The FCC recently lowered the acceptable frequency range of digital devices. Haven't heard about this? Don't worry, you're hardly alone. Even some of the biggest players out there haven't.
Effects Bay has a nice little write-up about a recent EHX dust-up:
http://www.effectsbay.com/2014/05/fc...ns-for-pedals/
The long and short of it is: anything with a digital clock that generates a frequency above 9,000Hz now must be tested for emissions. EHX got slammed with almost a half a million dollars in fines. Testing is expensive, and equipment to do so would cost thousands of dollars, putting it out of reach for I suspect, most small or even medium sized pedal builders. Shipping something used without a certificate could even potentially violate the FCC regulations, similar to trying to ship guitars internationally. I really hope that I'm being alarmist, but I'm going to have to check with my boss (work in a law office) to see if I'm misunderstanding anything.
What's this affect in your pedals, you ask?
Anything with a charge pump -- yup, all your Klones.
Anything that requires a clock chip to produce the effect -- analog octave down, bucket brigade delay/chorus/vibrato, etc.
PT2399 delays and other digital delays -- so far as I can tell, everything involved in making analog delay pedals, with one notable exception, is now in violation. That exception is tape delays. I'm sure we'll all be thrilled to go back to THAT technology.
Anything with tap tempo.
Every pedal you can think of based on the FV-1 -- this covers a LOT of reverb pedals.
All those reverbs based on the Belton brick -- this covers most of your other reverbs.
The list goes on. Why? Because digital audio circuits need to have clock frequencies well above at least 15KHz, preferably well above 20KHz, to get out of human hearing. So you're stuck either finding a testing method for your pedals (expensive) or lowering the clock frequencies into human hearing range (which would just be terrible).
More info here: http://www.diystompboxes.com/smfforum/index.php?topic=107145.msg972029
That's pretty huge, especially if a company uses a uC for switching. I didn't see how much it costs to have a device tested.
This is most unfortunate, but not surprising.
The FCC is (and has been) lobbied heavily by those who purchased the 700 MHz spectrum (Verizon, AT&T, Qualcomm, etc) to protect their investment. These companies paid billions of dollars to secure this valuable "real-estate" in the RF spectrum and bring 4G/LTE devices to smartphone users as well as broadband wireless internet. It is a very valuable portion of the spectrum, because based on physics you can send a signal the farthest distance with the least amount of output power in the 600-700 MHz (UHF) range. UHF also has superior wall penetration compared to other technologies like 2.4 GHz.
With the impending auction of the 600 MHz frequency range in an estimated 1-2 years, we can only expect these same companies to act even more aggressively to protect their investment as they look to grab new spectrum between 600-700 MHz. They want to ensure nothing encroaches on their wireless devices and causes them (or their users) interference. Now that they are heavily invested in the sub 1 GHz range, they are focused on ensuring their devices will not be encroached on. Who can blame them after they spent an obscene amount of money...what is unfortunate is that because of the scope of the 700 MHz auction (and upcoming 600 MHz), the "little guys" (music industry electronics manufacturers as a whole) are left out in the cold. I was once told that the entire music industry of product manufacturers is equal to something like 2% of the potato chip industry. Money talks in Washington, and billions of dollars recently spent certainly speaks volumes. Smartphones already have to go through a rigourous RF testing process, so it is really no problem for the phone manufacturers/network providers to have their devices be tested.
In my experience, it is not so much the FCC who is going around and pointing the finger at those who violate the new laws in the aftermath of the spectrum realignment...but rather those same companies who paid dearly for it. It is not uncommon for Verizon and AT&T to have little white vans with guys armed with spectrum analyzers & directional antennas who scour local churches on Sundays to see if they are still using 700 MHz wireless microphones...I have personally seen the cease and desist letters on numerous occasions. The FCC will levy heavy fines if it is made clear and evident that someone continually is violating the rules (as seen with EHX fine).
Those same guys in the white vans are more than happy to put any violator's information served on a silver platter for the FCC to do as they please. With that being said, it is a little pedantic to make every pedal be tested just because it uses a charge pump or PT2399 delay. A lot of these components are already tested before being sold by the manufacturer however the FCC is making it clear that once you use it in a new circuit that the circuit must be tested as a whole. Will this stop the influx of millions of 3rd party Arduinos and electronics you see being sold on eBay?...I think not. Time will only tell how this will affect the small/medium 'bootique' builders. I suppose the more high profile your business, the more vulnerable you are (like EHX..I feel bad for them).
:(
>:( >:( >:( >:( >:( >:(
Granted, up here in the GWN, you know, where apparently rosewood, ebony, and mahogany are illegal, we're likely 15 years behind in our bannings (in true Canadian fashion, we make our wireless companies share, not compete), so we'll just start bootlegging 'em down to you if you lose the ability to source them domestically.
The government auctioned off the 700mhz band this year too.
Jacob
Quote from: jkokura on May 06, 2014, 10:51:40 PM
The government of Canada auctioned off the 700mhz band this year too. Rogers owns most of it Canada wide.
Jacob
Well, in that case (cue up the 'Priest)
"Breaking the law, breaking the law...."
I've just started trying to look into this, but I can't find reference to any frequency limits on digital devices other than an upper exemption limit of 1.705MHz. I'm still looking and trying to understand though.
This page from Sparkfun seems helpful and relevant to our interests. https://www.sparkfun.com/tutorials/398 (https://www.sparkfun.com/tutorials/398)
Quote from: GermanCdn on May 06, 2014, 10:39:56 PM
>:( >:( >:( >:( >:( >:(
Granted, up here in the GWN, you know, where apparently rosewood, ebony, and mahogany are illegal, we're likely 15 years behind in our bannings (in true Canadian fashion, we make our wireless companies share, not compete), so we'll just start bootlegging 'em down to you if you lose the ability to source them domestically.
Just like Canadian whiskey of lore! Haha
Obamacare is clearly to blame
-pedalalexjones
In all seriousness, this is an incredible bummer. It will be interesting to see how this plays out.
It's already played out. The stuff with EHX was finished on April 22, 2013. It started back in 2010. If you search the FCC site, there are other cases with Fender, Mackie, and others that are from even earlier. It looks to me like they just weren't in compliance with either documentation or testing. I can't figure out which from the docs. But, the main thing is that it doesn't look to be anything new and it hasn't stopped any of these companies yet.
All I have to say is:
(http://images2.fanpop.com/images/photos/5900000/Pump-Up-The-Volume-pump-up-the-volume-5998622-1600-900.jpg)
Quote from: RobA on May 07, 2014, 12:56:15 AM
It's already played out. The stuff with EHX was finished on April 22, 2013. It started back in 2010. If you search the FCC site, there are other cases with Fender, Mackie, and others that are from even earlier. It looks to me like they just weren't in compliance with either documentation or testing. I can't figure out which from the docs. But, the main thing is that it doesn't look to be anything new and it hasn't stopped any of these companies yet.
That why i don't understand why the manufacturer of the IC or whatever device have'nt stop their production or devellopement.... there's certainly something we are missing here.
I tried to go through all the text, but the technical writting make it like a russian dictionnary for me to read..... :-[ and can't find any articles about it in french... i'm damned to ignorance.
Quote from: GrindCustoms on May 07, 2014, 01:23:31 AM
Quote from: RobA on May 07, 2014, 12:56:15 AM
It's already played out. The stuff with EHX was finished on April 22, 2013. It started back in 2010. If you search the FCC site, there are other cases with Fender, Mackie, and others that are from even earlier. It looks to me like they just weren't in compliance with either documentation or testing. I can't figure out which from the docs. But, the main thing is that it doesn't look to be anything new and it hasn't stopped any of these companies yet.
That why i don't understand why the manufacturer of the IC or whatever device have'nt stop their production or devellopement.... there's certainly something we are missing here.
I tried to go through all the text, but the technical writting make it like a russian dictionnary for me to read..... :-[ and can't find any articles about it in french... i'm damned to ignorance.
I don't know for sure, but I don't think there is an actual problem with any device. The wording makes me think it is purely with their compliance on the testing and/or documentation end of things.
Edit: by "their" I mean the end product manufacturers (EHX, etc.), not the producers of the IC's or other components.
Explained this to my wife. her response: go hide all the dog whistles before the FCC takes them away.
seriously though 9kHz is way too low.
Quote from: Peteyboy on May 07, 2014, 01:28:49 AM
Explained this to my wife. her response: go hide all the dog whistles before the FCC takes them away.
seriously though 9kHz is way too low.
I still haven't seen anything in the documents or the rules that says anything about 9kHz. One thing to note though is that clocks often use square waves which would have harmonics well above 9kHz and the rules have to do with the actual frequency that a device radiates at.
Quote from: RobA on May 07, 2014, 01:31:31 AM
Quote from: Peteyboy on May 07, 2014, 01:28:49 AM
Explained this to my wife. her response: go hide all the dog whistles before the FCC takes them away.
seriously though 9kHz is way too low.
I still haven't seen anything in the documents or the rules that says anything about 9kHz. One thing to note though is that clocks often use square waves which would have harmonics well above 9kHz and the rules have to do with the actual frequency that a device radiates at.
The EHX compliance doc cites the section. It's s15 something.
Quote from: midwayfair on May 07, 2014, 01:34:14 AM
Quote from: RobA on May 07, 2014, 01:31:31 AM
Quote from: Peteyboy on May 07, 2014, 01:28:49 AM
Explained this to my wife. her response: go hide all the dog whistles before the FCC takes them away.
seriously though 9kHz is way too low.
I still haven't seen anything in the documents or the rules that says anything about 9kHz. One thing to note though is that clocks often use square waves which would have harmonics well above 9kHz and the rules have to do with the actual frequency that a device radiates at.
The EHX compliance doc cites the section. It's s15 something.
The EHX doc cites sections 15.19 and 15.105 with "Labelling requirements" and "Information to the user" resp. I don't see that they mention a specific frequency. I could be missing it. There are very specific statements about what the requirements are in other sections though. And they go into detail about what's allowed back onto power lines and everything else in the world.
The section I can find (15.109e Radiated emission limits) says,
Quote
Carrier current systems used as unintentional radiators or other unintentional radiators that are designed to conduct their radio frequency emissions via connecting wires or cables and that operate in the frequency range of 9 kHz to 30 MHz, including devices that deliver the radio frequency energy to transducers, such as ultrasonic devices not covered under part 18 of this chapter, shall comply with the radiated emission limits for intentional radiators provided in §15.209 for the frequency range of 9 kHz to 30 MHz.
This doesn't seem to apply to me and even if it does, the limit is specified and wouldn't be that hard to achieve.
Edit: Hmm, now I think it does apply. It would really apply to modular synths. Still, any manufacturer would just need to verify that the device complies with the emission standards and the documentation. As far as the emission goes, the devices already need RF shielding just to work correctly.
One thing that does look to be an issue though is that the rules are going to be pretty hard on boutique builders. The testing isn't exactly cheap for someone that isn't making a significant profit from it. One of the sites I saw quoted something like (US)$1000 to get the testing done for a product. You'd need to sell quote a few to make that up.
Quote from: RobA on May 07, 2014, 02:05:21 AM
One thing that does look to be an issue though is that the rules are going to be pretty hard on boutique builders. The testing isn't exactly cheap for someone that isn't making a significant profit from it. One of the sites I saw quoted something like (US)$1000 to get the testing done for a product. You'd need to sell quote a few to make that up.
The last quote I saw was about $2k for this type of testing.
crazy :o
My next step is to build a company to test these for all pedal builders and offer it slightly cheaper than others and profit :P
This exemption case:
Joystick controllers or similar devices, such as a mouse, used with digital devices but which contain only non-digital circuitry or a simple circuit to convert the signal to the format required (e.g., an integrated circuit for analog to digital conversion) are viewed as passive add-on devices, not themselves directly subject to the technical standards or the equipment authorization requirements.
Would'nt it exempt the use of a charge pump in a pedal? If no digital device are used in the unit, like an OD.
Quote from: GrindCustoms on May 07, 2014, 02:54:33 AM
This exemption case:
Joystick controllers or similar devices, such as a mouse, used with digital devices but which contain only non-digital circuitry or a simple circuit to convert the signal to the format required (e.g., an integrated circuit for analog to digital conversion) are viewed as passive add-on devices, not themselves directly subject to the technical standards or the equipment authorization requirements.
Would'nt it exempt the use of a charge pump in a pedal? If no digital device are used in the unit, like an OD.
My interpretation of all of this is that it only applies to complete, end-user products. So, no component, like an IC, has to comply by itself.
It seems to me that a MIDI controller might be covered by that exemption, but I'm pretty sure that wasn't the point of the exemption.
Quote from: mattlee0037 on May 07, 2014, 02:30:17 AM
My next step is to build a company to test these for all pedal builders and offer it slightly cheaper than others and profit :P
That would probably work if:
- You have enough start-up cash to get the necessary equipment plus the cost of getting it calibrated by NIST.
- You can line up a lot of pedal builders.
Quote from: rullywowr on May 06, 2014, 10:18:01 PM
The FCC is (and has been) lobbied heavily by those who purchased the 700 MHz spectrum (Verizon, AT&T, Qualcomm, etc) to protect their investment.
Perhaps this is because I was not raised in America (a pie to me is meat of some sort in a pastry enclosure, not pizza or one of those fruit pie things), but I tend to read "lobbying" as "America has the best government money can buy!"
If I'm understanding lobbying to basically be nagging the living shit out of, and bribing like hell.
I could be wrong, I probably am.
Quote from: alanp on May 07, 2014, 05:26:34 AM
Perhaps this is because I was not raised in America (a pie to me is meat of some sort in a pastry enclosure, not pizza or one of those fruit pie things), but I tend to read "lobbying" as "America has the best government money can buy!"
If I'm understanding lobbying to basically be nagging the living shit out of, and bribing like hell.
I could be wrong, I probably am.
I have never read a more correct statement in my life.
I only know the european rules with RF testing. You need to do this to get the CE-sign. No sign, not able to sell a single device.
The procedures to test things are very complex but the is a lot of writing about 'similar devices' that dont need testing.
Where they get you is if you dont write about possible interferences in your manual.
If you state that your device should not come near audio amplification because it might impact it and if you say that cell phones should be kept away from your device you are fine.
I know this is crazy to tell people that they should not put their new effect pedal near an amplifier, but the point is that if you tell the buyer you have met the guidelines!
Well this is interesting. I imagine the FCC will go after the big fishies first... then they will go for the slimmer pickings.
The company I work for need pre-compliance testing carried out on a device we are in part developing.
Cost for a days pre-compliance testing = £1000.00.
That doesn't even get you through the required validations and approvals. It's just to see if the device has any emissions or immunity problems that need eradicating before full testing and approvals commence.
My guesstimate for the testing and GBA (General Buggering About) would be at least 5 days for the full tests. So we are talking at least 5k.
In the EU you also have to follow very closely the applicable EN standards you need to meet (ie. depending on the application of the device).
You have to purchase the EN standards... which then reference other standards that may require purchasing.
Oh, and they change them every year too.
The whole thing is just a gravy train for the respective governing bodies and their team of representative vampires/solicitors ( ;))
I imagine it's no different in the US.
There's a video tour of the Marshall factory on YT and they show the room and a little of the process they have to go through for rf testing. It seemed like they were none to pleased with the expense and hassle but a least they are big enough to do it in house. Sounds like a killer for small business's though.
CE testing is usually considerably more expensive than FCC testing, but it depends on what tests are being done, of course. I've had to deal with that on a few products and I don't think it's ever been less than $10k, and $20k isn't unusual at all.
At my job we have an extensive set of rf testing "rf anechoic" chambers however we still need to have it done by a 3rd party in order to qualify for CE and FCC compliance. And it is Very expensive. A common theme is to make variants on similar products which use the same board so once that board is ok it can be used in more than just one product. I imagine the same mentality will be (or already has been) forced on manufacturers like ehx et. al.
I doubt that the FCC will ever go after the little guys like boutique builders. They have little chance of making it worth the effort, I reckon. It's easy enough to target the major players where the big money is to be taken. 450k is a massive payoff compared to 1k from your average Christian Landowner (sorry, inside joke).
Still, it's a bummer.
Quote from: madbean on May 07, 2014, 02:06:35 PM
I doubt that the FCC will ever go after the little guys like boutique builders. They have little chance of making it worth the effort, I reckon. It's easy enough to target the major players where the big money is to be taken. 450k is a massive payoff compared to 1k from your average Christian Landowner (sorry, inside joke).
Still, it's a bummer.
I think you're probably right, but where it would worry me is it being used as a weapon by some butthurt competitor.
Quote from: jubal81 on May 07, 2014, 02:24:13 PM
Quote from: madbean on May 07, 2014, 02:06:35 PM
I doubt that the FCC will ever go after the little guys like boutique builders. They have little chance of making it worth the effort, I reckon. It's easy enough to target the major players where the big money is to be taken. 450k is a massive payoff compared to 1k from your average Christian Landowner (sorry, inside joke).
Still, it's a bummer.
I think you're probably right, but where it would worry me is it being used as a weapon by some butthurt competitor.
And, they probably have no choice but to go after you if you are turned in for a violation. All of the actions against music equipment companies I saw at the FCC site were for documentation violations. That's dead simple for them to prove and will cost them next to nothing to take action on. I also doubt if the fine would be in the $1k range just because you are small. I'd expect it to be at least an order of magnitude higher and probably closer to two orders higher. Still, the rules aren't new and the actions I looked at were started up to 5 years ago and there hasn't been any actions taken against boutique builders that I've heard of yet.
What I wonder is if there are any pedals that actually have enough power in the relevant ranges to produce RF emissions that are strong enough to be in violation. Can you legally test for emissions yourself for devices that aren't exempt and then document them yourself and be in compliance?
I checked the back of a digital muti-effect box i have and the label says , Complies with the limits for a Class "B" computing device pusuant to subpart J of Part 15 of FCC rules. There's further explanation in the manual and what to do if it interfers with the TV or radio. Got this Yamaha REX 50 in '87 or '88 so these type of rules have been around for awhile, hardly seems likely that EHX was caught unaware.
Quote from: davent on May 07, 2014, 03:49:19 PM
I checked the back of a digital muti-effect box i have and the label says , Complies with the limits for a Class "B" computing device pusuant to subpart J of Part 15 of FCC rules. There's further explanation in the manual and what to do if it interfers with the TV or radio. Got this Yamaha REX 50 in '87 or '88 so these type of rules have been around for awhile, hardly seems likely that EHX was caught unaware.
No one said that the rules haven't been around for a while. What seems to be RECENT (not super recent, but within the last decade) is the 9KHz frequency. I think it used to be much higher.
Quote from: jubal81 on May 07, 2014, 02:24:13 PM
Quote from: madbean on May 07, 2014, 02:06:35 PM
I doubt that the FCC will ever go after the little guys like boutique builders. They have little chance of making it worth the effort, I reckon. It's easy enough to target the major players where the big money is to be taken. 450k is a massive payoff compared to 1k from your average Christian Landowner (sorry, inside joke).
Still, it's a bummer.
I think you're probably right, but where it would worry me is it being used as a weapon by some butthurt competitor.
That....is very scary.
For this eample... I would like to use the Klon ::)
SAME circuit - CHECK!
SAME type components - CHECK!
SAME build materials - CHECK!
Built in aluminum enclosure like original - CHECK!
Cloner not having enough to pay $20K to get some ridiculous FCC emissions check performed even though it is 99% like the original that passed said check - PROBLEM!
Of course, this could apply to just about ALL cloned pedals. I suspect that problems/interference are run into when these "type" circuits are not properly enclosed and shielded. Such as those who build in non-shielded wooden enclosures, plexiglass, phenolic, etc.
That doesn't work. Emissions are often created on a PCB level. You'd need to certify the product with your layout.
Even if it was functionally identical, their qualification wouldn't pass to a cloner.
Quote from: pickdropper on May 07, 2014, 04:47:36 PM
Even if it was functionally identical, their qualification wouldn't pass to a cloner.
Of course not.... no money in that! ::)
Quote from: Govmnt_Lacky on May 07, 2014, 04:49:22 PM
Quote from: pickdropper on May 07, 2014, 04:47:36 PM
Even if it was functionally identical, their qualification wouldn't pass to a cloner.
Of course not.... no money in that! ::)
Greg, I think you're not understanding what Dave was talking about. There are different methods of PCB construction, layout, etc. that could change whether or not a circuit is compliant. They don't care that you're using a frequency doubler chip in a distortion circuit, they care whether or not the final product complies with the regulations.
From sparkfun: https://www.sparkfun.com/tutorials/398 (https://www.sparkfun.com/tutorials/398)
QuoteWhat can I do to avoid expensive testing and still remain in compliance with the laws?
There are two ways to avoid testing: restrict yourself to selling only subassemblies, or restrict yourself to devices on the exempted products list. The exempted product categories are pretty hard to remain within, and are given in section 15.103 of CFR47:
There's a loophole here somewhere. Subassemblies!!
Quote from: midwayfair on May 07, 2014, 05:03:54 PM
Quote from: Govmnt_Lacky on May 07, 2014, 04:49:22 PM
Quote from: pickdropper on May 07, 2014, 04:47:36 PM
Even if it was functionally identical, their qualification wouldn't pass to a cloner.
Of course not.... no money in that! ::)
Greg, I think you're not understanding what Dave was talking about. There are different methods of PCB construction, layout, etc. that could change whether or not a circuit is compliant. They don't care that you're using a frequency doubler chip in a distortion circuit, they care whether or not the final product complies with the regulations.
Yes, exactly. How it is put together makes a difference, as does the components used. The test labs aren't going to spend any time analyzing the circuit. All they will do is check that the emissions are within spec.
As far as there being money in it, that is true, but the money isn't going to the FCC as they don't do the actual testing. Now, of course there are lobbyists and of course there are other money funnels, but the bulk of the testing money does not go to the people passing the legislation.
I bet you if the people that owned the test labs wrote the rules, there would be a lot more testing. ;-)
But yeah, the level of testing and cost gets frustrating, particularly for small businesses. There needs to be a happy medium. Some of the testing really is necessary, but some of the rules can be heavy handed.
I was right on par with what you were saying Dave. Im with ya'
Let me try to simplify my point.
If you put a "circuit" into a 1590B with a 100KHz clock and it passes the FCC inspection (a'la multiple manufacturer's boxes on the market today)
If you take that same circuit... still generating that 100KHz clock.... clone it.... and put it into a 1590B. Where is the problem? Why the need to re-test?
Answer = Money!
Otherwise EVERY Tom, Dick, and Cloner could just leverage off of someone else's FCC qualification.
I wonder how it is sorted? By parent company?
That sounds rather scary... Although it might just be a little bit like music/film/... downloading. Everyone does it, everyone knows that everyone's doing it, everyone knows it's illegal (or at least very immoral) and the only ones who are pursuit are the really big fish/providers...
No matter what, I just wanted to say: we're all pretty badass around here. Real gangsters 8)
The reason you need to test it is because you may have changed something important while cloning it.
I am dealing with the FCC on a product right now. If The board is changed in a way they deem significant, then I have to redo the FCC testing. The reason is that the new board could fail in ways the other one didn't.
The real question is if the standard is valid at all. I am not the most knowledgable on why the 9kHz rule exists so I'll have to research before saying anything about the validity. For a lot of the higher bandwidth products, the FCC regs are important, especially for interoperability in an increasingly dense RF world.
I think the cash grab angle is a blatant oversimplification people use because the process is so frustrating, especially if you are just getting started with it (I'm certainly not immune). But I've known some folks involved with FCC standards. They may have been a bit officious at times, but none of them made it rich by passing standards. They probably make more money rejecting and discussing them ad nausium (mostly kidding).
Quote from: Govmnt_Lacky on May 07, 2014, 06:37:30 PM
I was right on par with what you were saying Dave. Im with ya'
Let me try to simplify my point.
If you put a "circuit" into a 1590B with a 100KHz clock and it passes the FCC inspection (a'la multiple manufacturer's boxes on the market today)
If you take that same circuit... still generating that 100KHz clock.... clone it.... and put it into a 1590B. Where is the problem? Why the need to re-test?
Answer = Money!
Otherwise EVERY Tom, Dick, and Cloner could just leverage off of someone else's FCC qualification.
I wonder how it is sorted? By parent company?
Are you imaginging taking the same circuit BOARD or the same CIRCUIT?
The CIRCUIT BOARD itself can affect the emissions, regardless of the circuit itself.
If you use the
exact same circuit board that has been tested for compliance in the smaller enclosure, then there's no need to retest. If you rehouse a pedal, you don't need to retest. But you don't have access to compliant circuit boards manufactured by EHX, Boss, etc. for their pedals anyway if you're building a clone, so, no, anything you build on is almost guaranteed not to be compliant if it generates a clock, and even if you did have their circuit board, as far as a regulatory agency is concerned, you're making your own product anyway, so you don't get to leach off someone else who paid for compliance testing.
Let's try to stay focused on the things that are ACTUALLY stupid about this and what we can do about it, instead of generating conspiracy theories about the money involved.
For anyone interested, the TGP thread has a few posts by medium-sized pedal manufacturers who have done this -- including Diamond -- and others who haven't -- including AnalogMan.
I'm wondering what the european, or dutch, equivalent of the FCC might be, and if their rules are as strict. Would it be possible to use me as a middle man to distribute pedals? That being the european rules aren't as strict (probably!)? Looking for loopholes here, let me know if us europeans can help out!
Paul
Quote from: pickdropper on May 07, 2014, 06:49:25 PM
I am dealing with the FCC on a product right now.
Is this for your work? It might help if you were to keep us informed of the process if it regards pedals or effects circuits ;)
Quote from: DutchMF on May 07, 2014, 06:52:22 PM
I'm wondering what the european, or dutch, equivalent of the FCC might be, and if their rules are as strict. Would it be possible to use me as a middle man to distribute pedals? That being the european rules aren't as strict (probably!)? Looking for loopholes here, let me know if us europeans can help out!
Paul
From what I can see on the markings on electronics and a couple of searches, the European standard is set out in EN 55022 and CISPR 22 and it is just as stringent, if not more so, as the US laws.
I think people are missing the point that these laws exist for very good reasons. On top of that, it looks to me like the section of the law that EHX and others got hit on is essentially consumer protection. If you, as an end user, have a device that is broadcasting illegally in RF, you will be forced to shut it down and not use it. The reason for the compliance marks is to let consumers know which devices have been properly tested and are safe to buy. That's why the clauses for DIY stuff exist. If you make your own device that violates the air space, then it's only your fault if you have to shut it down.
Quote from: midwayfair on May 07, 2014, 03:54:16 PM
Quote from: davent on May 07, 2014, 03:49:19 PM
I checked the back of a digital muti-effect box i have and the label says , Complies with the limits for a Class "B" computing device pusuant to subpart J of Part 15 of FCC rules. There's further explanation in the manual and what to do if it interfers with the TV or radio. Got this Yamaha REX 50 in '87 or '88 so these type of rules have been around for awhile, hardly seems likely that EHX was caught unaware.
No one said that the rules haven't been around for a while. What seems to be RECENT (not super recent, but within the last decade) is the 9KHz frequency. I think it used to be much higher.
My impression is that the 9kHz limit is pretty old. I'm guessing that it exists in that section as a way to exempt telephone lines and related equipment from having to meet the rules. Telephony has an upper frequency of 8kHz and I'd imagine it was pretty hard to keep RF from coming off of the giant bundles of wire carrying large numbers of analog phone calls. That is purely a guess though.
Quote from: midwayfair on May 07, 2014, 06:51:31 PM
If you use the exact same circuit board that has been tested for compliance in the smaller enclosure, then there's no need to retest. If you rehouse a pedal, you don't need to retest. But you don't have access to compliant circuit boards manufactured by EHX, Boss, etc. for their pedals anyway if you're building a clone, so, no, anything you build on is almost guaranteed not to be compliant if it generates a clock, and even if you did have their circuit board, as far as a regulatory agency is concerned, you're making your own product anyway, so you don't get to leach off someone else who paid for compliance testing.
Actually, changing the box could have an effect as RF emissions can be different if the wiring scheme changes or possibly even the enclosure. Now, at 9kHz it's not as much of an issue, but at 2.4GHz, you have to worry about little metal bits acting as an antenna.
Quote from: midwayfair on May 07, 2014, 06:51:31 PM
Let's try to stay focused on the things that are ACTUALLY stupid about this and what we can do about it, instead of generating conspiracy theories about the money involved.
Totally agreed.
Quote from: Govmnt_Lacky on May 07, 2014, 06:59:34 PM
Quote from: pickdropper on May 07, 2014, 06:49:25 PM
I am dealing with the FCC on a product right now.
Is this for your work? It might help if you were to keep us informed of the process if it regards pedals or effects circuits ;)
Not at all related to pedals or effects circuits.
Quote from: RobA on May 07, 2014, 07:18:18 PM
Quote from: DutchMF on May 07, 2014, 06:52:22 PM
I'm wondering what the european, or dutch, equivalent of the FCC might be, and if their rules are as strict. Would it be possible to use me as a middle man to distribute pedals? That being the european rules aren't as strict (probably!)? Looking for loopholes here, let me know if us europeans can help out!
Paul
From what I can see on the markings on electronics and a couple of searches, the European standard is set out in EN 55022 and CISPR 22 and it is just as stringent, if not more so, as the US laws.
I think people are missing the point that these laws exist for very good reasons. On top of that, it looks to me like the section of the law that EHX and others got hit on is essentially consumer protection. If you, as an end user, have a device that is broadcasting illegally in RF, you will be forced to shut it down and not use it. The reason for the compliance marks is to let consumers know which devices have been properly tested and are safe to buy. That's why the clauses for DIY stuff exist. If you make your own device that violates the air space, then it's only your fault if you have to shut it down.
Yeah, the European Union is notoriously strict. Beyond compliance testing for emissions, read up on REACH and RoHS 2 compliance.
Quote from: RobA on May 07, 2014, 07:26:18 PM
Quote from: midwayfair on May 07, 2014, 03:54:16 PM
Quote from: davent on May 07, 2014, 03:49:19 PM
I checked the back of a digital muti-effect box i have and the label says , Complies with the limits for a Class "B" computing device pusuant to subpart J of Part 15 of FCC rules. There's further explanation in the manual and what to do if it interfers with the TV or radio. Got this Yamaha REX 50 in '87 or '88 so these type of rules have been around for awhile, hardly seems likely that EHX was caught unaware.
No one said that the rules haven't been around for a while. What seems to be RECENT (not super recent, but within the last decade) is the 9KHz frequency. I think it used to be much higher.
My impression is that the 9kHz limit is pretty old. I'm guessing that it exists in that section as a way to exempt telephone lines and related equipment from having to meet the rules. Telephony has an upper frequency of 8kHz and I'd imagine it was pretty hard to keep RF from coming off of the giant bundles of wire carrying large numbers of analog phone calls. That is purely a guess though.
I was discussing this with one of my co-workers today. He seems fairly convinced that the 9kHz standard became a bigger deal in the 80's because of household devices interfering with television reception, but I haven't looked up the history to see if that is correct.
I've been trying to understand all this, and what it truly means/impacts. Let me know which option I have is correct:
1. This affects products (pedals) that are:
a) sold in any US physical retail stores (online excluded) to US customers
b) sold in any US story (online and physical) to US customers
c) sold in any store worldwide (online or physical) to US customers
d) sold in any US store (online or physical) to any country worldwide
e) Sold in any story worldwide (online or physical) to worldwide customers
2. Pedals are fine if they:
a) Do not contain charge Pumps, PT2399's or FV1 chips
b) Do not contain analog BBD technology (Chorus, Delay, Flange, Etc)
c) Are made in small numbers
d) Are made and sold from outside the US
3. DIY pedals are fine?
If that sums it up, in the end, what does a very small shop like mine really need to pay attention to? Do I need to pull and stop selling anything with a Tap Tempo or Charge Pump in it?
Jacob
Quote from: jkokura on May 07, 2014, 08:53:17 PM
I've been trying to understand all this, and what it truly means/impacts. Let me know which option I have is correct:
1. This affects products (pedals) that are:
a) sold in any US physical retail stores (online excluded) to US customers
b) sold in any US story (online and physical) to US customers
c) sold in any store worldwide (online or physical) to US customers
d) sold in any US store (online or physical) to any country worldwide
e) Sold in any story worldwide (online or physical) to worldwide customers
2. Pedals are fine if they:
a) Do not contain charge Pumps, PT2399's or FV1 chips
b) Do not contain analog BBD technology (Chorus, Delay, Flange, Etc)
c) Are made in small numbers
d) Are made and sold from outside the US
3. DIY pedals are fine?
If that sums it up, in the end, what does a very small shop like mine really need to pay attention to? Do I need to pull and stop selling anything with a Tap Tempo or Charge Pump in it?
Jacob
There are a lot of questions there and I'm not enough of an expert to answer all of them. From my limited understanding:
1.) Country of sale dictates what regulations need to be conformed to. For the US it's FCC (also UL if line voltage is present). For Canada, it's Industry Canada, for Europe it's the EU (CE Mark). There are different ones for Australia, Japan, Korea, etc. All of the rules aren't the same, and the 9kHz emission requirements may not apply in all countries. The onus is on the manufacturer to understand the laws of the land.
2.) Pedals are fine if they are within the specified emissions standards above 9kHz. If they don't emit anything above 9kHz (for example a fuzz or a distortion with standard mechanical switching) then there are no emissions to be tested. If they have a clock that operates above 9kHz (most digital circuits) or charge pumps then they most likely won't have excessive emissions but they need to be conformance tested. If they fail because their RF emissions are above allowed thresholds, they can't be sold until they are modified to conform.
I've never seen anything that tied compliance to the amount of units sold. From what I understand, the FCC just has set the regulations and products comply or don't and the businesses need to make sure they have done their due diligence (regulators love that phrase). If it is being sold in a retail environment, it could certainly be considered a commercial product.
I don't know if DIYers are technically exempt, but I think they are certainly off the radar. Unless you managed to make something that had such large emissions that it actually caused a problem the FCC actually noticed, I can't imagine it would be a problem. I've never heard of anybody sending a non-commercial product for FCC certification; it just wouldn't make any sense.
Is it worth it for a small shop to drop the coin for compliance? That's tough to answer. I think that most regulators would say yes, but I am sure a lot of small business owners would say no. The real risk is a financial one. The odds of the FCC cracking down on a smaller pedal builder is likely very very small. If they did, however, there could be fines involved.
I could imagine a certain designer of certain circuit and their assistant being just butt-hurt enough to drop dimes. Not of their own doing mind you...
The rules say it needs to be tested if it plugs in to the mains ...
(http://cdn.shopify.com/s/files/1/0191/2838/products/2.1mmto9v1_1024x1024.jpg?v=1356927248)
Quote from: jubal81 on May 07, 2014, 10:37:06 PM
The rules say it needs to be tested if it plugs in to the mains ...
(http://cdn.shopify.com/s/files/1/0191/2838/products/2.1mmto9v1_1024x1024.jpg?v=1356927248)
atta boy jubal. just ship each pedal with one of those and state it's intended to operate on a 9v battery.
Sell the offending chip seperately?
Quote from: jubal81 on May 07, 2014, 10:37:06 PM
The rules say it needs to be tested if it plugs in to the mains ...
(http://cdn.shopify.com/s/files/1/0191/2838/products/2.1mmto9v1_1024x1024.jpg?v=1356927248)
Haha! Awesome, i send some of those sometime to customer who asks for spare solution.
Quote from: Haberdasher on May 07, 2014, 10:44:19 PMatta boy jubal. just ship each pedal with one of those and state it's intended to operate on a 9v battery.
You know what ... this is probably the real solution.
I don't think that'll work to get an exemption. The full wording includes,
Quote
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.
I think just putting in the DC jack would count as a provision.
....just like the Mayans predicted.
Quote from: jubal81 on May 07, 2014, 10:37:06 PM
The rules say it needs to be tested if it plugs in to the mains ...
(http://cdn.shopify.com/s/files/1/0191/2838/products/2.1mmto9v1_1024x1024.jpg?v=1356927248)
That is pure genius right there! I think you solved the issue.
Quote from: jubal81 on May 07, 2014, 10:37:06 PM
The rules say it needs to be tested if it plugs in to the mains ...
(http://cdn.shopify.com/s/files/1/0191/2838/products/2.1mmto9v1_1024x1024.jpg?v=1356927248)
That is pure genius right there! I think you solved the issue.
the link in the OP doesn't work...
Quote from: Beedoola on May 08, 2014, 02:45:26 AM
the link in the OP doesn't work...
This is the one in the diysb thread.
http://www.effectsbay.com/2014/05/fcc-regulations-for-pedals/
Here's a bit more info that I've found:
http://www.bureauveritas.com/wps/wcm/connect/31b53f004edb713e8d5fcd600bbc220b/FCC_Frequently_Asked_Questions_Aug10.pdf?MOD=AJPERES
For those who CBA to read the link, here are a couple of salient points:
"Battery power is not an exemption. Even a cell ph
one can broadcast for miles. Toys are not exempt
either. Toys can make more radio noise than other equipment because plastic or plush enclosures
do not shield the electronics like a metal box may.
Manufacturing run is not exempt either. Even if
you make and sell only a handful of devices,
it needs FCC equipment authorization. "
It also breaks down what types of testing are needed. For a 9kHz device like a pedal, it is an unintentional radiator and only needs verification testing (basically, it needs to be checked to ensure that it passes emissions standards). I assume that one could self-certify assuming there was access to the test equipment and an anechoic chamber. I am not sure about that. Unintentional radiator does seem to have the least stringent requirements. Compare that to something like a Bluetooth device, where you have to do all of the testing, get certified and register with the FCC.
"The FCC has four main categories of equipment authorization:
Verification (unintentional radiators)
Declaration of Conformity (unintentional radiators that connect with PC's or television systems)
Certification (intentional radiators, radar detectors)
Registration (telephones & telecommunication devices)
Different authorization is needed for different types of equipment. Technical expertise is needed to
evaluate the design to ensure correct authorization. "
I'm still trying to figure out what the overall bottom line is to this. I'm hoping I can find something that is reasonable as far as cost but qualifies from a regulatory perspective.
In case anybody is still even remotely interested in the topic, I've gone a bit further down the rabbit hole.
Here is a copy of the previous ANSI standard that outlines the requirements for compliance.
http://ecee.colorado.edu/~ecen4517/materials/refs/standards/ANSI_C63.4-2003.pdf
The current standard is ANSI C63.4-2009, but it costs $141 and I wasn't ready to fork that out just yet. It looks like the new standard has some new info on intentional radiators, so the unintentional transmitters may not have changed much. This is a good starting point.