HI Neils Your client should understand that it is not his point of view that matters, it is what the FCC says about the device and what they say needs to be done in order for the device to be authorized. The simple fact that it can, at any time, connect to a PC and download software makes this a Computer Peripheral. It does not matter how often it can be done, nor how many times it is actually done, the fact that it can be done and that it is a consumer device makes this device a Class B Computing Device Peripheral subject to DoC or Certification, depending on how the grantee wants to address the authorization.
Thanks Dennis Ward Senior Certification Engineer PCTEST This communication and its attachments contain information from PCTEST Engineering Laboratory, Inc., and is intended for the exclusive use of the recipient (s) named above. It may contain information that is confidential and/or legally privileged. Any unauthorized use that may compromise that confidentiality via distribution or disclosure is prohibited. Please notify the sender immediately if you receive this communication in error, and delete it from your computer system. Usage of PCTEST email addresses for non-business related activities is strictly prohibited. No warranty is made that the e-mail or attachment(s) are free from computer virus or other defect. Thank you. From: Niels Hougaard [mailto:n...@bolls.dk] Sent: Friday, March 14, 2014 7:05 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] Concerning FCC classification of digital devices Dear list members, Being an independent testing facility, we have received a question from a costumer regarding FCC classification. The consumers product is a small portable device for use with a musical instrument. When the product is used normally, it is attached to the instrument by audio Jack cables. The product is battery powered, but can be powered by a general purpose adaptor. The product has a build-in microprocessor and therefore clock frequencies that requires a classification with regards to FCC (47 cfr part 15, §15.101). For software update, programming purpose , and under these circumstances also sometimes powering, the product has a MINI-B USB connector depending on variant, the product can either be supplied with or without the USB cable in the shipping box. Question is Is this product considered a Class B Computer Peripheral which require a DoC, and an accredited test report from an NVLAP accredited test lab and appropriate FCC logo markings (DoC or certification procedure) ? or is the product considered Other Class B digital device - - which require only a verification and no FCC logo marking (Verification procedure) ? Our costumer states that in their point of view the users only operates the device with a computer connected, when they are putting the device into operation initially or for reconfiguration, software upgrade or similar. Therefore they claims it should not be considered Computer Peripheral since the use of the product is very different from the use of typical computer Peripherals like keyboard, mouse or printer. Is having a USB connector enough to classify the product as a Class B Computer Peripheral? Or is the use of the USB connector of importance<+ Does anyone in here have experience from similar cases? Regards, Niels Niels Hougaard Bolls ApS Ved Gadekæret 11F DK-3660 Stenløse Denmark T: +45 48 18 35 66 F: +45 48 18 35 30 <mailto:n...@bolls.dk> n...@bolls.dk <http://www.bolls.dk/> www.bolls.dk - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <emc-p...@ieee.org> All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) <http://www.ieee-pses.org/list.html> List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <emcp...@radiusnorth.net> Mike Cantwell <mcantw...@ieee.org> For policy questions, send mail to: Jim Bacher <j.bac...@ieee.org> David Heald <dhe...@gmail.com> - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <emc-p...@ieee.org> All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <emcp...@radiusnorth.net> Mike Cantwell <mcantw...@ieee.org> For policy questions, send mail to: Jim Bacher: <j.bac...@ieee.org> David Heald: <dhe...@gmail.com>
