EEVblog Electronics Community Forum

General => General Technical Chat => Topic started by: homeward on September 13, 2016, 11:27:01 am

Title: Can anyone help with some FCC questions please?
Post by: homeward on September 13, 2016, 11:27:01 am
Hello,

Apologies if this is the wrong forum, feel free to move. I'm looking for some pointers with regards FCC certification, I appreciate this is no substitute for proper legal advice but any help would be most useful. I have read into this somewhat but there are number of things I cannot find answers for.

I have an unintentional radiator product that I am starting to sell from the UK to within the EU, I have been approached by a few potential customers in the USA wanting to buy what I make. I'd like to know, basically...can I legally get away with not FCC certifying. My thoughts are, these are very small numbers, custom one off designs, do such things need certifying?

Quote
The FCC Declaration of Conformity or the FCC label or the FCC mark is a certification mark employed on electronic products manufactured or sold in the United States
Since I'm not producing or selling in the US (selling to the US), would I be exempt?

It seems that individuals in the US are allowed to import three or fewer devices as long as they are for personal use and not intended for sale...where would that put me as the exporter?

Many thanks.
Title: Re: Can anyone help with some FCC questions please?
Post by: Neilm on September 13, 2016, 06:37:44 pm
If it passes the tests for the EU, I would have thought it would be OK for the USA - if it does not pass the tests for the EU, you shouldn't be selling it in the EU
Title: Re: Can anyone help with some FCC questions please?
Post by: T3sl4co1l on September 13, 2016, 09:01:15 pm
It's up to the importer to verify if the product satisfies local laws. :)

Tim
Title: Re: Can anyone help with some FCC questions please?
Post by: wraper on September 13, 2016, 09:15:38 pm
If it is not something huge and very expensive, then very unlikely there will be any problems at customs, it is importer's problem anyway.
Title: Re: Can anyone help with some FCC questions please?
Post by: homeward on September 14, 2016, 04:36:11 pm
Thanks chaps, that's what I was hoping to hear! Whilst I'm confident it would pass testing, the fees would seriously reduce (all?) all profit and not really worth it for 2 or 3 sales.


It's up to the importer to verify if the product satisfies local laws. :)

Tim

Do you know where it states this please, so I can put my mind to rest!
Title: Re: Can anyone help with some FCC questions please?
Post by: tatus1969 on September 14, 2016, 06:28:29 pm
anyway, is that a self declaration like CE in Europe? Or do you have to always go through lab certification to do it correctly?
Title: Re: Can anyone help with some FCC questions please?
Post by: rsjsouza on September 14, 2016, 07:03:43 pm
Check
https://www.fcc.gov/oet/ea/importation (https://www.fcc.gov/oet/ea/importation)

Thanks chaps, that's what I was hoping to hear! Whilst I'm confident it would pass testing, the fees would seriously reduce (all?) all profit and not really worth it for 2 or 3 sales.
Depending on what relationship you have with the certification agency, bundling FCC and ICES (Canada) into your EU testing should not be very expensive. Obviously that depends on how important and profitable these sales are.

If you did tests on EU and your product falls into a harmonized code, then there is a higher chance your product will not be blocked in the port of entry. However, from question 4 of the reference above:
Quote
Importers should not consider the lack of a flag, or the presence of an FC3 flag or FC4 flag, as a definite indication that a product is regulated by the FCC. 

It's up to the importer to verify if the product satisfies local laws. :)
Do you know where it states this please, so I can put my mind to rest!
Question 5 of the reference above:
Quote
If requested, the ultimate consignee must be ready to provide to Customs and/or the FCC the specific equipment authorization documentation.

anyway, is that a self declaration like CE in Europe? Or do you have to always go through lab certification to do it correctly?
It is not self-declared, nor the FCC mark needs to be put in every device. However, depending on the product category you must go through lab cert. Question 1 of the reference above.
Title: Re: Can anyone help with some FCC questions please?
Post by: wraper on September 14, 2016, 07:09:16 pm
anyway, is that a self declaration like CE in Europe? Or do you have to always go through lab certification to do it correctly?
CE *is* self declaration. However it's not like you can just slap on the CE mark (you can if don't care about possible consequences). You need to keep a technical file which proves that it is CE compliant, and be ready to show it to authorities at any moment.
Title: Re: Can anyone help with some FCC questions please?
Post by: homeward on September 14, 2016, 07:26:45 pm
It's up to the importer to verify if the product satisfies local laws. :)
Do you know where it states this please, so I can put my mind to rest!
Question 5 of the reference above:

Thanks very much, from the link above...point 3-7 states
Quote
Three or fewer radio receivers, computers, or other unintentional radiators as defined in Part 15, are being imported for the individual's personal use and are not intended for sale.
I guess that's the golden ticket? As my customer would only be importing one, for their personal use it sounds like these would be exempt.