 

Top management support will be given at all levels of the business to ensure that sufficient resource is available to realise customer expectations, to ensure legal compliance and to see that the requirements of any relevant national or international standards are satisfied.

I decided to see if any of the Newark support folks on live chat have any such training

on FCC regulatory requirements.  Here's the relevant excerpt:

me:  What are you basing your opinion on? Have you been trained at all on FCC rules?

agent:  No I have not you may contact the FCC directly or you may contact the Raspberry PI foundation.

agent:  I have sent you a link for that before.

me:  Is there someone else I can chat with that has some training on FCC rules?

agent:  We are not trained on FCC rules I apologize.

me:  Is there someone else I can chat with that has some training on FCC rules?

agent:  No I am sorry we do not have anyone that is trained on that in our department.

That FCC document that coder27 linked, "UNDERSTANDING THE FCC REGULATIONS FOR COMPUTERS AND OTHER DIGITAL DEVICES", is certainly explicit:

On pages 8-9, FCC writes:

 

What is the difference between a Class A and Class B digital device?

If a digital device will be sold to anyone who is likely to use it in a residential
environment then it is a Class B digital device. When determining whether a particular
device should be classified as Class A or Class B, the Commission normally considers
the following three questions, in this order:

    Is the marketing of the device restricted in such a manner that it is not sold to residential users?

If a digital device is sold or offered for sale to any residential users (including
commercial or industrial companies that could employ the equipment in a residential
environment) then it is a Class B digital device regardless of its price or application.
Marketing through a general retail outlet or by mail order to the general public with a
simple disclaimer, such as "For Business Use Only," is not sufficient to qualify as
Class A. Instead, all marketing (advertising, sale and distribution) must be restricted
by the marketer to users in a commercial, industrial, or business environment.

    Does the application for which the device is designed generally preclude operation in residential areas?

For example, mainframe computer systems have generally been considered Class A
digital devices because it is highly unlikely that they would be used in residential
environments.

    Is the price of the device high enough that there is little likelihood that it would be used in a residential environment, including a home business?

The merits of classifying a digital device as Class A based on its price are reviewed on
a case-by-case basis. This is because, for example, the price threshold for an I/O card
will be different than the price threshold for a computer system configuration.

Portable computers, because they are designed to be used anywhere, are considered
Class B devices regardless of their price or restrictions placed on marketing. Only in
those cases where the designed application precludes the possibility of operation in a
residential environment may portable computers be qualified as Class A devices.

 

 

 

What happens if one sells or imports non-compliant digital devices?

As explained earlier, the form of authorization that is required for a digital device
depends on how the device will be marketed. The FCC rules are designed to control
the marketing of digital devices and, to a lesser extent, their use. If someone purchases
a non-compliant digital device, uses it, causes interference to authorized radio
communications, and is the subject of an FCC interference investigation, the user will
be told to stop operating the device until the interference problem is corrected.
However, the person (or company) that sold this non-compliant digital device to the
user has violated the FCC marketing rules in Part 2 as well as federal law and may be
subject to an enforcement action by the Commission's Field Operations Bureau that
could result in one or more of the following:

-- forfeiture of all non-compliant equipment
-- $100,000/$200,000 criminal penalty for an individual/organization
-- a criminal fine totalling twice the gross gain obtained from sales of the non-compliant equipment
-- an administrative fine totalling $10,000/day per violation.

It is the act of selling or leasing, offering to sell or lease, or importing a digital device
that has not gone through the appropriate FCC equipment authorization procedure that
is a violation of the Commission's rules and federal law.

Yikes!

If I understand the above correctly, product classification into class A or B is not a vendor option.  A product falls into one class or another depending on who is expected to buy it, and the duty then falls upon the vendor to obtain the appropriate certification, otherwise apparently it's in violation of FCC rules and federal law.  Is there any other way of understanding the above FCC statements?

NOTES and REFERENCES.

• Link to FCC OET (Office of Engineering and Technology) Rules and Regulations page.
• The FCC OET  publishes the e-CFR (Electronic Code of Federal Regulations), and at the time of writing declares "e-CFR Data is current as of August 22, 2013".  The relevant item here is Title 47 (Telecommunication).
• OET e-CFR Title 47 Part 15 (RADIO FREQUENCY DEVICES) Subpart A (General) section 15.3 (Definitions) maintains the definition of Class A and B devices that was described in the OET Bulletin 62 document that we examined above.

I think you unintentionally removed the emphasis on "any" and "portable computers".

Morgaine Dinova wrote:

 

That seems totally clear.  The Pi board in question (which revision?) was Class A certified only.  That was in April 2012 and things may have changed since then, but at least there can be no doubt about that specific Model B.

 

This Raspberry Pi Safety Data Sheet is probably the one mentioned by Gary.  Note that it's dated 19th April 2012.

Then they should have no problem telling who, how, when, what, where made the tests and post publically as the Beaglebone guys did, the test reports.

There is no tops secret or trade information on those reports, just a detail of what test have been performed and if the device passed or failed the test.

Thanks for the headsup.  All emphases in the original were lost because I imported those paragraphs via a text file to avoid direct pasting into the forum editor, since that causes all kinds of literary fireworks.  I'd better go back and reinsert them manually, since it's an official document.

DONE,  I've put the missing emphases back.  I see why you mentioned it --- the paragraph about Portable computers is very specific:

Portable computers, because they are designed to be used anywhere, are considered
Class B devices regardless of their price or restrictions placed on marketing. Only in
those cases where the designed application precludes the possibility of operation in a
residential environment may portable computers be qualified as Class A devices.

Based on the above FCC document, the situation doesn't look too good, to put it mildly.

There's not much that can be done on the weekend, but perhaps good advice for Monday morning at Element14 is to begin the first steps towards Class B certification.  If that requires Pi board redesign, so be it, the result will be a better board.

If I understand the above correctly, product classification into class A or B is not a vendor option.  A product falls into one class or another depending on who is expected to buy it, and the duty then falls upon the vendor to obtain the appropriate certification, otherwise apparently it's in violation of FCC rules and federal law.  Is there any other way of understanding the above FCC statements?

Yes, good point.  That's my understanding as well.

I don't see any other way of reading it.  I think it directly contradicts Gary's claim that

The board underwent EMC testing which enables one to discern if it should be classed A or B.

http://www.element14.com/community/community/legislation/europe/other/blog/2012/04/24/rp-i-class-a-and-b

and you will notice that my comment pointing this out was not answered.

http://www.element14.com/community/community/legislation/europe/other/blog/2012/04/24/rp-i-class-a-and-b#comment-13534

School year is starting right now on this side of the pond, recommendation already went out, budget and curriculum is closed.

If that requires Pi board redesign, so be it, the result will be a better board.

Back in May 2012, Eben said there was already PCB-level work going on to meet Class B standards.

Starting at 17:35

http://www.youtube.com/watch?v=WIf4Fk2252A

So the question was when are the boxed ones for kids going to be available?

Most of our distribution partners have boxing plans afoot.

I've seen some CAM models they look pretty cute.

I guess the kid's thing's got two things associated with it.

One of them is a Class B FCC pass, so a consumer FCC pass.

It's really pretty important I think not to start to ship millions of these

into schools before we have the FCC pass,

so we'll be doing that.

There's PCB level work going on at the moment to accomplish that

and, yeah, lets say summertime.

It doesn't take 14 months to redesign a small board and a box, so a reasonable conclusion is that the PCB work Eben described as ongoing in May 2012 was put on hold.

Pi board redesign is Pete Lomas' bailiwick, I think.  I wonder if there are any clues as to why the work was stopped in the articles he's written.

It doesn't take 14 months to redesign a small board and a box, so a reasonable conclusion is that the PCB work Eben described as ongoing in May 2012 was put on hold.

So maybe it's all Jamodio's fault for finding the LAN chip power bug, which may have accelerated plans for rev 2.0, pushing Class B compliance back to rev 3.0.  Then maybe 3.0 was delayed by the camera module.  Who knows?  The emphasis these days seems to be on industrial applications, so that may have shifted the focus away from homes and schools.  A recent Eben intervew says:

Gareth Jones tells me that the Raspberry Pi is being considered as a processor for controlling industrial processes, with a division of Sony in San Jose interested in using the computer for a project they’re developing.

http://www.makeuseof.com/tag/raspberry-pi-featureinterview/

The interview says they will soon be producing up to 12,000 boards per day, and I doubt they are expecting schools to be a large fraction of that demand anytime soon.

It doesn't take 14 months to redesign a small board and a box, so a reasonable conclusion is that the PCB work Eben described as ongoing in May 2012 was put on hold.

So maybe it's all Jamodio's fault for finding the LAN chip power bug, which may have accelerated plans for rev 2.0, pushing Class B compliance back to rev 3.0.  Then maybe 3.0 was delayed by the camera module.  Who knows?  The emphasis these days seems to be on industrial applications, so that may have shifted the focus away from homes and schools.  A recent Eben intervew says:

Gareth Jones tells me that the Raspberry Pi is being considered as a processor for controlling industrial processes, with a division of Sony in San Jose interested in using the computer for a project they’re developing.

http://www.makeuseof.com/tag/raspberry-pi-featureinterview/

The interview says they will soon be producing up to 12,000 boards per day, and I doubt they are expecting schools to be a large fraction of that demand anytime soon.

I've added FCC reference links confirming currency of the Class A and B definitions to my long post #16 above.

During the whole conversation, I did not see any mention of the new rev of the boards.

The conversation seemed to cover the original design, and ignore the changes made in the latest release.

Maybe this one passed all the test, but we do not have documentation.

Just my two cents.

AC9GH

Yes, that's clearly a very relevent issue, since certification of one revision of a board may not carry over to another revision.  What's more, Pi Models A and B are very different electronically despite using the same PCB.

So, quite separate from the issue of Class B certification for what is clearly a device in residential use, there is also the matter of whether the revisions of both models sold today are actually covered by a current FCC certification even for Class A.  Newer revisions can usually be expected to behave better than old ones (as I think you were hinting), but this of course needs to be verified.  I assume that a test certificate details the exact board revision being tested, so Element14 can (presumably) verify the validity of existing certifications immediately without room for doubt just by checking revision numbers.

I suspect that there are clear rules for when a certification can be carried over to a new revision and when not.  Has anyone found the relevant FCC guidelines?

I suspect that there are clear rules for when a certification can be carried over to a new revision and when not.  Has anyone found the relevant FCC guidelines?

See p. 10 of the previously cited OET Bulletin 62 under the heading

What changes can be made to an FCC-authorized device without requiring a new FCC

authorization?

http://transition.fcc.gov/Bureaus/Engineering_Technology/Documents/bulletins/oet62/oet62rev.pdf

If my reading of p.13 is correct, then "For certified equipment (personal computers and their peripherals)", with the proviso that clock circuitry is unchanged (because that could entirely change RF characteristics), if there is no increase in RF emissions, then no new certification is required.  Again stressing that this is only if my reading is correct. then because this equipment is only certified rather than verified, it is up to the certifier to declare that there has been no increase in RF emissions, rather than it needing to be verified.  It seems to work on trust.

It wouldn't surprise me if my reading of this is incorrect, since such an approach seems open to abuse --- comments welcome.  That said, I would not expect any  engineering professional in the Pi ecosystem to abuse such regulations, so it doesn't seem to be relevant here.

In other words, it seems to me that if Pi development engineers find that "a change does not affect, or reduces the radio frequency emissions from the device" (the FCC's words) then it's entirely proper to consider the previous certification to continue to apply.  Needless to say, this "Class I permissive change" would have to appear on the certification, or an ammendment to it.  Just saying nothing is asking for trouble.

Morgaine

Without diving in FCC, if you certify something, you have tested that it meets the necessary requirement/laws and that testing will record the conditions under which it met those requirement/laws.

If the manufacturer continues with the method, then any subsequent items will still meet that certification.

Verify is to check it still meets the requirement/law and could be random sampling (espcially if its close) or when something has been changed.

I believe there were issues with the HDMI during inital testing, hence it was reduced slightly to meet the necessary emissions, and tested under those settings.

I do note that once again NZ and Australia have been singled out.

AUSTRALIA AND NEW ZEALAND CLASS A EMISSIONS COMPLIANCE STATEMENT

Warning: This is a Class A product. In a domestic environment this product may cause radio interference in which case the user may be required to take adequate measures.

Mark

Yes Model A and B require different emissions tests given that Model A does not include the 25MHz crystal and ethernet PHY, a very well known source of common mode noise and EMI.

-J

Let me share as an example what accompanies the Texas Instruments LaunchPad Evaluation Kit ...

The problem with RPF and Rpi is that the initial plan for it was to be an evaluation board, that way they were able to circumvent the certification requirements, but instead of sticking with the original plan of creating a limited number of boards for testing and development they got blinded by ambition after seeing the demand generated by so much hype and buzz.

Then it was too late to circumvent the tests when you start calling it a "computer" or a "box" and obviously the number of boards produced.

After making a deal with Farnell and RS, they had to step in and at least perform the hazardous materials tests, I remember seeing a picture of one guy from RS holding one of the early RPi boards on the Fischer material analyser, results of those tests have never been made public.

I remember that there was an issue with the signal levels on HDMI that complicated the first pass of the emissions tests, but afaik minimal changes have been done to the pcb layout between 1.0 and 2.0 to address any other issues, and what Pete Lomas said about sharing what other issues have been found never materialized.

Will RPF ever make all this information public ? Who knows, but if Farnell/element14 have assumed the responsibility of manufacturing and selling the boards, they SHOULD be now the ones to make the information available publicly.

There is nothing wrong about been transparent and open, if it is not certified or certification can't be met, it is not the end of the world, at least we know what we are dealing with and know what to say to the end user.

My .02

There is a discussion of development kits here:

http://www.element14.com/community/community/legislation/europe/rohs/blog/2012/09/28/development-kits-in-scope-of-the-rohs-recast

During the whole conversation, I did not see any mention of the new rev of the boards.

The conversation seemed to cover the original design, and ignore the changes made in the latest release.

Maybe this one passed all the test, but we do not have documentation.

Eben was asked if the Rev 2 board would be tested for FCC Class B emissions,

and he said:

Not on this version. This will have to wait for the “educational release” board.

http://www.raspberrypi.org/archives/1929#comment-31756