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.

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

It's striking that FCC makes no distinction at all based on intended use of a board at design or manufacturing time.  All that matters is to whom the vendor markets or sells the board, and the likelihood of its use in a domestic environment.  This is very sensible if you think about it, because a board that was not designed for domestic use but is then sold to residential users as if it had been so designed represents a liability to society, with potentially damaging consequences of many kinds.  This is especially true if large numbers are sold.

In effect, non-compliance with consumer standards (whether that non-compliance is declared or not) cannot be invoked as a defence nor waiver when marketing a board into the consumer segment, because non-compliance would entail violation of FCC regulations and federal law.  Therefore the only option is not marketing a non-compliant board into that segment in the first place.

The US tends not to be associated with consumer protection laws quite as much as the EU, but in this case FCC regulation is clearly very strong.  This isn't necessarily about protecting consumers of course --- unintentional radiators as covered in Part 15 can affect everyone, including hospitals and the military.  I wouldn't be surprised if that is why the penalties are so severe.

Element14 has written about "dev kits" being considered finished products in the EU.  What seems to be appreciated somewhat less is that the FCC has effectively the same rules, but just differing in language.

Whereas the EU refers to "finished products" (bare boards are considered finished when they merely require plugging in), the FCC doesn't bother with such finessing and instead simply classifies digital devices based on marketting and sales:  if they are marketted and sold for use in a residential environment, then they are Class B devices, and require Class B certification before they can be marketed or sold at all.  No ifs or buts, and the FCC's published penalties for violation are harsh.

Since the EU employs the same A/B classification for commercial/residential uses and in addition defines ready-to-operate boards as finished products, in practice there is no distinct category for so-called "dev kits" in EU nor FCC regulations.  If marketed or sold into a residential environment, they are captured by the Class B certification requirement on both side of the Atlantic.

This makes me wonder why certification of "dev kits" is a discrete topic of discussion at all.  It appears to be wishful thinking, since such a distinction doesn't seem to exist in EU/US legislation.  (It might exist in other jurisdictions though.)

and the FCC's published penalties for violation are harsh

Amazon raised some eyebrows by taking pre-orders last Sept for its latest Kindle,

prior to FCC approval. but FCC declined to comment.

http://www.reuters.com/article/2012/09/08/amazon-fcc-idUSL2E8K80EB20120908

But they say it's very unusual for a company to announce major new products without first getting the sign-off from the agency.

 

"I can't think of an instance where a device has been offered by a U.S. carrier or an independent retailer that has not had FCC approval yet," said John Jackson, a wireless analyst at CCS Insight.

 

An FCC spokesman declined to comment.

 

The 4G Kindle Fire tablets are a crucial part of Amazon's attempt to challenge Apple Inc's iPad at the premium end of the booming tablet market.

 

The lack of FCC approval at this stage is likely a result of Amazon's lack of experience with wireless hardware, according to Charles Golvin, a wireless analyst at Forrester Research.

 

Lazarus said Apple Inc, Motorola, now owned by Google, Samsung and Microsoft have never had such issues.

 

"These companies have dedicated staff whose job it is to ensure FCC compliance and they do their job very well," Lazarus added.

 

Sprint Nextel, a leading wireless carrier, does not release phones for pre-order unless they have already been FCC approved.

 

"In the vast majority of cases, we will not accept a phone into our formal lab process that has not already received FCC approval," said Sprint spokeswoman Michelle Leff Mermelstein.

 

A spokeswoman for AT&T, which is providing the 4G data plan for the new Kindle Fire wireless tablets, declined to comment.

coder27 wrote:

Lazarus said Apple Inc, Motorola, now owned by Google, Samsung and Microsoft have never had such issues.

 

"These companies have dedicated staff whose job it is to ensure FCC compliance and they do their job very well," Lazarus added.

 

Sprint Nextel, a leading wireless carrier, does not release phones for pre-order unless they have already been FCC approved.

 

"In the vast majority of cases, we will not accept a phone into our formal lab process that has not already received FCC approval," said Sprint spokeswoman Michelle Leff Mermelstein.

Well how difficult can it be?  If your job spec says "Keep us FCC-compliant", all you have to do is to read the damn FCC documentation, advise your company accordingly, and give hell to your suppliers until their products comply.  Damn it, I'd love such a cushie job!  (Parden the "damn"s, but they're warranted in this case.)

How to fail on such a simple task is hard to imagine.  Maybe by trying really really really hard?  The FCC goes out of its way to write short and friendly documents about certification, easily understandable by anyone.  It's hard to pin the blame on them.

Well, if RPF manage to redesign the Rpi to run on batteries and with a clock speed of 1.7MHz they will be excluded ...

-J

Well, if RPF manage to redesign the Rpi to run on batteries and with a clock speed of 1.7MHz they will be excluded ...

-J