Ray Russell
- Apr 28, 2018
- 4
- Joined
- Apr 28, 2018
- Messages
- 4
Hi all,
I have designed a personal device that fits inside a key ring fob.
It does not connect in any way or under any conditions to the AC mains.
The device operates at very low duty cycle and can operate at very low system clock speeds.
The device is aimed at the consumer market.
I am interested in manufacturing this device and realize that the device must pass FCC Part 15b regulations.
As far as I can tell there are two areas within 15b that seem to apply to my situation:
1) This is the regulation:
From §15.103 "(h) Digital devices in which both the highest frequency generated and the highest frequency used (my emphasis in two places) are less than 1.705 MHz and which do not operate from the AC power lines or contain provisions for operation while connected to the AC power lines. 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."
My comment:
I can certainly reduce my clock frequency down below 1.705 MHz. However, the signal edge speeds will be significantly higher than 1.705 MHz so I imagine that I would run afoul of the "generated" part.
2) And this appears to be the definition of "Digital Device" as used above:
From 47 CFR § 15.3 "(k) Digital device. (Previously defined as a computing device). An unintentional radiator (device or system) that generates and uses timing signals or pulses at a rate in excess of 9,000 pulses (cycles) per second and uses digital techniques; inclusive of telephone equipment..."
My comment:
Notice that in item 2) there is no mention of "generated", it only addresses "timing signals or pulses". So if I reduce my system clock source to less than 9KHz does that knock me out of the "Digital Device" category and thus exempt me from FCC compliance testing?
I'm interested in any and all thoughts on the matter.
Thanks in advance,
Ray Russell
I have designed a personal device that fits inside a key ring fob.
It does not connect in any way or under any conditions to the AC mains.
The device operates at very low duty cycle and can operate at very low system clock speeds.
The device is aimed at the consumer market.
I am interested in manufacturing this device and realize that the device must pass FCC Part 15b regulations.
As far as I can tell there are two areas within 15b that seem to apply to my situation:
1) This is the regulation:
From §15.103 "(h) Digital devices in which both the highest frequency generated and the highest frequency used (my emphasis in two places) are less than 1.705 MHz and which do not operate from the AC power lines or contain provisions for operation while connected to the AC power lines. 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."
My comment:
I can certainly reduce my clock frequency down below 1.705 MHz. However, the signal edge speeds will be significantly higher than 1.705 MHz so I imagine that I would run afoul of the "generated" part.
2) And this appears to be the definition of "Digital Device" as used above:
From 47 CFR § 15.3 "(k) Digital device. (Previously defined as a computing device). An unintentional radiator (device or system) that generates and uses timing signals or pulses at a rate in excess of 9,000 pulses (cycles) per second and uses digital techniques; inclusive of telephone equipment..."
My comment:
Notice that in item 2) there is no mention of "generated", it only addresses "timing signals or pulses". So if I reduce my system clock source to less than 9KHz does that knock me out of the "Digital Device" category and thus exempt me from FCC compliance testing?
I'm interested in any and all thoughts on the matter.
Thanks in advance,
Ray Russell