Does EVERY device with a wireless transceiver (e.g. Zigbee) need FCC approval?

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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.

Re: Does EVERY device with a wireless transceiver (e.g. Zigbee) need FCC approval?

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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.

Re: Does EVERY device with a wireless transceiver (e.g. Zigbee) need FCC approval?
You sort of answered it, but maybe I can rephrase it.

Here's one scenario: For example, a third party company sells a little
kit which they got FCC approval on. This kit has an RS232 interface to
attach to other devices. So I buy hundreds of those "plug-in" kits
(well maybe I shouldn't be calling it "plug-in"), and want to
wireless-enable 5 different legacy embedded devices we currently sell.
Will I then need to submit all five of those products for FCC
approval, since the third party kit is already FCC-approved?

I concluded from your answer, Jim, is that the third party kit really
does not need FCC approval, and instead the burden to get it approved
falls on the company using the kit, for each and every product it is
connected to. Oh well.


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Re: Does EVERY device with a wireless transceiver (e.g. Zigbee) need FCC approval?
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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



Re: Does EVERY device with a wireless transceiver (e.g. Zigbee) need FCC approval?
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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.

Re: Does EVERY device with a wireless transceiver (e.g. Zigbee) need FCC approval?

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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.


Re: Does EVERY device with a wireless transceiver (e.g. Zigbee) need FCC approval?
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


Re: Does EVERY device with a wireless transceiver (e.g. Zigbee) need FCC approval?
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Any device sold needs to have FCC approval (within the expectations of the
appropriate class).  If you take an approved kit and attach something to it
and sell it you'd have to get your part of it approved.  The thing you're
attaching would require it's own FCC approval regardless of what devices
were attached to it.  You can't "leech" off the approval of the other device
nor does yours 'rub off' onto the other.  As in, a computer attached to an
FCC approved UPS would certainly still need it's own approval.

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If you sell something then you'd be well advised to be sure of it's
approval.  If you're 'bundling' it as a kit of your own then you may be
incurring approval risks.  It would make very good sense to contact the FCC
directly and ask them.  Follow this with assurance from a lawyer skilled in
handling FCC licensing issues.

-Bill Kearney


Re: Does EVERY device with a wireless transceiver (e.g. Zigbee) need FCC approval?

much snippage...    

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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.




Re: Does EVERY device with a wireless transceiver (e.g. Zigbee) need FCC approval?

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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.



Re: Does EVERY device with a wireless transceiver (e.g. Zigbee) need FCC approval?
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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.





Re: Does EVERY device with a wireless transceiver (e.g. Zigbee) need FCC approval?

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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.


Re: Does EVERY device with a wireless transceiver (e.g. Zigbee) need FCC approval?
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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.










Re: Does EVERY device with a wireless transceiver (e.g. Zigbee) need FCC approval?

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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.


Re: Does EVERY device with a wireless transceiver (e.g. Zigbee) need FCC approval?
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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.

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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.


Re: Does EVERY device with a wireless transceiver (e.g. Zigbee) need FCC approval?

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the
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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.  


Re: Does EVERY device with a wireless transceiver (e.g. Zigbee) need FCC approval?
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.



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Re: Does EVERY device with a wireless transceiver (e.g. Zigbee) need FCC approval?
[Please remember to choose only *one* group for followups, if you
crosspost.  Fixed.]

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*Every* device you sell (in the U.S.) needs some kind of FCC approval.
In other words, the FCC can take any random device at any time, test
it, and if it violates some FCC regulation, they'll have it removed
from the shelves.

So the actual question is what kind of approval you need.  For some
kinds of devices, approval is implied by the fact they don't do
anything likely to cause trouble, for others, you'll have to run tests
and present results to the FCC to prove all regulations are met, and
you can't go to market without a written statement of approval by the
FCC.

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That depends entirely on the properties of the Zigbee standard, like

0) what frequency range it uses
1) how it manages emission strength
2) what parts of it are controlled by immutable hardware, and what parts
   the software / end user gets to manage

E.g., point 2) is what makes life miserable for WLAN hardware support
on Linux --- chip manufacturers claim they can't publish complete
datasheets because that would enable users to configure the chips to
violate FCC regulations (or their counterparts elsewhere) on frequency
band usage and emission levels.  So you're eventually stuck with a
chip that nobody can be allowed to know how to program without signing
an NDA and further paperework.

--
Hans-Bernhard Broeker ( snipped-for-privacy@physik.rwth-aachen.de)
Even if all the snow were burnt, ashes would remain.

Re: Does EVERY device with a wireless transceiver (e.g. Zigbee) need FCC approval?

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So the chip manufacturers will allow you to mistakenly
violate FCC regulations because they won't give you the
info needed to avoid doing so?

Re: Does EVERY device with a wireless transceiver (e.g. Zigbee) need FCC approval?
[...]

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That's not something for the manufacturer to "allow", anyway.  If
people want to make mistakes, there's exactly nothing their parts
suppliers can do about that.

The message essentially is "Since mistakes in this area could lead to
legal repercussions for both you and us, we're not telling you
*anything* about the device, so you won't even get to the point where
you could make them until."  The part maker wants someone else they
can point the blame to in case the FCC or one of its international
brethren comes after them.  

At the root of all this is that WLAN regulations are different in
various regions of the world, but the parts makers want to sell the
same hardware everywhere.  To get out of that fix, they make the chips
software-driven, with the firmware uploaded by the OS driver for the
chip adapting it to the local specifics of regulation.  But that means
errors or manipulations to that firmware are all it would take to
violate those regulations.  

In the end, this means that something happened that wasn't originally
foreseen: that pure software could be under FCC regulation.  Now all
that remains is to find a way to stick an FCC approval seal onto a
driver update downloaded from some website...

To some extent, this is the result of a conflict of cultures between
lawyers and engineers.  Every engineer will know that shit sometimes
just happens, with no individual to be blamed.  But the world of law
refuses this notion, following their ancient principle "It doesn't
really matter who, but some punk _will_ hang for this", amended by the
golden rule of all corporate lawyering: "... and it's sure as shit not
going to be us!".

--
Hans-Bernhard Broeker ( snipped-for-privacy@physik.rwth-aachen.de)
Even if all the snow were burnt, ashes would remain.

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