Well, looks like the FCC has made a bunch of pedals illegal

[RobA]

It's already played out. The stuff with EHX was finished on April 22, 2013. It started back in 2010. If you search the FCC site, there are other cases with Fender, Mackie, and others that are from even earlier. It looks to me like they just weren't in compliance with either documentation or testing. I can't figure out which from the docs. But, the main thing is that it doesn't look to be anything new and it hasn't stopped any of these companies yet.

That why i don't understand why the manufacturer of the IC or whatever device have'nt stop their production or devellopement.... there's certainly something we are missing here.

I tried to go through all the text, but the technical writting make it like a russian dictionnary for me to read.....   and can't find any articles about it in french... i'm damned to ignorance.

I don't know for sure, but I don't think there is an actual problem with any device. The wording makes me think it is purely with their compliance on the testing and/or documentation end of things.

Edit: by "their" I mean the end product manufacturers (EHX, etc.), not the producers of the IC's or other components.

[Peteyboy]

Explained this to my wife. her response: go hide all the dog whistles before the FCC takes them away.
seriously though 9kHz is way too low.

[RobA]

Explained this to my wife. her response: go hide all the dog whistles before the FCC takes them away.
seriously though 9kHz is way too low.

I still haven't seen anything in the documents or the rules that says anything about 9kHz. One thing to note though is that clocks often use square waves which would have harmonics well above 9kHz and the rules have to do with the actual frequency that a device radiates at.

[midwayfair]

Explained this to my wife. her response: go hide all the dog whistles before the FCC takes them away.
seriously though 9kHz is way too low.

I still haven't seen anything in the documents or the rules that says anything about 9kHz. One thing to note though is that clocks often use square waves which would have harmonics well above 9kHz and the rules have to do with the actual frequency that a device radiates at.

The EHX compliance doc cites the section. It's s15 something.

[RobA]

Explained this to my wife. her response: go hide all the dog whistles before the FCC takes them away.
seriously though 9kHz is way too low.

I still haven't seen anything in the documents or the rules that says anything about 9kHz. One thing to note though is that clocks often use square waves which would have harmonics well above 9kHz and the rules have to do with the actual frequency that a device radiates at.

The EHX compliance doc cites the section. It's s15 something.

The EHX doc cites sections 15.19 and 15.105 with "Labelling requirements" and "Information to the user" resp. I don't see that they mention a specific frequency. I could be missing it. There are very specific statements about what the requirements are in other sections though. And they go into detail about what's allowed back onto power lines and everything else in the world.

The section I can find (15.109e Radiated emission limits) says,

Carrier current systems used as unintentional radiators or other unintentional radiators that are designed to conduct their radio frequency emissions via connecting wires or cables and that operate in the frequency range of 9 kHz to 30 MHz, including devices that deliver the radio frequency energy to transducers, such as ultrasonic devices not covered under part 18 of this chapter, shall comply with the radiated emission limits for intentional radiators provided in §15.209 for the frequency range of 9 kHz to 30 MHz.

This doesn't seem to apply to me and even if it does, the limit is specified and wouldn't be that hard to achieve.

Edit: Hmm, now I think it does apply. It would really apply to modular synths. Still, any manufacturer would just need to verify that the device complies with the emission standards and the documentation. As far as the emission goes, the devices already need RF shielding just to work correctly.

[RobA]

One thing that does look to be an issue though is that the rules are going to be pretty hard on boutique builders. The testing isn't exactly cheap for someone that isn't making a significant profit from it. One of the sites I saw quoted something like (US)$1000 to get the testing done for a product. You'd need to sell quote a few to make that up.

[pickdropper]

One thing that does look to be an issue though is that the rules are going to be pretty hard on boutique builders. The testing isn't exactly cheap for someone that isn't making a significant profit from it. One of the sites I saw quoted something like (US)$1000 to get the testing done for a product. You'd need to sell quote a few to make that up.

The last quote I saw was about $2k for this type of testing.

[nzCdog]

crazy 

[mattlee0037]

My next step is to build a company to test these for all pedal builders and offer it slightly cheaper than others and profit

[GrindCustoms]

This exemption case:

Joystick controllers or similar devices, such as a mouse, used with digital devices but which contain only non-digital circuitry or a simple circuit to convert the signal to the format required (e.g., an integrated circuit for analog to digital conversion) are viewed as passive add-on devices, not themselves directly subject to the technical standards or the equipment authorization requirements.

Would'nt it exempt the use of a charge pump in a pedal? If no digital device are used in the unit, like an OD.

[RobA]

This exemption case:

Joystick controllers or similar devices, such as a mouse, used with digital devices but which contain only non-digital circuitry or a simple circuit to convert the signal to the format required (e.g., an integrated circuit for analog to digital conversion) are viewed as passive add-on devices, not themselves directly subject to the technical standards or the equipment authorization requirements.

Would'nt it exempt the use of a charge pump in a pedal? If no digital device are used in the unit, like an OD.

My interpretation of all of this is that it only applies to complete, end-user products. So, no component, like an IC, has to comply by itself.

It seems to me that a MIDI controller might be covered by that exemption, but I'm pretty sure that wasn't the point of the exemption.

[pickdropper]

My next step is to build a company to test these for all pedal builders and offer it slightly cheaper than others and profit

That would probably work if:

- You have enough start-up cash to get the necessary equipment plus the cost of getting it calibrated by NIST.

- You can line up a lot of pedal builders.

[alanp]

The FCC is (and has been) lobbied heavily by those who purchased the 700 MHz spectrum (Verizon, AT&T, Qualcomm, etc) to protect their investment.

Perhaps this is because I was not raised in America (a pie to me is meat of some sort in a pastry enclosure, not pizza or one of those fruit pie things), but I tend to read "lobbying" as "America has the best government money can buy!"

If I'm understanding lobbying to basically be nagging the living shit out of, and bribing like hell.

I could be wrong, I probably am.

[haveyouseenhim]

Perhaps this is because I was not raised in America (a pie to me is meat of some sort in a pastry enclosure, not pizza or one of those fruit pie things), but I tend to read "lobbying" as "America has the best government money can buy!"

If I'm understanding lobbying to basically be nagging the living shit out of, and bribing like hell.

I could be wrong, I probably am.

I have never read a more correct statement in my life.

[Thomas_H]

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!