38 Replies Latest reply on Nov 30, 2016 4:35 PM by clem57

    Class B Certification for Pi strongly advised

    morgaine

      Last week in the Element14 Pi Group, we continued the perennial and very interesting discussion about FCC certification by examining the rules published by FCC which determine whether a digital device is considered to be Class A (commercial) or Class B (residential).

       

      In the FCC's document OET Bulletin 62,

      "UNDERSTANDING THE FCC REGULATIONS FOR COMPUTERS AND OTHER DIGITAL DEVICES"

      http://www.fcc.gov/Bureaus/Engineering_Technology/Documents/bulletins/oet62/oet62rev.pdf

      pages 8-9 seem to make it clear that the level of certification is not just an arbitrary vendor choice independent of to whom a digital device is marketed, but is very strongly defined by whether it "is sold or offered for sale to any residential users" (the FCC's own words and emphasis).

       

      See my post at http://www.element14.com/community/message/87490#87490 for full details, further discussion, and FCC references in the footnote.  The FCC references confirm that the definition of Class A/B explained in FCC OET Bulletin 62 is current today.

       

      According to OET Bulletin 62, the only exceptions from Class B arise from "the application for which the device is designed" precluding operation in residential areas, and "the price of the device" being high enough to make residential use improbable.  It does not seem likely that the Pi can avail itself of either of these exceptions.  Reducing the options still further, FCC states that portable computers are considered Class B devices "regardless of their price or restrictions placed on marketing".

       

      The FCC's subsequent paragraph explains "What happens if one sells or imports non-compliant digital devices?"  The penalties it lists are so harsh (including a per-day, per-violation fine) that I think it would be wise for Premier Farnell to immediately (re)commence the Class B certification work that we were told was already in progress in May 2012, in parallel with urgently seeking authoritative input.

       

      Prevaricating on this matter for Raspberry Pi really doesn't seem worth the many risks, particularly when similar devices like Beagleboard Black are already certified to Class B levels.

       

      Legal and financial risks aside, everyone even slightly acquainted with Pi knows that it is in residential use almost universally.  On engineering responsibility grounds alone, that makes certification to residential standards important.

       

       

      [FCC Section 15.3 (h) citation now added below in post #8.]

      • Reply
        • Re: Class B Certification for Pi strongly advised
          morgaine

          It might be worth pointing out that a hypothetical "Class B certification is planned for the educational release" would not address the issue nor eliminate the ongoing risks of violation.  FCC regulations do not limit Class B to educational use but apply to all residential uses of digital devices, and very probably to the million+ Pi in homes right now.

          • Re: Class B Certification for Pi strongly advised
            morgaine

            Our detailed analyses of certification issues in the Pi Group have been (mostly) specific to FCC regulations alone.  Although these do not apply directly to the EU nor other parts of the world, I note from reading EU EMC standards that there is an ongoing "harmonization effort" which not only unifies regulations in the member EU nations but also brings the language of EU EMC legislation closer to that used by the FCC.

             

            This small extract from the article "Update on the European Union's EMC Directive" in Compliance Engineering magazine addresses the definition of Class A and B digital devices in EU harmonized legislation specifically:

             

            Existing Harmonized Standards
            Product-Family Standards

            The first standards under the EMC Directive were not published ("harmonized") until February 19, 1992. The majority were product-family emission standards-that is, they prescribe limits depending primarily upon the nature of the equipment, rather than upon where it is used. Some of these standards do, however, provide Class A and Class B limits to accommodate residential or industrial applications, as shown in Figure 2.

             

            http://www.ce-mag.com/99ARG/media/99ARGCE80A.jpg

                 Figure 2. Class A and Class B limits to accommodate residential or industrial applications.

             

             

            The use of Class A and Class B limits within the EU often differs from FCC usage. Within Europe, Class B emissions limits are frequently imposed upon equipment that, though operating in a commercial or light-industrial environment, is nevertheless connected to an AC mains branch that also serves residential units. This is justified as follows: because conducted interference propagates through the residential AC mains, emissions from all connected sources should be kept to the lower (Class B) limits. This interpretation is popular throughout the EU and has been formalized into a policy of mandatory Class B compliance for all hospital equipment in Sweden and all telecommunications equipment in Norway. The EU interpretation is moving closer to the FCC definitions of Class A (nonresidential) and Class B (residential) devices. The latest version of CISPR 22 (1997) adopts the FCC class definitions, based upon a lack of evidence of interference when the FCC guidelines are used.

             

            In summary, the article explains that although FCC and EU EMC directives are not the same, the FCC's commercial/residential definitions of "Class A" and "Class B" are nevertheless already adopted and being strengthened in the harmonization effort.  No doubt manufacturers and vendors alike see this as a good thing.

             

            However, it does place a strong burden of responsibility upon them to understand the FCC definitions in the first place, and of course to be in compliance with the legal requirements for devices that are in residential  use.

              • Re: Class B Certification for Pi strongly advised
                John Beetem

                Morgaine Dinova wrote:

                 

                Existing Harmonized Standards
                Product-Family Standards

                The use of Class A and Class B limits within the EU often differs from FCC usage. Within Europe, Class B emissions limits are frequently imposed upon equipment that, though operating in a commercial or light-industrial environment, is nevertheless connected to an AC mains branch that also serves residential units. This is justified as follows: because conducted interference propagates through the residential AC mains, emissions from all connected sources should be kept to the lower (Class B) limits.

                 

                I once heard a lecture on TV technology from a guy who wanted a television set that would interfere with his neighbors' power tools.   This was the same lecture where I learned that NTSC stands for "Never Twice Same Color".

                  • Re: Class B Certification for Pi strongly advised
                    morgaine

                    A TV that interferes with a power tool is not actually as ludicrous as it might at first appear.

                     

                    As our tools get more and more "intelligent" (rolling of eyes is permitted), the control electronics of a power tool will become every bit as sensitive as those of a TV.  It's certainly no stretch of the imagination that a badly designed CPU board will one day accidentally cause a badly designed power tool to power-on and  result in harm or death.

                     

                    As engineers, we don't currently swear to a Hypocratic Oath like physicians do in many countries, but nevertheless we do have a social responsibility as professionals in our discipline.  Complying with the safety and emissions regulations in our respective jurisdictions is the most visible manifestation of that social responsibility.  It's what distinguishes professional engineers from cowboys.

                • Re: Class B Certification for Pi strongly advised
                  morgaine

                  To make it easier for interested parties to follow the regulatory details, here is the relevant FCC citation.

                   

                  FCC OET e-CFR Title 47 Part 15 Subpart A Section 15.3 (h,i) defines (my highlighting in bold):

                  (h) Class A digital device. A  digital device that is marketed for use in a commercial, industrial or  business environment, exclusive of a device which is marketed for use by  the general public or is intended to be used in the home.

                   

                  (i) Class B digital device. A  digital device that is marketed for use in a residential environment  notwithstanding use in commercial, business and industrial environments.  Examples of such devices include, but are not limited to, personal  computers, calculators, and similar electronic devices that are marketed  for use by the general public.

                  In other words, a Class A device cannot  be marketed for use by the general public or intended to be used in the home.  If such a device previously marketed for commercial, business and industrial use (and correctly certified as Class A), were to have its marketing changed such that it subsequently becomes marketed for use by the general public or intended to be used in the home, then it would no longer be a Class A device, it would instantly become a Class B device.

                   

                  That's the point of the word "exclusive" in Section (h), it denies in an absolute manner (through definition) the possibility of Class A devices being marketed for use in a residential environment.  The corresponding definition of a Class B device is given in Section (i).

                   

                   

                  (In case the specific URL ever changes, navigate to Section 15.3 (h) from the top level of the FCC e-CFR.)

                  • Re: Class B Certification for Pi strongly advised
                    morgaine

                    It has been over a week since I posted this thread in Feedback & Support.  Although not phrased as a question to be answered, it was nevertheless reasonable I think to expect some kind of acknowledgement, given the gravity of the matter.  After all, FCC regulations and federal law are not optional, and the penalties for violation are harsh.

                     

                    The FCC regulations about Class B digital devices have been clearly cited, in FCC OET e-CFR Title 47 Part 15 Subpart A Section 15.3 (h,i) and FCC OET Bulletin 62.  They don't leave much room for misinterpretation.  Even if you are averse to reading legal documents of any kind, it should be clear that devices marketed for residential use require residential certification, which is Class B.

                     

                    And yet, Raspberry Pi is being marketed and sold into the residential market as we speak bearing only a Class A certification.  Every reader who has examined the citations should be able to understand that there is very high likelihood of an FCC violation ongoing, with a million+ non-residentially certified units deployed into the domestic environment already.  And every employee of Premier Farnell group should also (at least in principle if not by training) be aware of the importance of compliance with regulatory EMC requirements, strongly reinforced by the group's own Code of Ethics.

                     

                    So, I'm now asking for confirmation  that this issue has been understood by people at Element14, and that the matter is not being dismissed on the say-so of one or more parties who may have given contrary advice without providing the FCC citations that justify it.

                      • Re: Class B Certification for Pi strongly advised

                        Morgaine, please be assured that we have escalated the question to our product team. We are still awaiting their response, and we will be happy to provide an update as soon as we hear from them.   

                          • Re: Class B Certification for Pi strongly advised
                            morgaine

                            Thanks Nicole.  The risks to everyone are too great for this matter not to be taken seriously.

                             

                            Nicole Fusz wrote:

                             

                            ... and we will be happy to provide an update as soon as we hear from them.   

                             

                            Note that the  "update" that I most want to see is E14 mandating that Pi obtain Class B certification with the greatest of urgency.

                             

                            Business issues are an internal matter for you alone, and I'm not giving advice on that.  But we are all stakeholders where regulatory EMC compliance is concerned, because we are all affected by these devices in our homes.  The risk is not limited to your customers alone, but also includes non-customers in the residential vicinity of this equipment.  It's everyone's professional responsibility to do the right thing about EMC here.

                             

                            Please keep the product team on the ball over this.  It's worth noting that they have already prevaricated for over a year despite regular concerns expressed about the issue by other members.

                        • Re: Class B Certification for Pi strongly advised

                          Hi Guys.  I posted this on the other thread I found for this topic, but wanted to share it with you as well. :-)  Many of you have been asking for an update on the FCC compliance of the Raspberry Pi. Our teams are closely investigating the points that have been raised here on the element14 Community. Compliance for all of our products is something we take very seriously, and we're glad you've been raising them here! We appreciate your patience and understanding while we confirm the outcome of this investigation.  We'll provide an update as soon as we can!  Thanks, Sagar

                            • Re: Class B Certification for Pi strongly advised

                              Two months ago, Sagar wrote:

                              Many of you have been asking for an update on the FCC compliance of the Raspberry Pi. Our teams are closely investigating the points that have been raised here on the element14 Community. Compliance for all of our products is something we take very seriously, and we're glad you've been raising them here!

                              Any news?

                                • Re: Class B Certification for Pi strongly advised
                                  jamodio

                                  This gives a new meaning to the word "closely" ....

                                    • Re: Class B Certification for Pi strongly advised
                                      mcb1

                                      Closely in this case might mean

                                      Can't

                                      Let

                                      Our

                                      Secret

                                      Escape

                                      Lets

                                      Yawn

                                       

                                      or

                                       

                                      Can't

                                      Let

                                      Others

                                      See

                                      element14

                                      Little

                                      Yarns

                                       

                                      I wouldn't hold your breath.

                                      The only way its going to happen is if its forced by reporting it to the FCC.

                                       

                                      Mark

                                       

                                      Oh dear I might get banned now ...in case i don't see you again....

                                        • Re: Class B Certification for Pi strongly advised
                                          jamodio

                                          I don't think that we have to play the certification police role. Frankly I don't care much if the boards are certified or not, but if I get asked by a school district if any particular piece of electronics meets their requirements in terms of certification, until we get a positive confirmation the only choice we have is to assume that the answer is no.

                                           

                                          Then it really complicates any plans for kids in some places to be able to use the Raspberry Pi in classrooms or science labs with boards provided by the school district, or the school may resort to have parents sign a waiver or some other workaround.

                                           

                                          Is that simple, the problem is not if it is complaint or not, the problem is the lack of a concrete response.

                                           

                                          On the other hand I don't see anything wrong if after the tests the conclusion is that the board as is not class B compliant, then in that case is a decision by whoever makes or distribute it if makes or not business sense to make the necessary changes to meet compliance.

                                           

                                          Regards

                                          Jorge

                                          • Re: Class B Certification for Pi strongly advised
                                            morgaine

                                            Element14 peeps, it's time for a practical update on this issue.  "Still working on it" is not an update.

                                             

                                            We've got a bit distracted by the site being turned into a disaster area by the "upgrade" in recent weeks, but that's not an excuse for delay that would hold any sway with the FCC.  The people who work on legal issues are in any case not the web developers nor the forum admins, and so progress will not have been delayed by the site issues.

                                             

                                            Whoever has grabbed this matter at E14, please show us progress, whatever there is of it.  There must be some progress over these last two months of silence, otherwise you have just been stonewalling us.

                                             

                                            I am concerned that Premier Farnell is going to be tarnished by the issue having been knowingly blocked within the E14 division, preventing it escalating to a level where it can be resolved.  The FCC rules are very clear, and strongly suggest that around a million or more devices may have been sold illegally into the US domestic market regulated by FCC.  With delay in resolution comes risk, since FCC outlines penalties per infraction.  Another two months of what appear to be illegal residential sales will not be helping.

                                             

                                            Please provide us with a genuine update.

                                             

                                            Morgaine.

                                              • Re: Class B Certification for Pi strongly advised
                                                GeorgeIoak

                                                Not that my opinion matters but Morgaine has brought up some very valid points. I recently started importing a similar product and have been investigating the FCC rules and came to the same conclusion as Morgaine. To be honest, where I'm confused is on the points of what is required beyond the actual testing. These boards would be classified as unintentional radiators so if my understanding is correct they don't need to be submitted to the FCC to obtain a FCC ID. What I'm not clear on is if just the testing (by an approved testing facility) is enough and whether this testing would have to be done on every model (Model A and Model B).

                                                 

                                                All of this shouldn't even be a discussion though. With over 2 million units sold the cost of testing is almost nothing. The BeagleBone had the testing performed and you know that it's volumes are significantly less than 2 million units.

                                                 

                                                As a side note, the wording I found in the FCC documents is that basically everyone in the distribution chain is liable if a product is being sold that does not meet FCC requirements. Why on earth would element14 even drag their heels on this?

                                                  • Re: Class B Certification for Pi strongly advised
                                                    jamodio

                                                    The FCC certification process is very simple and straight forward, not even expensive for a commercial enterprise. Not every single board has to be tested and certified, and FCC does not perform the testing, there are many approved labs that can do the testing and provide the necessary information to file the paperwork with FCC.

                                                     

                                                    The obvious issue is that if you don't pass the tests you can't apply or claim that the product meets the certification requirements, but it does not mean you can't sell it under some conditions.

                                                     

                                                    Hard to say because we are not getting any responses, but after all this time the most reasonable assumption is that the board didn't pass some of the tests and there are no intentions (for whatever reasons) to make the design and production changes needed to meet the certification requirements, and the status quo  and stay mute about the subject is the preferred option.

                                                     

                                                    My .02

                                                    Regards

                                                    Jorge

                                                    • Re: Class B Certification for Pi strongly advised
                                                      morgaine

                                                      George Ioakimedes wrote:

                                                       

                                                      As a side note, the wording I found in the FCC documents is that basically everyone in the distribution chain is liable if a product is being sold that does not meet FCC requirements. Why on earth would element14 even drag their heels on this?

                                                       

                                                      There's no shortage of companies willing to work just slightly on the wrong side of the law and to accept fines as nothing more than "the cost of doing business".  I do NOT however consider Premier Farnell to be one of them.

                                                       

                                                      The FCC documents are very clear and don't seem to leave any room for misinterpretation, so the current situation is very concerning.  Particularly the silence, which is deafening.

                                                       

                                                      Morgaine.

                                                        • Re: Re: Class B Certification for Pi strongly advised
                                                          GeorgeIoak

                                                          I think Jorge may be right in that the initial testing showed some issues but then if that was the case I can't imagine them not trying to fix them when they released the Rev B design.

                                                           

                                                           

                                                          Jorge wrote"


                                                          Not every single board has to be tested and certified

                                                          I wan't implying that every board needed to be tested but would a separate report be needed for the Model A and the Model B since it could be claimed they would emit the same level of radiation.

                                                            • Re: Class B Certification for Pi strongly advised

                                                              George Ioakimedes wrote:

                                                               

                                                              I wan't implying that every board needed to be tested but would a separate report be needed for the Model A and the Model B since it could be claimed they would emit the same level of radiation.

                                                              Interesting question, the answer probably depends on how deeply anyone digs into the design. On the original spin of the board where the lan9512's 1.8v was tied to the rest of the board and you ended up with the lan9512 regulator doing all the work, then a model A vs model B result could potentially be diferent as the model A ends up using a different power path.  That problem goes away with the respin of the board, but then even if you don't retest for A vs B, do you have to for spin 1 vs spin 2 ?  As far as we know the only one tested was a spin 1 model B. If there's now more spin 2 boards been produced than spin 1 I'm sure someone could come up with a credible argument for requiring a retest with spin 2.

                                                                • Re: Class B Certification for Pi strongly advised
                                                                  mcb1

                                                                  Many years ago I was involved in a project to produce a commercially installed device.

                                                                  We went through the electrical testing via an approved company.

                                                                   

                                                                  The paperwork detailed key features and specified that 'that' design was approved and recorded the various parts and the construction, method of attaching the incoming power, etc.

                                                                  Not 100% the same as FCC, however if hardware that could change the outcome of the results is changed, then it would be expected to be retested with the new design.

                                                                  Otherwise you could build it to meet, and then change it to work.

                                                                   

                                                                  ie changing a resistor manufacturer, or regulator manufacturer would be okay, however changing the load on the regulator would be a different design.

                                                                   

                                                                  A model A and model B IMO are NOT the same, and each would require testing for compliance.

                                                                   

                                                                  Mark

                                                                • Re: Class B Certification for Pi strongly advised
                                                                  jamodio

                                                                  Ohh, OK. Yes different certification tests are required for each model, particularly model B will be the most tricky since ethernet interfaces are extremely "noisy"

                                                                   

                                                                  -J

                                                  • Re: Class B Certification for Pi strongly advised

                                                    Slight divergence, but it appears that the Cubieboard A10 version has recently passed FCC class B, the certification and test report are available from http://cubieboard.org/download/

                                                     

                                                    or:

                                                    http://ubuntuone.com/6n2rLKYmlU2BcK6yPPQBv3

                                                    http://ubuntuone.com/4y5EUmcQ0ogrBjtBbV2D92

                                                    • Re: Class B Certification for Pi strongly advised
                                                      morgaine

                                                      Reinforcing how bad (and self-inflicted) the situation has become for Farnell with a Christmas-specific thread:

                                                       

                                                      "Christmas presents for children without residential certification".

                                                       

                                                      As I noted there, presumably CPC-Farnell advertising the bundle as "Years 8+" is additional indication of deliberate residential marketing.

                                                       

                                                      Morgaine.