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

[raulduke]

Well this is interesting. I imagine the FCC will go after the big fishies first... then they will go for the slimmer pickings.

The company I work for need pre-compliance testing carried out on a device we are in part developing.

Cost for a days pre-compliance testing = £1000.00.

That doesn't even get you through the required validations and approvals. It's just to see if the device has any emissions or immunity problems that need eradicating before full testing and approvals commence.

My guesstimate for the testing and GBA (General Buggering About) would be at least 5 days for the full tests. So we are talking at least 5k.

In the EU you also have to follow very closely the applicable EN standards you need to meet (ie. depending on the application of the device).

You have to purchase the EN standards... which then reference other standards that may require purchasing.

Oh, and they change them every year too.

The whole thing is just a gravy train for the respective governing bodies and their team of representative vampires/solicitors ( )

I imagine it's no different in the US.

[sonarchotic]

There's a video tour of the Marshall factory on YT and they show the room and a little of the process they have to go through for rf testing. It seemed like they were none to pleased with the expense and hassle but a least they are big enough to do it in house. Sounds like a killer for small business's though.

[pickdropper]

CE testing is usually considerably more expensive than FCC testing, but it depends on what tests are being done, of course.  I've had to deal with that on a few products and I don't think it's ever been less than $10k, and $20k isn't unusual at all.

[rullywowr]

At my job we have an extensive set of rf testing "rf anechoic" chambers however we still need to have it done by a 3rd party in order to qualify for CE and FCC compliance.  And it is Very expensive. A common theme is to make variants on similar products which use the same board so once that board is ok it can be used in more than just one product. I imagine the same mentality will be (or already has been) forced on manufacturers like ehx et. al.

[madbean]

I doubt that the FCC will ever go after the little guys like boutique builders. They have little chance of making it worth the effort, I reckon. It's easy enough to target the major players where the big money is to be taken. 450k is a massive payoff compared to 1k from your average Christian Landowner (sorry, inside joke).

Still, it's a bummer.

[jubal81]

I doubt that the FCC will ever go after the little guys like boutique builders. They have little chance of making it worth the effort, I reckon. It's easy enough to target the major players where the big money is to be taken. 450k is a massive payoff compared to 1k from your average Christian Landowner (sorry, inside joke).

Still, it's a bummer.

I think you're probably right, but where it would worry me is it being used as a weapon by some butthurt competitor.

[RobA]

I doubt that the FCC will ever go after the little guys like boutique builders. They have little chance of making it worth the effort, I reckon. It's easy enough to target the major players where the big money is to be taken. 450k is a massive payoff compared to 1k from your average Christian Landowner (sorry, inside joke).

Still, it's a bummer.

I think you're probably right, but where it would worry me is it being used as a weapon by some butthurt competitor.

And, they probably have no choice but to go after you if you are turned in for a violation. All of the actions against music equipment companies I saw at the FCC site were for documentation violations. That's dead simple for them to prove and will cost them next to nothing to take action on. I also doubt if the fine would be in the $1k range just because you are small. I'd expect it to be at least an order of magnitude higher and probably closer to two orders higher. Still, the rules aren't new and the actions I looked at were started up to 5 years ago and there hasn't been any actions taken against boutique builders that I've heard of yet.

What I wonder is if there are any pedals that actually have enough power in the relevant ranges to produce RF emissions that are strong enough to be in violation. Can you legally test for emissions yourself for devices that aren't exempt and then document them yourself and be in compliance?

[davent]

I checked the back of a digital muti-effect box i have and the label says , Complies with the limits for a Class "B" computing device pusuant to subpart J of Part 15 of FCC rules. There's further explanation in the manual and what to do if it interfers with the TV or radio. Got this Yamaha REX 50 in '87 or '88 so these type of rules have been around for awhile, hardly seems likely that EHX was caught unaware.

[midwayfair]

I checked the back of a digital muti-effect box i have and the label says , Complies with the limits for a Class "B" computing device pusuant to subpart J of Part 15 of FCC rules. There's further explanation in the manual and what to do if it interfers with the TV or radio. Got this Yamaha REX 50 in '87 or '88 so these type of rules have been around for awhile, hardly seems likely that EHX was caught unaware.

No one said that the rules haven't been around for a while. What seems to be RECENT (not super recent, but within the last decade) is the 9KHz frequency. I think it used to be much higher.

[madbean]

I doubt that the FCC will ever go after the little guys like boutique builders. They have little chance of making it worth the effort, I reckon. It's easy enough to target the major players where the big money is to be taken. 450k is a massive payoff compared to 1k from your average Christian Landowner (sorry, inside joke).

Still, it's a bummer.

I think you're probably right, but where it would worry me is it being used as a weapon by some butthurt competitor.

That....is very scary.

[Govmnt_Lacky]

For this eample... I would like to use the Klon 

SAME circuit - CHECK!
SAME type components - CHECK!
SAME build materials - CHECK!
Built in aluminum enclosure like original - CHECK!

Cloner not having enough to pay $20K to get some ridiculous FCC emissions check performed even though it is 99% like the original that passed said check - PROBLEM!

Of course, this could apply to just about ALL cloned pedals. I suspect that problems/interference are run into when these "type" circuits are not properly enclosed and shielded. Such as those who build in non-shielded wooden enclosures, plexiglass, phenolic, etc.

[pickdropper]

That doesn't work.  Emissions are often created on a PCB level.  You'd need to certify the product with your layout.

Even if it was functionally identical, their qualification wouldn't pass to a cloner.

[Govmnt_Lacky]

Even if it was functionally identical, their qualification wouldn't pass to a cloner.

Of course not.... no money in that! 

[midwayfair]

Even if it was functionally identical, their qualification wouldn't pass to a cloner.

Of course not.... no money in that! 

Greg, I think you're not understanding what Dave was talking about. There are different methods of PCB construction, layout, etc. that could change whether or not a circuit is compliant. They don't care that you're using a frequency doubler chip in a distortion circuit, they care whether or not the final product complies with the regulations.

[gjcamann]

From sparkfun: https://www.sparkfun.com/tutorials/398

What can I do to avoid expensive testing and still remain in compliance with the laws?
There are two ways to avoid testing: restrict yourself to selling only subassemblies, or restrict yourself to devices on the exempted products list. The exempted product categories are pretty hard to remain within, and are given in section 15.103 of CFR47:

There's a loophole here somewhere. Subassemblies!!