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"
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.]