More questions on color reader...

Interesting. It doesn't really do that much, does it... ;-)

Ok, that is an error in the schematic. Those are all three 10K resistors. It was correct on the board... ;-)

I had built in a test for the 'CLEAR' component, where I measured the ambient, and subtracted it from the measured values, built in testing it was always so low I didn't feel the need to keep it in. Might need to test that hypothesis now...

Thanks!!!!

Charlie

Hmmmm... It is definitely not an intentional radiator, and no clock outputs leave the chip. The two switchers are only going to a cap less than

10 mm from the chip. Would never have thought anything this simple could need certification. Jeorge? Any thoughts?

Thanks, Charlie

Well, there are paths of self-certification:

I run into this a lot. Is a change serious enough to warrant re-cert? Most clients do it anyhow, send the stuff to an EMC lab. But it's expensive, basically we rarely get out of there under $5k. If this is more like a non-profit product and helps the visually-impaired you may be able to convince a lab to do a "charity run".

But first I'd fix that "CLEAR" ambient subtraction routine that must have fallen through the cracks ... whoops ... got to have that :-)

--
Regards, Joerg

http://www.analogconsultants.com/

"gmail" domain blocked because of excessive spam.
Use another domain or send PM.

Ok, so if we market this device in the US, since it has a MCU in it, then we have to get certified by the FCC that we don't radiate?

We may just have gone out of business!!!!!!

Charlie

Stricly speaking, I think that's the case, but it also seems that the FCC doesn't really care that much when you're small: There are many companies selling various ham radio-related accessories all over the Internet (and many of them ARE intentional radiators), most of them are not certified (well, maybe they're self-certified, but you can guess how many of those ever saw a real test lab...), and they seem to stick around year after year.

Just a couple of examples:

Some of them seem to get away by calling their wares "kits" wherein, while you get a fully-assembled PCB, you have to connect up a few cables and put the screws in the case to finish things off...

Seems to me there's a rather large grey area here!

---Joel

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I wasn't too sure about whether the LED's were modulated, and if so, at what frequency, etc..,

Your device appears to be in the same family tree as small battery- powered calculators and TV remotes. In other words, a Class-B (household) digital device, configured as an unintentional radiator Note: A digital device is pretty much anything with a clock faster than 9 kHz.

Typically, these types of devices will have DoC's, and I suspect yours should as well. That said, the rules appear vague and flexible enough to allow Verification.

See FCC Rule 15.101. Link:

1-part15.pdf

Sorry to rain on your parade, (if I have?). Just thought you should be aware, particularly given the advertising thing. The good news is that Verification / DoC is a lot cheaper, easier and faster to get than a full-blown TCB Equipment Certification.

Again, best of luck getting the bugs out!

-mpm

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No. Kits are covered under the regs.

I agree that as a practical matter, nobody will complain unless / until interference to some other licensed radio service occurs. If / when that happens, the last thing you want is no DoC, Verficiation or FCC ID on file for your gear. - particularly if someone gets hurt. That an invitation to get fined and sued into the poor house. (I'm thinking about those motorized wheelchair controllers that went crazy every time a taxicab radio keyed up in the vicinity!)

But before jumping ship, Charlie -- just call the folks at the FCC OET in Washington, describe your product, and see if you can squeak by with Verification. If so, no money out of pocket -- assuming you know how to self- certify, and have access to the right test equipment.

Even if they require a DoC, all is not lost. Shop around. It may be cheaper than you think!

Looks like something NASA would do.

Or a competitor gets a burr under their saddle.

IME, EMI compliance is pretty cheap (though test labs vary quite a bit). It's all the rest of the stuff that takes time and $$. If there is no AC power (even a charger) most of that goes away.

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Hey Joel,

Tigertronics is FCC registered. Link:

I didn't check them all, or course; nor every product Tiger has. I did pull up one of their manuals (online PDF) and if that's what comes in the box, I think you're right - they are violating some specific FCC rules. I would also question whether the device itself is marked with the FCC ID#, as required by law. ???

-mpm

Ok, heart attack over. From the FCC at

looks like we don't even have to file anything, just put a note in our instructions that we meet (verification) the specs. Whewwww... you had me worried there!

Charlie

Add software to sample levels and other parameters that you measure in the lab; samples to be stored where you can get at them later at worst or add display for them.

I'm in another country Charlie, but have had similar compliance issues with low volume items. If you feel the need, find a friendly EMC test lab and see if he will rent himself to you for a couple of hours & provide you with a couple of spectrograms to show that emissions are acceptable. The cost goes up up up if the lab writes up any report for you.

Yabbut... the point was that exactly what constitutes a "kit" seems to be a bit of a gray area as well. I'm pretty sure this product here:

is officially a "kit," even though it really is nothing more than plugging in some cables, screwing the PCB to the case, and screwing the case itself together.

---Joel

Thanks, that's more than I had figured.

I'll have to check my SignaLink USB, but I don't *think* there's an FCC sticker on the bottom.

I know my AADE LCR meter certainly doesn't have any FCC stickers on it!

a

ing

Whether it is a kit or not, it would be covered by the rules. This part of FCC regulation is well-settled law. I know of no enforcement action to the contrary going back at least a dozen years.

On Apr 26, 3:07=A0pm, Charlie E. wrote: [about a color meter]

Well, yes, of course that happens. You're looking at ratios of RGB light intensities, and when the color is dark, your inputs are R =3D 0 + noise G =3D 0 + noise B =3D 0 + noise and it isn't surprising that the ratios are dominated by ... noise.

= Well, yes, of course that happens. You're looking at ratios = of RGB light intensities, and when the color is dark, your = inputs are = R = 0 + noise = G = 0 + noise = B = 0 + noise = and it isn't surprising that the ratios are dominated by ... noise.

Therefore, he should set a threshold above noise and call anything below that "dark".

It just seems as though the rules for kits are rather more lax than for completely assembled widgets.

That's true of most things, though, I suppose... you can probably readily sell someone a kit of parts for a howitzer, whereas selling the assembled unit is rather trickier. :-)