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

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.

Reply to
Mike V.
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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.

Reply to
Jim Stewart

*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.

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 (broeker@physik.rwth-aachen.de)
Even if all the snow were burnt, ashes would remain.
Reply to
Hans-Bernhard Broeker

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.

Reply to
Mike V.

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?

Reply to
Everett M. Greene

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

Reply to
Meindert Sprang
[...]

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 (broeker@physik.rwth-aachen.de)
Even if all the snow were burnt, ashes would remain.
Reply to
Hans-Bernhard Broeker
[...]

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." 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 rather unexpectedly pure software can fall under FCC (et al.) 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 (broeker@physik.rwth-aachen.de)
Even if all the snow were burnt, ashes would remain.
Reply to
Hans-Bernhard Broeker

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.

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

Reply to
wkearney99

much snippage...

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.

Reply to
Jim Stewart

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.

Reply to
Dave Houston

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.

Reply to
Jim Stewart

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.

Reply to
Dave Houston

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 to
Jim Stewart

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 to
Dave Houston

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.

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 to
Jim Stewart

the

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 to
Dave Houston

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 to
Mike V.

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.

Reply to
Mike V.

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 to
Dave Houston

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