Brian,
Industrial equipment is not exempt from FCC Part 15 regulations.  The common 
belief that it is exempt is based on a misinterpretation of Part 15 Section 
15.103(c) which states as exempt "A digital device used exclusively as 
industrial, commercial, or medical test equipment.".  I sent an inquiry to the 
FCC some time ago and their response was: “It is an exemption for demonstrating 
compliance for the digital logic contained in test equipment exclusively used 
in commercial, medical and industrial situations, not commercial equipment.”
Therefore, unless the industrial equipment is test equipment, it is not exempt. 
 Note however that even exempt equipment is subject to the general conditions 
of operation contained in Section 15.5 and 15.29 that the operator of the 
exempted device shall be required to stop operating the device upon a finding 
by the Commission or its representative that the device is causing harmful 
interference. Operation shall not resume until the condition causing the 
harmful interference has been corrected. Although not mandatory, it is strongly 
recommended that the manufacturer of an exempted device endeavor to have the 
device meet the specific technical standards in this part.
Basically, the procedure for the equipment authorizations is verifying that the 
device is within limits for unintentionally radiating unwanted emissions as 
good quality engineering.

Refer also to FCC KDB 772105 
D01<https://apps.fcc.gov/kdb/GetAttachment.html?id=aPHDD74GRH5N2s050fBjxA%3D%3D&desc=772105%20D01%20Exempt%20Devices%20v01r01&tracking_number=33062>

Bill Stumpf - Lab/Technical Manager
D.L.S. Electronic Systems, Inc.
166 South Carter Street
Genoa City, WI 53128
262-279-0210




From: Brian Kunde [mailto:bkundew...@gmail.com]
Sent: Tuesday, January 12, 2021 11:22 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] FCC Emissions on Industrial Equipment

I am working on the first Industrial Machine of my career so I could use some 
advice and clarification regarding the requirements for FCC emissions.

I have been told by many that in North America, Industrial Equipment does not 
have to be tested, verified, or anything for FCC by the manufacturer of the 
equipment.  Is this true?  I was told that interference is unlikely, even if 
the equipment exceeds the FCC emissions limits.   Meeting the FCC limits is 
recommended, and voluntary, but not required.  True?


On the other hand,  Europe is not so.  If EE equipment goes to Europe, it has 
to pass the EN 55011 emissions test as well as the immunity tests.   Is that 
correct?


Any additional information that would be helpful to me would be appreciated.

The Other Brian


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