Dev Board Emissions Testing?

[TheAdmiralty]

Evening!

Question.  Let's say I was bringing an FPGA development board to the US market.

Now, I'm having trouble understanding FCC language on marketing something like this.  My understanding is that this sort of thing (think Digilent Basys/Nexys/etc) needs to pass emissions per FCC 47 CFR 15 for unintended radiation since it doesn't specifically fall under any exemptions.  If so, how exactly does one certify an unprogrammed development board?  What would stop someone from just shipping the thing clocked off of the 32Khz internal oscillator, completely powering everything else down, and calling that the intended use?

And at what point does just a PCB without enclosure go from being a subassembly to a retail product?  If I shipped a breakout board with a single 50MHz oscillator and nothing else, what differentiates this from a retail development board?  Would I be expected to blow $10K on testing every single variant of every product?

I know I only have half a clue how this all works right now, so please feel free to enlighten me while I keep reading!

[Tomorokoshi]

I looked at "FPGA" development boards available on Digi-Key. Out of maybe 6 PDF documents from different manufacturers, I couldn't find anything that said anything about FCC, EMC, or other regulations.

One could casually ask their various on-line or FAE resources about what they do for FCC approval of development boards due to internal corporate requirements, etc. to see how they go about it.

Alternatively, you could get one of theirs, set it next to an AM radio, observe interference, then ask a technical question about it and see if there are any reports they can give you.

[T3sl4co1l]

More specifically, you're looking for 15.103c:
https://www.ecfr.gov/cgi-bin/text-idx?SID=8e06b3bd83cc5f8c93b0e47dda2fa673&mc=true&node=se47.1.15_1103&rgn=div8

15.5 says the usual ("doesn't produce harmful interference, accepts harmful interference") and lays out the C&D notification, and 15.29 says they can request equipment or documents.

Tim

[mikeselectricstuff]

One argument is that a devboard is effectively a component, not a finished product, and therefore outside the scope of many EMC and similar requirements.

[TheAdmiralty]

Yep, that's the section I was looking for.  Thanks for the link.

What got me thinking about all this was the silkscreen on this board:
http://www.ti.com/diagrams/tps565208evm-858_tps565208_top.jpg
...would imply that even that little buck converter eval board is not considered a sub-assembly. That said, this seems like them just covering-their-arse since they have so many of these.

I'll avoid going into detail (a lot of paperwork is in flight right now) but I've just incorporated here and am in the process of sorting these things before actually bringing everything online.  Am hemorrhaging money gathering things like PCIe and USB VIDs, etc.  I'll probably just look for a contact to answer this one, should be an adventure to find.