FCC Compliance for small business

[Raisintoe]

TL;DR Summary

Ideas for helping a startup business get products certified?

I have been developing some simple electronic devices to help with Animated Christmas Light displays. I was about to start selling professional versions of my devices, until I found out I am required to get them FCC certified. This costs about $2500 per design, which is completely outrageous considering that I only plan to sell about a hundred of them. I thought engineering was supposed to be fun; but the government has its hands too far in this industry. I understand the importance of regulations, but this is an intentional tax on the industry, and completely destroys small business and innovation. At least I only need FCC, and not CE or UL.

Does anyone know of a way to get financial support to pay for FCC compliance testing? My only thoughts are to get on Kickstarter or Iniegogo to get backers. Even then, I don't think I can get enough support to pay for this.

I also wonder how the little vendors sell their stuff on SparkFun. I see cheep little USB devices on their website, and I don't believe they are CE or FCC certified. Are their loopholes that I don't know about?

Maybe there are standard circuit blueprints that are FCC certified. And if I follow the blueprint, I don't have to get my device certified? This first device that I am trying to sell is a pretty generic circuit design.

 

[berkeman]

Summary:: Ideas for helping a startup business get products certified?

I also wonder how the little vendors sell their stuff on SparkFun. I see cheep little USB devices on their website, and I don't believe they are CE or FCC certified. Are their loopholes that I don't know about?

I believe they are probably claiming that those open boards are for lab use only, and not for commercial use in homes, etc. The whole reason for FCC certification is to ensure that your device does not cause harmful radio interference with other electronic devices. The last thing you want to have happen is for your device to cause interference with police/fire/EMS radio channels. I've helped on "fox hunts" for such interfering devices, as they are taken quite seriously.

Do you have any digital clocks in your device? If so, what frequencies?

 

[Raisintoe]

I believe they are probably claiming that those open boards are for lab use only, and not for commercial use in homes, etc. The whole reason for FCC certification is to ensure that your device does not cause harmful radio interference with other electronic devices. The last thing you want to have happen is for your device to cause interference with police/fire/EMS radio channels. I've helped on "fox hunts" for such interfering devices, as they are taken quite seriously.

Do you have any digital clocks in your device? If so, what frequencies?

This first device I made is a USB 2.0 - to - DMX interface device. So I have to get FCC certified for the 125 KHz caused by the DMX protocol, as well as the 240 MHz caused by the USB 2.0 protocol.

 

[berkeman]

USB 2.0 - to - DMX interface device

Something like this?

https://www.enttec.com/product/controls/dmx-usb-interfaces/dmx-usb-interface/

 

[Raisintoe]

Yes! Except mine is just like their ENTTEC Open DMX. Same thing.

 

[Raisintoe]

I only plan to sell within the United States. So FCC should be all I need.

 

[berkeman]

I only plan to sell within the United States. So FCC should be all I need.

I think that's right, unless you connect to AC Mains or are claiming isolation voltage like the first link that I posted.

Yes! Except mine is just like their ENTTEC Open DMX. Same thing.

Like this one -- can you just use an off-the-shelf unit that already has the certification(s), and add value with your software?

 

[Raisintoe]

I think that's right, unless you connect to AC Mains or are claiming isolation voltage like the first link that I posted.

Like this one -- can you just use an off-the-shelf unit that already has the certification(s), and add value with your software?

I guess I just won't sell mine, that's the answer. But mine uses the 3-pin DMX output, which is more common. It also has some status LEDs which would be helpful for someone trying to debug their settup. Mine was a first attempt to learn the business, and now I know it.

 

[Raisintoe]

One other question. I don't need my PE license to design and manufacture electronic products do I? As long as everything I do is contained within my business, and I am not offering an "Engineering Service" to anyone, then that is acceptable?

 

[berkeman]

One other question. I don't need my PE license to design and manufacture electronic products do I? As long as everything I do is contained within my business, and I am not offering an "Engineering Service" to anyone, then that is acceptable?

It depends on the product probably, but I would say no. When you start to sell your products to the public, though, you do need to think about liability and maybe some form of insurance. If your product is unlikely to hurt someone or catch fire, then it's less of an issue. But if you're considering selling hoverboards with Li-Ion batteries in them, well, you may want to talk to a business insurance agent.

You mentioned Christmas Lights in your original post (OP). Are those Christmas Lights AC Mains powered, or low-voltage (12Vac/Vdc) powered?

 

[DaveE]

The last thing you want to have happen is for your device to cause interference with police/fire/EMS radio channels. I've helped on "fox hunts" for such interfering devices, as they are taken quite seriously.

In the 1980's I worked at a defense contractor in Silicon Valley that (among other things) designed and tested antennas (in a goofy inflatable building, BTW. A "temporary" structure that stood for decades). Then a cable ground station moved in next door. We all thought it was a stupid location, what with 1/R² and such. Sometime in the next year we did something to interfere with everyone's cable signal. Yes, fire and EMS are important, but there is no wrath in America like the wrath of screwing up people's TV reception. The cable company and the FCC had our facility* completely shut down in just a few hours with cease and desist orders.

Anyway, there is a difference between "taxes" and regulations. Regulations are necessary if you live near other people. The cost (to everyone, BTW) is that you may have to demonstrate compliance. You may not want to, or think it's unfair, but your neighbors shouldn't have to pay that cost. It is reasonable to test and certify devices at the manufacturer level. This is why we get to have communications systems, like your smart phone, that actually work.

edit: * "our facility" included about six large buildings with lots of other electronic labs. They shut down everything that wasn't "office work" everywhere until they'd sorted it out. Which actually didn't take long given that they were dealing with other EE's on site.

 

[Raisintoe]

It depends on the product probably, but I would say no. When you start to sell your products to the public, though, you do need to think about liability and maybe some form of insurance. If your product is unlikely to hurt someone or catch fire, then it's less of an issue. But if you're considering selling hoverboards with Li-Ion batteries in them, well, you may want to talk to a business insurance agent.

You mentioned Christmas Lights in your original post (OP). Are those Christmas Lights AC Mains powered, or low-voltage (12Vac/Vdc) powered?

Christmas Lights would be another story, yes. They would be the 120 V AC Christmas Lights

 

[Tom.G]

Christmas Lights would be another story, yes. They would be the 120 V AC Christmas Lights

With 120VAC you probably want UL (Underwriters Laboratory) approval. UL was created by the insurance companies to cut their losses from shoddy products. As far as I know, UL certification is not legally required.

But, and this is a BIG BUT, if injury or property damage is caused by a non-UL approved product the insurance companies won't pay, leaving you responsible for all damages. So if your product burns down somebodys mansion, you just bought a pile of ashes for the replacement cost of that mansion and its contents.

Instead of producing the complete product, perhaps you could produce an adapter/debug add-on that works only on the low voltage interface to the competing product. That may avoid the UL problem. It is unclear to me if that would avoid the FCC requirements. The FCC has authority over any device that generates a signal of 10kHz or higher.

Yeah, building a business can be fun, and satisfying... but boy you sure learn a lot in the process!

Cheers,
Tom

p.s. Here in California at least, you need a PE license if you are selling Engineering Services, not products.

 

[Raisintoe]

With 120VAC you probably want UL (Underwriters Laboratory) approval. UL was created by the insurance companies to cut their losses from shoddy products. As far as I know, UL certification is not legally required.

But, and this is a BIG BUT, if injury or property damage is caused by a non-UL approved product the insurance companies won't pay, leaving you responsible for all damages. So if your product burns down somebodys mansion, you just bought a pile of ashes for the replacement cost of that mansion and its contents.

Thanks, I remember hearing that UL cost $60 000 / year. That's good to know if that is optional. Although, as you explained, I wouldn't want to end up legally liable for someone's home burning down.

p.s. Here in California at least, you need a PE license if you are selling Engineering Services, not products.

That is what I remember learning in my research. Thank you for confirming that.

 

[russ_watters]

One other question. I don't need my PE license to design and manufacture electronic products do I? As long as everything I do is contained within my business, and I am not offering an "Engineering Service" to anyone, then that is acceptable?

A PE license is primarily if not exclusively for the construction industry. It is for getting building permits. So no, you don't need it.

 

[Raisintoe]

I just found this on SparkFun, and thought I'd share it. This answers some common questions about FCC compliance: https://www.sparkfun.com/tutorials/398

 

[DaveE]

UL cost $60 000 / year

UL isn't the only game in town. Frankly that sounds ridiculous for a simple product. But a few decades ago at least, I can attest that UL is sometimes was often ridiculous. They WERE my absolutely least favorite regulatory agency to work with, but we also had unusually complex stuff to certify.

Simple products (from a product safety view) are simple to get approvals for, they will do a couple of simple tests and inspect your documentation. For the European CE certifications you can "self-certify" but real companies don't do this often because of the liability concerns mentioned above. If you really, really do have a safe product, and you really, really do build it correctly, then theoretically, you won't lose in court. However, you will probably spend more on lawyers than you would have on simple safety certifications. BTW, agency approvals aren't a free ride, you will still have to show that you are building exactly the same thing that they approved.

 

[berkeman]

I remember hearing that UL cost $60 000 / year.

Where did you see/hear this? I agree with @DaveE that the number is way out of line with my UL experiences.

 

[Raisintoe]

Where did you see/hear this? I agree with @DaveE that the number is way out of line with my UL experiences.

What I heard was that it cost up to $15 000 per audit that they do. Maybe it is a company-wide audit, I am not sure. And these audits happen up to four times a year. I really don't know much about UL.