Messages

I think you won the Tayda lottery.  Those all look OK.

If you test more than that, I'd put the data in a spreadsheet; it'd be easier to compare.

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 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'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. 

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. 

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.

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.

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).

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.

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.

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.

My next step is to build a company to test these for all pedal builders and offer it slightly cheaper than others and profit

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.

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.

Very nice.

Mine's coming soon.  Can't wait.

Well, I guess it's time to break out the Han Solo in Carbonite chocolate bar

Great looking etch, Cody.  I love the symmetrical lion around the switch.