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

[pickdropper]

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.

Yes, exactly.  How it is put together makes a difference, as does the components used.  The test labs aren't going to spend any time analyzing the circuit.  All they will do is check that the emissions are within spec.

As far as there being money in it, that is true, but the money isn't going to the FCC as they don't do the actual testing.  Now, of course there are lobbyists and of course there are other money funnels, but the bulk of the testing money does not go to the people passing the legislation.

I bet you if the people that owned the test labs wrote the rules, there would be a lot more testing.  ;-)

But yeah, the level of testing and cost gets frustrating, particularly for small businesses.  There needs to be a happy medium.  Some of the testing really is necessary, but some of the rules can be heavy handed.

[Govmnt_Lacky]

I was right on par with what you were saying Dave. Im with ya'

Let me try to simplify my point.

If you put a "circuit" into a 1590B with a 100KHz clock and it passes the FCC inspection (a'la multiple manufacturer's boxes on the market today)

If you take that same circuit... still generating that 100KHz clock.... clone it.... and put it into a 1590B. Where is the problem? Why the need to re-test?

Answer = Money!

Otherwise EVERY Tom, Dick, and Cloner could just leverage off of someone else's FCC qualification.

I wonder how it is sorted? By parent company?

[m-Kresol]

That sounds rather scary... Although it might just be a little bit like music/film/... downloading. Everyone does it, everyone knows that everyone's doing it, everyone knows it's illegal (or at least very immoral) and the only ones who are pursuit are the really big fish/providers...
No matter what, I just wanted to say: we're all pretty badass around here. Real gangsters 

[pickdropper]

The reason you need to test it is because you may have changed something important while cloning it.

I am dealing with the FCC on a product right now.  If The board is changed in a way they deem significant, then I have to redo the FCC testing.  The reason is that the new board could fail in ways the other one didn't.   

The real question is if the standard is valid at all.  I am not the most knowledgable on why the 9kHz rule exists so I'll have to research before saying anything about the validity.  For a lot of the higher bandwidth products, the FCC regs are important, especially for interoperability in an increasingly dense RF world.

I think the cash grab angle is a blatant oversimplification people use because the process is so frustrating, especially if you are just getting started with it (I'm certainly not immune).  But I've known some folks involved with FCC standards.  They may have been a bit officious at times, but none of them made it rich by passing standards.  They probably make more money rejecting and discussing them ad nausium (mostly kidding).

[midwayfair]

I was right on par with what you were saying Dave. Im with ya'

Let me try to simplify my point.

If you put a "circuit" into a 1590B with a 100KHz clock and it passes the FCC inspection (a'la multiple manufacturer's boxes on the market today)

If you take that same circuit... still generating that 100KHz clock.... clone it.... and put it into a 1590B. Where is the problem? Why the need to re-test?

Answer = Money!

Otherwise EVERY Tom, Dick, and Cloner could just leverage off of someone else's FCC qualification.

I wonder how it is sorted? By parent company?

Are you imaginging taking the same circuit BOARD or the same CIRCUIT?

The CIRCUIT BOARD itself can affect the emissions, regardless of the circuit itself.

If you use the exact same circuit board that has been tested for compliance in the smaller enclosure, then there's no need to retest. If you rehouse a pedal, you don't need to retest. But you don't have access to compliant circuit boards manufactured by EHX, Boss, etc. for their pedals anyway if you're building a clone, so, no, anything you build on is almost guaranteed not to be compliant if it generates a clock, and even if you did have their circuit board, as far as a regulatory agency is concerned, you're making your own product anyway, so you don't get to leach off someone else who paid for compliance testing.

Let's try to stay focused on the things that are ACTUALLY stupid about this and what we can do about it, instead of generating conspiracy theories about the money involved.

For anyone interested, the TGP thread has a few posts by medium-sized pedal manufacturers who have done this -- including Diamond -- and others who haven't -- including AnalogMan.

[DutchMF]

I'm wondering what the european, or dutch, equivalent of the FCC might be, and if their rules are as strict. Would it be possible to use me as a middle man to distribute pedals? That being the european rules aren't as strict (probably!)? Looking for loopholes here, let me know if us europeans can help out!

Paul

[Govmnt_Lacky]

I am dealing with the FCC on a product right now. 

Is this for your work? It might help if you were to keep us informed of the process if it regards pedals or effects circuits 

[RobA]

I'm wondering what the european, or dutch, equivalent of the FCC might be, and if their rules are as strict. Would it be possible to use me as a middle man to distribute pedals? That being the european rules aren't as strict (probably!)? Looking for loopholes here, let me know if us europeans can help out!

Paul

From what I can see on the markings on electronics and a couple of searches, the European standard is set out in EN 55022 and CISPR 22 and it is just as stringent, if not more so, as the US laws.

I think people are missing the point that these laws exist for very good reasons. On top of that, it looks to me like the section of the law that EHX and others got hit on is essentially consumer protection. If you, as an end user, have a device that is broadcasting illegally in RF, you will be forced to shut it down and not use it. The reason for the compliance marks is to let consumers know which devices have been properly tested and are safe to buy. That's why the clauses for DIY stuff exist. If you make your own device that violates the air space, then it's only your fault if you have to shut it down.

[RobA]

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.

My impression is that the 9kHz limit is pretty old. I'm guessing that it exists in that section as a way to exempt telephone lines and related equipment from having to meet the rules. Telephony has an upper frequency of 8kHz and I'd imagine it was pretty hard to keep RF from coming off of the giant bundles of wire carrying large numbers of analog phone calls. That is purely a guess though. 

[pickdropper]

If you use the exact same circuit board that has been tested for compliance in the smaller enclosure, then there's no need to retest. If you rehouse a pedal, you don't need to retest. But you don't have access to compliant circuit boards manufactured by EHX, Boss, etc. for their pedals anyway if you're building a clone, so, no, anything you build on is almost guaranteed not to be compliant if it generates a clock, and even if you did have their circuit board, as far as a regulatory agency is concerned, you're making your own product anyway, so you don't get to leach off someone else who paid for compliance testing.

Actually, changing the box could have an effect as RF emissions can be different if the wiring scheme changes or possibly even the enclosure.  Now, at 9kHz it's not as much of an issue, but at 2.4GHz, you have to worry about little metal bits acting as an antenna.

Let's try to stay focused on the things that are ACTUALLY stupid about this and what we can do about it, instead of generating conspiracy theories about the money involved.

Totally agreed.

[pickdropper]

I am dealing with the FCC on a product right now. 

Is this for your work? It might help if you were to keep us informed of the process if it regards pedals or effects circuits 

Not at all related to pedals or effects circuits. 

[midwayfair]

My impression is that the 9kHz limit is pretty old.

1932, to be precise ...

[pickdropper]

I'm wondering what the european, or dutch, equivalent of the FCC might be, and if their rules are as strict. Would it be possible to use me as a middle man to distribute pedals? That being the european rules aren't as strict (probably!)? Looking for loopholes here, let me know if us europeans can help out!

Paul

From what I can see on the markings on electronics and a couple of searches, the European standard is set out in EN 55022 and CISPR 22 and it is just as stringent, if not more so, as the US laws.

I think people are missing the point that these laws exist for very good reasons. On top of that, it looks to me like the section of the law that EHX and others got hit on is essentially consumer protection. If you, as an end user, have a device that is broadcasting illegally in RF, you will be forced to shut it down and not use it. The reason for the compliance marks is to let consumers know which devices have been properly tested and are safe to buy. That's why the clauses for DIY stuff exist. If you make your own device that violates the air space, then it's only your fault if you have to shut it down.

Yeah, the European Union is notoriously strict.  Beyond compliance testing for emissions, read up on REACH and RoHS 2 compliance. 

[pickdropper]

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.

My impression is that the 9kHz limit is pretty old. I'm guessing that it exists in that section as a way to exempt telephone lines and related equipment from having to meet the rules. Telephony has an upper frequency of 8kHz and I'd imagine it was pretty hard to keep RF from coming off of the giant bundles of wire carrying large numbers of analog phone calls. That is purely a guess though.

I was discussing this with one of my co-workers today.  He seems fairly convinced that the 9kHz standard became a bigger deal in the 80's because of household devices interfering with television reception, but I haven't looked up the history to see if that is correct.

[jkokura]

I've been trying to understand all this, and what it truly means/impacts. Let me know which option I have is correct:

1. This affects products (pedals) that are:
a) sold in any US physical retail stores (online excluded) to US customers
b) sold in any US story (online and physical) to US customers
c) sold in any store worldwide (online or physical) to US customers
d) sold in any US store (online or physical) to any country worldwide
e) Sold in any story worldwide (online or physical) to worldwide customers

2. Pedals are fine if they:
a) Do not contain charge Pumps, PT2399's or FV1 chips
b) Do not contain analog BBD technology (Chorus, Delay, Flange, Etc)
c) Are made in small numbers
d) Are made and sold from outside the US

3. DIY pedals are fine?

If that sums it up, in the end, what does a very small shop like mine really need to pay attention to? Do I need to pull and stop selling anything with a Tap Tempo or Charge Pump in it?

Jacob