Good to know - FCC regulations

[GibsonGM]

Seriously, any company planning to sell pedals needs to include in their business plan to consult an attorney who can explain all of the regulations, have their products tested, file the proper forms, and if necessary, provide the proper labeling.  Ca-Ching $$$

Right, part of a business plan is to help you determine if the business can be profitable before diving in including the expense for regulations, statutes etc.. As long the regulations are applicable they need to be top of mind, properly evaluated and considered up front. If one is successful and purposely tries to fly under the radar, they eventually end up in the news. 

Yes, and now think of all the ones who COULD have been successful, but can't afford to 'play by the rules' (whose rules??  The big dogs with the power).   That's what over-regulation does - it ruins markets, stunts creativity, and puts a ball and chain on the market(s).  Eventually, nobody wants to play anymore.  OR - it's worth more to you to take the risk under the radar, creating MORE problems for people rather than less.

The cost of "compliance" is actually simply money that is taken out of the economy, since it does NOTHING, serves no useful purpose.  Just like the money paid to attorneys and accountants when you have an overly-complex and very punitive tax code.   It's simply waste.  Damn shame; I personally could have hired a couple of guys this year, but "the cost of compliance" just cost those two mystery workers decent jobs.  I had to pay to remain 'legal', and taking 2 workers on would have put my biz in jeopardy.      *shrug* 

Get used to it, you'll see much more of that going forward.   This is apolitical, BTW; it's about public policy, not "politics".

[CodeMonk]

I dunno if this has been posted (I'm sure a few here have found their way to this link already)...
http://www.ecfr.gov/cgi-bin/text-idx?SID=e496c9bf69a719781578cfa0373e06fd&tpl=/ecfrbrowse/Title47/47cfr15_main_02.tpl
More specifically for us:
http://www.ecfr.gov/cgi-bin/retrieveECFR?gp=&SID=e496c9bf69a719781578cfa0373e06fd&n=47y1.0.1.1.16.2&r=SUBPART&ty=HTML

[PRR]

> things (like my air conditioner) that are actually polluting the spectrum

§15.103   Exempted devices.

The following devices are subject only to the general conditions of operation in §§15.5 and 15.29 and are exempt from the specific technical standards and other requirements contained in this part. The operator of the exempted device shall be required to stop operating the device upon a finding by the Commission or its representative that the device is causing harmful interference.

(d) A digital device utilized exclusively in an appliance, e.g., microwave oven, dishwasher, clothes dryer, air conditioner (central or window), etc.

Build your digi-pedal into a clothes dryer.

[Jdansti]

^ Looks like the appliance manufacturers spent a little money up front on lobbyists to save a bunch later.

[TOPLEL]

Could something like an ADA Flanger pass this test built into a shielded alu enclosure?

What about the modular synth guys? Their stuff is not shielded, will all of their modules fail these tests?

[amz-fx]

Could something like an ADA Flanger pass this test built into a shielded alu enclosure?

What about the modular synth guys? Their stuff is not shielded, will all of their modules fail these tests?

If the power is low and the pcb is properly designed, an enclosure may not even be needed to pass the emissions tests. For example, the Arduino Uno has been certified and it is an exposed pc board.

Most pedals are low power and you would expect the radiated emissions to be low, but this does not alleviate the need to test the product.

Also, for DIY guys: Part 15.23   Home-built devices. (a) Equipment authorization is not required for devices that are not marketed, are not constructed from a kit, and are built in quantities of five or less for personal use.

regards, Jack

[R.G.]

Sure puts a crimp in the guys who come here not knowing how to solder and then having a web site up to sell boutique pedals two weeks later, though.   

[Jdansti]

It would be interesting to know if any of the dozen boutiquers on the forum are testing and using labeling. Those who aren't would probably be better off not saying anything.

[Govmnt_Lacky]

Sure puts a crimp in the guys who come here not knowing how to solder and then having a web site up to sell boutique pedals two weeks later, though.   

You mean these guys:



 

[midwayfair]

^ Looks like the appliance manufacturers spent a little money up front on lobbyists to save a bunch later.

It's because you can't hook up those devices just anywhere. Most driers need a gas line, and washers need a water line. Houses are already set up to have them in a specific place.

>Part 15.23   Home-built devices. (a) Equipment authorization is not required for devices that are not marketed, are not constructed from a kit, and are built in quantities of five or less for personal use.

Does this mean that KITS (like from BYOC) are potentially a problem -- i.e., you sell a kit, someone builds the kit, do the people selling the kit need to get certification? I sure hope not. It's not an emitter when it's sold.

Oh, quoting TH Custom here (from the Madbean thread) for the EU guys. Not legal advice, etc., but I wonder whether there's a similar workaround under the U.S. guidelines:

I only know the european rules with RF testing. You need to do this to get the CE-sign. No sign, not able to sell a single device.

The procedures to test things are very complex but the is a lot of writing about 'similar devices' that dont need testing.

Where they get you is if you dont write about possible interferences in your manual.
If you state that your device should not come near audio amplification because it might impact it and if you say that cell phones should be kept away from your device you are fine.

I know this is crazy to tell people that they should not put their new effect pedal near an amplifier, but the point is that if you tell the buyer you have met the guidelines!

[TOPLEL]

Could something like an ADA Flanger pass this test built into a shielded alu enclosure?

What about the modular synth guys? Their stuff is not shielded, will all of their modules fail these tests?

If the power is low and the pcb is properly designed, an enclosure may not even be needed to pass the emissions tests. For example, the Arduino Uno has been certified and it is an exposed pc board.

Most pedals are low power and you would expect the radiated emissions to be low, but this does not alleviate the need to test the product.

Also, for DIY guys: Part 15.23   Home-built devices. (a) Equipment authorization is not required for devices that are not marketed, are not constructed from a kit, and are built in quantities of five or less for personal use.

regards, Jack

And what will happen with something like a one man modular synth business? For example where the guy sells 10-15 different modules where most of them have some digital clocking here and there. Is he forced to spend 10-15x1000 dollars to get them measured and stuff? I hope my favourite guys won't vanish from the net because of this. Or this won't be enforced that seriously?

[slacker]

This mentions kits https://www.sparkfun.com/tutorials/398 seems clear as mud.

[Mark Hammer]

Well, it's not like these regs came into effect this week.  The articles I linked to concerned a fine that EHX paid much earlier last year, and related to infractions from previous years.  EHX is a big company with lots of products and customers, and extensive worldwide distribution: i.e., a big target, low-hanging fruit, or whatever metaphor you want to use.  I think the little guys are pretty safe for now.  Even if they aren't, one little guy in a herd of 1,000,000 stampeding wildebeest has a pretty good chance of not being the one the cheetah takes down.

BTW, that Sparkfun writeup is pretty decent.  Thanks.

[slacker]

I was going to say the same Mark, I don't think this stuff is new, I've got Boss pedals that are probably 15 years old that have statements on them saying they're compliant with part 15 of the FCC rules.

[davent]

I was going to say the same Mark, I don't think this stuff is new, I've got Boss pedals that are probably 15 years old that have statements on them saying they're compliant with part 15 of the FCC rules.

My Yamaha REX 50, bought in 1987-88 has the FCC compliance sticker on the back as well as more info in the manual.

[Mark Hammer]

I don't know that the discussion is entirely over, but I did want to say that it has been most instructive.  I didn't dream when I started the thread that it would generate such interest and "digging down" by members who were variously familiar with the technology, and with the law and/or regs.

It's been fascinating.  And with any luck and foresight, none of us here will be paying a $450,000 fine! 

Thanks, one and all. You've done a service to your colleagues.

[Digital Larry]

^ Looks like the appliance manufacturers spent a little money up front on lobbyists to save a bunch later.

It's because you can't hook up those devices just anywhere. Most driers need a gas line, and washers need a water line. Houses are already set up to have them in a specific place.

I wouldn't be so sure about that...  washers on stage

[wavley]

^ Looks like the appliance manufacturers spent a little money up front on lobbyists to save a bunch later.

It's because you can't hook up those devices just anywhere. Most driers need a gas line, and washers need a water line. Houses are already set up to have them in a specific place.

I wouldn't be so sure about that...  washers on stage

I forgot about the Geddy Lee thing!!

I don't see what not being hooked up just anywhere, while I see your reasoning and it's probably what they used, has anything to do with being exempt.  Last time I checked a Faraday cage isn't usually a feature built into a laundry room, so it's selective enforcement of the rules by excluding some of the biggest radiators.  When I was having my problem a HAM I worked with said "It's probably your air conditioner, I pick them up all the time" and let me borrow some equipment to track it down.

[Unlikekurt]

Is anyone aware of how this impacts the sale of a dc switching wallwart with a pedal?
At that point you are a reseller.  Is this covered in some manner such as how MSDS or IMDS is handled?  By having the certification of your vendor you are then good to go.  Or would that not be sufficient, in which case you'd be better suited to not include the powering device with your units?

[pickdropper]

This is the third thread  on three forums that I read dealing with this.  Hopefully, I can keep it all straight.

For anybody that enjoys a good read, here is a link to the previous ANSI standard that covers this.  The current version is the 2009 standard, but I couldn't find a link to it and I didn't feel like paying nearly $150 for it.

http://ecee.colorado.edu/~ecen4517/materials/refs/standards/ANSI_C63.4-2003.pdf

This is a copy of the post I put on TGP:

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Anything can generate noise, the FCC only appears to care if it is above 9kHz. The rules aren't new; they've been around for decades. According to a friend of mine, they really began leaning on this in the the 80's when a lot of complaints rolled into the FCC about interference with television reception (apparently from personal computers and video game systems). There's a WIKI article that doesn't dig too deep, but it's a starting point:

http://en.wikipedia.org/wiki/Home_co...y_interference

The rules have been there for a long time, it just hasn't trickled down to most of the small fish yet. Will it cause any issues if they don't comply? That's hard to say. Could it cause them to get fined? Certainly.

As far as the FCC knocking down your door and asking you to surrender your pedal/mixing board/etc, that is HIGHLY unlikely. If you had an unlicensed radio station and a cluster of klystron tubes, they'd be more interested. But for a 9kHz offender? Not likely unless your device is causing serious problems to somebody else and they complain to the FCC.

------------------------------------------------

And this is what I posted on Madbeans:

-------------------------------------------------

Here's a bit more info that I've found:

http://www.bureauveritas.com/wps/wcm/connect/31b53f004edb713e8d5fcd600bbc220b/FCC_Frequently_Asked_Questions_Aug10.pdf?MOD=AJPERES

For those who CBA to read the link, here are a couple of salient points:

"Battery power is not an exemption. Even a cell ph
one can broadcast for miles. Toys are not exempt
either. Toys can make more radio noise than other equipment because plastic or plush enclosures
do not shield the electronics like a metal box may.
Manufacturing run is not exempt either. Even if
you make and sell only a handful of devices,
it needs FCC equipment authorization. "

It also breaks down what types of testing are needed.  For a 9kHz device like a pedal, it is an unintentional radiator and only needs verification testing (basically, it needs to be checked to ensure that it passes emissions standards).  I assume that one could self-certify assuming there was access to the test equipment and an anechoic chamber.  I am not sure about that.  Unintentional radiator does seem to have the least stringent requirements.  Compare that to something like a Bluetooth device, where you have to do all of the testing, get certified and register with the FCC.

"The FCC has four main categories of equipment authorization:

Verification (unintentional radiators)

Declaration of Conformity (unintentional radiators that connect with PC's or television systems)

Certification (intentional radiators, radar detectors)

Registration (telephones & telecommunication devices)
Different authorization is needed for different types of equipment. Technical expertise is needed to
evaluate the design to ensure correct authorization. "

I'm still trying to figure out what the overall bottom line is to this.  I'm hoping I can find something that is reasonable as far as cost but qualifies from a regulatory perspective.

----------------------------------------

Basically, pedals would fall into the category of "unintentional radiator" unless they have bluetooth or some other wireless design built into them.  FCC testing for anything that radiates emissions at frequencies 9kHz or above has been in place for a long time, it's just bubbling to the surface now.  Everybody is bound by its rules, but not everybody who ignores the rules will run into issues, much like it is now.  The cost of being wrong is potentially high, however.


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