Bone Capes and FCC Compliance?

I've searched around but only found questions regarding FCC part 15
compliance of the Beagles (in all varieties) themselves.

I'm interested in possibly developing a cape (and selling it if
there's interest) for the Bone, but I'm concerned about FCC compliance
testing costs. Getting a Bone and cape combo tested to ensure
compliance is not free (I've been told a few thousand US dollars). I
expect the market for my specialized capes to be rather small (*maybe*
a hundred units per year at most), so the up-front cost of FCC
compliance testing would cause each cape to be cost prohibitive.

What is the BeagleBoard team's stance on FCC compliance for capes?

For example, are the "official" capes that the BeagleBoard team is
developing (I'm making an assumption that the BeagleBoard team is
actually doing this, I have no evidence) going to be tested to ensure
compliance with FCC part 15?

Is there an expectation that hobbyist designed capes will also be
tested for compliance? (This may be more of a legal issue than a
market desire)

Are there any exceptions for "add-on cards" (or the like) within the
FCC requirements that hobbyists could take advantage of in order to
design and sell capes without the expense of actual testing?

It is my understanding that a "kit" sold where the buyer must solder
the parts to the bare PCB does not have to be tested to be compliant
with FCC. But that potentially limits the types of capes that can be
designed (ie: no BGA parts). This follows the same thinking where you
can build your own desktop computer from parts you buy. As long as
you don't sell the assembled computer, it does not have to comply with
FCC regulations unless someone complains about your computer's
emissions (but if someone complains, you have to fix it).

Thanks!

Well, you done went and did it. You just opened Pandora’s box. There are different perspectives on this topic. Yes it does indeed cost money. This may be something I can help you with, but that is on a case by case basis and would depend on the specific function of the board. I am willing to have a one on one discussion with you about this.

Overall, the issue pertains to whether or not this is in a box and sold as a finished product. If it is, then there are FCC requirements that it be tested and comply. If you are selling a component, like a Cape as it can’t function alone, having this tested will help with sales as it shows your component complies, but the builder of the finished product will need to retest the entire assembly.

Agreed, if you are only selling 100 boards, then this will not be in an end product and the cost of getting FCC testing done will add cost to the board, a lot of cost. requiring each cape to be FCC tested would mean we may have 10 Capes by the end of the year.

The big wild card in all this is that if you have a BeagleBone and a Cape that you test and show it complies great! Then somebody adds a few wires or tacks a circuit to it, it most likely will not comply. And to do what I just described, is exactly what we want people to do. Then if they were to be so bold as to add another Cape in the stack, it would affect your compliance as well. Does that mean you would have to test your board over and over and over again as new Capes come out? I suspect that would throw a wrench into you plans.

As far as an official stand from beagleboard.org, it is up to the builder of the device to make that call. But, I see little value in getting it done. If you follow the model from others, like Arduino for example, I don’t believe their shields have FCC testing. Some of them may have. Such devices, such as WIFI, BT, or other RF devices should be taken through some level of testing or even better, use modules that have already been tested and shown to comply with FCC rules. Other countries have their own rules as well to consider. These boards are developed for creating new applications and concepts by building Capes, adding Capes, modifying Capes to make these solutions better. These Capes are all just components and not finished products and cannot operate with a BeagleBone being plugged in. I think ROHS type issues are just important and a lot easier to control.

This is just my opinion! I welcome input from others on this topic.

Gerald

Well, you done went and did it. You just opened Pandora's box.

It is my intention to open the box. I used to work for a big company
that took FCC (and every other country) compliance testing very
seriously (think basketball court sized anechoic chamber on site that
got daily use). I see emissions compliance being rather untalked
about in the hobbyist hardware communities. There's a huge lack of
information out there on what exactly you, as a seller of hobbyist
designed hardware, need to do in order to be on the right sides of
what ever laws apply. This is something that's not directly
applicable to the open source / free software side of things.

This
may be something I can help you with, but that is on a case by case basis
and would depend on the specific function of the board. I am willing to
have a one on one discussion with you about this.

Thanks. I'd prefer to not need personal support that sets any kind of
precedent, as I don't think that scales well for the BeagleBoard.org
team.

Overall, the issue pertains to whether or not this is in a box and sold as
a finished product. If it is, then there are FCC requirements that it be
tested and comply. If you are selling a component, like a Cape as it can't
function alone, having this tested will help with sales as it shows your
component complies, but the builder of the finished product will need to
retest the entire assembly.

I think then we get into the minutia of what counts as a "finished
product." I'd be wanting to sell capes themselves, making them a
product in my eyes. I wouldn't be selling capes attached to Bones.
The capes as I sell them wouldn't be able to do anything unless
attached to a Bone (cause that's where the power comes from, least of
all).

But given that, how is it different than a graphics card company
selling PCI-Express cards? It looks to me like it's not. PCI-Express
cards themselves don't do anything, you have to plug them into a
computer for them to be useful (and get power). But I have never seen
a PCI-Express card that doesn't have an FCC logo sticker implying
compliance.

Regardless of if the PCI-Express card is FCC compliant, when Dell
designs a new computer to sell, they have to get the entire system to
pass compliance tests.

The big wild card in all this is that if you have a BeagleBone and a Cape
that you test and show it complies great! Then somebody adds a few wires or
tacks a circuit to it, it most likely will not comply. And to do what I
just described, is exactly what we want people to do. Then if they were to
be so bold as to add another Cape in the stack, it would affect your
compliance as well.

Yes, but same goes for any other technology I buy that I want to
modify. That doesn't prevent each piece that I purchase from needing
to be compliant with FCC. The intent of the buyer is not considered,
the operation of the product in its usual mode is. If the user buys
my cape and modifies it such that it violates FCC regulations, the
buyer is at fault, not me, and the FCC will come after them (not me).

Same way I can go buy a radio transmitter, tune it to an FM radio
station frequency, and start my own pirate radio station. As long as
the transmitter I bought was FCC certified, the transmitter seller
isn't at fault, I am. I'm the idiot broadcasting on a frequency I'm
not supposed to be on.

Does that mean you would have to test your board over
and over and over again as new Capes come out? I suspect that would throw a
wrench into you plans.

I would just test my cape attached to a stock Bone, powered and
connected to peripherals that are reasonable to expect a user to have
(same way FCC already requires). This is the same rationale used when
testing just the BeagleBone for compliance, you don't have to test
every possible thing that can plug into USB, just a likely example USB
device.

As far as an official stand from beagleboard.org, it is up to the builder
of the device to make that call. But, I see little value in getting it
done. If you follow the model from others, like Arduino for example, I
don't believe their shields have FCC testing. Some of them may have.

I'll definitely take a look at Arduino shields.
I found a good set of links in an Adafruit forum post:
http://forums.adafruit.com/viewtopic.php?f=26&t=22596

People seem to not want to discuss FCC certification. It's regarded
as a dirty secret thing. I think that's bad for the hobbyist hardware
designer (or a market ripe for innovation! :).

Such devices, such as WIFI, BT, or other RF devices should be taken through
some level of testing or even better, use modules that have already been
tested and shown to comply with FCC rules. Other countries have their own
rules as well to consider. These boards are developed for creating new
applications and concepts by building Capes, adding Capes, modifying Capes
to make these solutions better. These Capes are all just components and not
finished products and cannot operate with a BeagleBone being plugged in. I
think ROHS type issues are just important and a lot easier to control.

But, even if you only use already compliant modules in your design,
you still must have your design comply with FCC regs as a *system*,
especially if you're selling an intentional emitter (since then you
have to register it with the FCC and get a certificate, which is even
more expensive). The only benefit from using modules that already
comply is that you can be less worried about your own system's
compliance.

I understand this is a very gray area. RoHS is a whole 'nother ball
game but with similar risks. In either case (FCC or RoHS), if no one
complains, you have no issue. But if someone complains or tests your
product and you fail, you could end up in a world of hurt...

When the BeagleBoard.org group originally started selling
BeagleBoards, had they been through and passed compliance testing? If
answering that question is a potential legal issue, feel free not to
answer (and I'd think you'd want to ask someone familiar with the law
before answering it if the answer is "no").

-Andrew

The BeagleBoard-xM and the BeageBone all went through FCC testimg before we started shipping. We didn’t get FCC done on the original BeagleBoard per se, no lab report we paid for, but it was tested by another company and it passed everything.

Gerald

Gerald,

Thank you for taking the time to answer my questions. I know this can
be a touchy subject.
I truly appreciate all that you and the rest of the BeagleBoard.org
team do and I value your work and input very highly.

Thanks!
-Andrew

No problem!

Gerald

The BeagleBoard-xM and the BeageBone all went through FCC testimg before we started shipping. We didn’t get FCC done on the original BeagleBoard per se, no lab report we paid for, but it was tested by another company and it passed everything.

I understand that this thread is really old; but i have a question related to this topic. Do you know where i can get a copy of the FCC report of beagleboard XM? I am particularly interested in the conducted RFI report of the on-board ethernet.

I personally tested conducted RFI of the ethernet port. It passed FCC Class A requirement, but failed comply with the EMC directive for Europe. There were excessive conducted emission for frequency .15-1.2Mhz. These are the harmonic frequencies observed:

150 Khz
210 Khz
262 Khz
357 Khz

If anyone as an idea what causes it please share.

Thank you,

-toan

Contact Circuitco. clint@circuitco.com

Gerald

As far as i know, The FCC report from Clint only indicated compliance for a system that uses mouse, keyboard, hdmi, and power adapter. His report was insufficient for European EMC since it did not include serial and ethernet. That’s why i needed to test the ethernet/serial for electromagnetic interfaces.

Then you will need to redo your own test and make adjustments to the design accordingly.

Gerald