News:

Forum may be experiencing issues.

Main Menu

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

Started by midwayfair, May 06, 2014, 09:42:31 PM

Previous topic - Next topic

pickdropper

Quote from: jkokura on May 07, 2014, 08:53:17 PM
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

There are a lot of questions there and I'm not enough of an expert to answer all of them.  From my limited understanding:

1.) Country of sale dictates what regulations need to be conformed to.  For the US it's FCC (also UL if line voltage is present).  For Canada, it's Industry Canada, for Europe it's the EU (CE Mark).  There are different ones for Australia, Japan, Korea, etc. All of the rules aren't the same, and the 9kHz emission requirements may not apply in all countries.  The onus is on the manufacturer to understand the laws of the land.

2.)  Pedals are fine if they are within the specified emissions standards above 9kHz.  If they don't emit anything above 9kHz (for example a fuzz or a distortion with standard  mechanical switching) then there  are no emissions to be tested.  If they have a clock that operates above 9kHz (most digital circuits) or charge pumps then they most likely won't have excessive emissions but they need to be conformance tested.  If they fail because their RF emissions are above allowed thresholds, they can't be sold until they are modified to conform.

I've never seen anything that tied compliance to the amount of units sold.  From what I understand, the FCC just has set the regulations and products comply or don't and the businesses need to make sure they have done their due diligence (regulators love that phrase).  If it is being sold in a retail environment, it could certainly be considered a commercial product.

I don't know if DIYers are technically exempt, but I think they are certainly off the radar.  Unless you managed to make something that had such large emissions that it actually caused a problem the FCC actually noticed, I can't imagine it would be a problem.  I've never heard of anybody sending a non-commercial product for FCC certification; it just wouldn't make any sense. 

Is it worth it for a small shop to drop the coin for compliance?  That's tough to answer.  I think that most regulators would say yes, but I am sure a lot of small business owners would say no.  The real risk is a financial one.  The odds of the FCC cracking down on a smaller pedal builder is likely very very small.  If they did, however, there could be fines involved.
Function f(x)
Follow me on Instagram as pickdropper

Clayford

I could imagine a certain designer of certain circuit and their assistant being just butt-hurt enough to drop dimes. Not of their own doing mind you...
head solder jockey, part time cook: cranky&jaded

jubal81

The rules say it needs to be tested if it plugs in to the mains ...

"If you put all the knobs on your amplifier on 10 you can get a much higher reaction-to-effort ratio with an electric guitar than you can with an acoustic."
- David Fair

Haberdasher

Quote from: jubal81 on May 07, 2014, 10:37:06 PM
The rules say it needs to be tested if it plugs in to the mains ...


atta boy jubal.  just ship each pedal with one of those and state it's intended to operate on a 9v battery.
Looking for a discontinued madbean board?  Check out my THREAD

FABBED PCB's FOR SALE:
Now carrying Matched JFETS

davent

"If you always do what you always did- you always get what you always got." - Unknown

If my photos are missing again... they're hosted by photobucket... and as of 06/2017 being held hostage... to be continued?

GrindCustoms

Quote from: jubal81 on May 07, 2014, 10:37:06 PM
The rules say it needs to be tested if it plugs in to the mains ...



Haha! Awesome, i send some of those sometime to customer who asks for spare solution.
Killing Unicorns, day after day...

Building a better world brick by brick:https://rebrickable.com/users/GrindingBricks/mocs/

midwayfair

Quote from: Haberdasher on May 07, 2014, 10:44:19 PMatta boy jubal.  just ship each pedal with one of those and state it's intended to operate on a 9v battery.

You know what ... this is probably the real solution.

RobA

I don't think that'll work to get an exemption. The full wording includes,

Quote
Digital devices that include, or make provision for the use of, battery eliminators, AC adaptors or battery chargers which permit operation while charging or that connect to the AC power lines indirectly, obtaining their power through another device which is connected to the AC power lines, do not fall under this exemption.

I think just putting in the DC jack would count as a provision.
Affiliations: Music Unfolding (musicunfolding.com), software based effects and Rockā€¢it Frog (rock.it-frog.com), DIY effects (coming soon).

peAk


rullywowr


Quote from: jubal81 on May 07, 2014, 10:37:06 PM
The rules say it needs to be tested if it plugs in to the mains ...



That is pure genius right there!  I think you solved the issue.



  DIY Guitar Pedal PCB projects!

rullywowr


Quote from: jubal81 on May 07, 2014, 10:37:06 PM
The rules say it needs to be tested if it plugs in to the mains ...



That is pure genius right there!  I think you solved the issue.



  DIY Guitar Pedal PCB projects!

Beedoola


davent

"If you always do what you always did- you always get what you always got." - Unknown

If my photos are missing again... they're hosted by photobucket... and as of 06/2017 being held hostage... to be continued?

pickdropper

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.
Function f(x)
Follow me on Instagram as pickdropper

pickdropper

In case anybody is still even remotely interested in the topic, I've gone a bit further down the rabbit hole.

Here is a copy of the previous ANSI standard that outlines the requirements for compliance.

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

The current standard is ANSI C63.4-2009, but it costs $141 and I wasn't ready to fork that out just yet.  It looks like the new standard has some new info on intentional radiators, so the unintentional transmitters may not have changed much.  This is a good starting point.
Function f(x)
Follow me on Instagram as pickdropper