Hi Gerald: While you may have discussed Ham radio with somebody at ARRL, I too would caution you regarding belief that you are exempt from FCC part 15 certification through a NRTL. With some exemptions, computing devices and their peripherals must meet such testing as generally do all devices containing a microprocessor or microcontroller. The fact that the DDS is a digitally controlled device may qualify you. The USB adapter, sold separately, would be subject to part 15 certification. You have the choice regarding whether you certify under Class A or Class B based upon your product definition as a consumer or industrial device, but these only apply to unintentional radiators, like the USB accessory. When your devices were sold as kits, you were exempted under 15.23, but this exemption disappears when you sell finished goods. Part 97 likely does not absolve obligations under part 15. The shrink wrap folks all certified under part 15 for these reasons.
Please feel free to contact me privately if you wish to discuss. I'd hate to see your company run afoul of the evil empire. Lee Pedlow (リー ペドロ) Systems Engineering Sony Electronics, Inc. San Diego, CA (858) 942-2538 [EMAIL PROTECTED] CONFIDENTIAL This email is covered by the Electronic Communications Privacy Act, 18 U.S.C. 2510-2521 and is legally privileged. This e-mail is intended only for the personal and confidential use of the individual(s) to which it is addressed and may contain confidential information. If you are not the intended recipient, you are hereby notified that you have received this document in error, and that any review, distribution, copying or disclosure is not authorized. If you have received this communication in error, please notify the sender immediately by telephone and destroy the message.