[PSES] FCC Emissions on Industrial Equipment

[Brian Kunde]

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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Re: [PSES] FCC Emissions on Industrial Equipment

[MIKE SHERMAN]

Brian --

I'm also interested in hearing from our group on the FCC question.

Regarding Europe: be careful on applying 55011. Read the scope closely. It is 
my belief that it applies to a much narrower subset of industrial machinery 
than the generic heavy industrial standards 61000-6-2 and 61000-6-4.

Mike

> On 01/12/2021 11:21 AM Brian Kunde  wrote:
>  
>  
> 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
>  
>  
> -
> 
> 
> 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 
> mailto: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 
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> 
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> 
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> David Heald mailto:dhe...@gmail.com >
> 

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Re: [PSES] FCC Emissions on Industrial Equipment

[André Videira]

Just saw I sent my e-mail only to Brian.


Hello Brian,

I worked for some time with industrial equipment, and rarely FCC was
required.
>From my understanding, it is only required if your machine has any type of
radio device in it.

About the Europe requirements, this depends a bit on the product you are
testing ans certifying.
Usually, the equipment has its own standard, and should be referred to it.
This standard sometimes may have different levels from the EN 55011, even
though it uses the same setup for tests.
It is a case-by-case evaluation.

I worked a long time with frequency inverters, and its basic standard for
EMC is the IEC/EN 61800-3.
In this standard, the test setup is almost the same as from the EN 55011
(the standard is referenced, but there are a few differences) , but there
there are changes in the limits (they are called C1, C2, C3 and C4, instead
of Class A and Class B).
For example, the C3 from radiated emission is a higher limit, that I don't
remember if there is any similar in EN 55011.

Hope I could help a bit.

Best regards,
André

Em ter, 12 de jan de 2021 18:21, Brian Kunde 
escreveu:

> 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
>
>
> -
> 
>
> 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 
> Mike Cantwell 
>
> For policy questions, send mail to:
> Jim Bacher 
> David Heald 
>

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Attachments are not permitted but the IEEE PSES Online Communities site at 
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formats), large files, etc.

Website:  http://www.ieee-pses.org/
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List rules: http://www.ieee-pses.org/listrules.html

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Scott Douglas 
Mike Cantwell 

For policy questions, send mail to:
Jim Bacher:  
David Heald: 

Re: [PSES] FCC Emissions on Industrial Equipment

[Bill Stumpf]

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

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


-


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 
mailto: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 mailto:sdoug...@ieee.org>>
Mike Cantwell mailto:mcantw...@ieee.org>>

For policy questions, send mail to:
Jim Bacher mailto:j.bac...@ieee.org>>
David Heald mailto:dhe...@gmail.com>>

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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 


All emc-pstc postings are archived and searchable on the web at:
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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:
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Jim Bacher:  
David Heald: 

Re: [PSES] FCC Emissions on Industrial Equipment

[Dennis Ward]

A couple of things

1 Never put a lot of confidence in statements like 
interference is unlikely.

2 Exemption from having a specific technical limit or 
exemption from FCC authorization, does not mean exemption from compliance.  
Industrial digital devices are subject to the general rules of 15.5 which 
states they are not to cause interference, and if they do they are to stop 
operating.  Industrial devices also have a specific interference mitigation 
process they may have to go through if they are found to cause interference.

3 The exemption for industrial equipment under 15.103 
applies ONLY to test equipment.  Many, if not all, Industrial devices do have 
technical limits in Part 18. They also may have general emissions limits 
outside the actual operating frequencies of the device in that rule part.  
While these limits may be more relaxed than part 15, they none the less do 
exist.

4 If the "industrial machine" is not a piece of test 
equipment, is not an appliance, is not a transportation vehicle or an 
electronic or power control system or the like, exemption under 15.103 cannot 
be applied.  Also most industrial devices are likely to be subject to the 
specific limits in Part 18.
Thanks
[cid:image001.png@01D6E8D4.F393F880]
Dennis Ward
Senior Reviewing Engineer
PCTEST Engineering Laboratory, LLC.
7185 Oakland Mills Road
Columbia, MD  21045
1 410 290 6652)

dennis.w...@pctest.com | 
www.pctest.com | 
www.element.com

This communication and any attachment contain information from PCTEST 
Engineering Laboratory, LLC. and is intended for the exclusive use of the 
recipient(s) named above.

From: Brian Kunde 
Sent: Tuesday, January 12, 2021 9:22 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] FCC Emissions on Industrial Equipment


CAUTION:This email originated from outside of Element Materials Technology. DO 
NOT click links or open attachments unless you recognize the sender and know 
the content is safe. Please contact IT Service Desk if you are in any doubt 
about this email.
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


-


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 
mailto:emc-p...@ieee.org>>

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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.

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unsubscribe)

Re: [PSES] FCC Emissions on Industrial Equipment

[Dennis Ward]

While for many industrial devices part 15 may not be required, they will 
generally have some portion of part 18 limits and requirements that must be 
met. And part 18 is FCC

[cid:image002.png@01D6E8D6.5F702A00]
Dennis Ward
Senior Reviewing Engineer
PCTEST Engineering Laboratory, LLC.
7185 Oakland Mills Road
Columbia, MD  21045
1 410 290 6652)

dennis.w...@pctest.com | 
www.pctest.com | 
www.element.com

This communication and any attachment contain information from PCTEST 
Engineering Laboratory, LLC. and is intended for the exclusive use of the 
recipient(s) named above.

From: André Videira 
Sent: Tuesday, January 12, 2021 10:13 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] FCC Emissions on Industrial Equipment


CAUTION:This email originated from outside of Element Materials Technology. DO 
NOT click links or open attachments unless you recognize the sender and know 
the content is safe. Please contact IT Service Desk if you are in any doubt 
about this email.
Just saw I sent my e-mail only to Brian.


Hello Brian,

I worked for some time with industrial equipment, and rarely FCC was required.
>From my understanding, it is only required if your machine has any type of 
>radio device in it.

About the Europe requirements, this depends a bit on the product you are 
testing ans certifying.
Usually, the equipment has its own standard, and should be referred to it.
This standard sometimes may have different levels from the EN 55011, even 
though it uses the same setup for tests.
It is a case-by-case evaluation.

I worked a long time with frequency inverters, and its basic standard for EMC 
is the IEC/EN 61800-3.
In this standard, the test setup is almost the same as from the EN 55011 (the 
standard is referenced, but there are a few differences) , but there there are 
changes in the limits (they are called C1, C2, C3 and C4, instead of Class A 
and Class B).
For example, the C3 from radiated emission is a higher limit, that I don't 
remember if there is any similar in EN 55011.

Hope I could help a bit.

Best regards,
André

Em ter, 12 de jan de 2021 18:21, Brian Kunde 
mailto:bkundew...@gmail.com>> escreveu:
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


-


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 
>

All emc-pstc postings are archived and searchable on the web at: 
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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)