Wednesday, 27 November 2019

Does my Arduino-based device need FCC certification?


I've built a small consumer device that contains an Arduino Nano. It's coupled to a custom daughter board that allows it to pulse a 12V electromagnet at about 1 hertz as well as inteface to some sensors. It does not intentionally produce any RF emissions like wifi or bluetooth.


I'd like to sell my device in the US, and I'm trying to determine what certification I need to legally sell it. From what I've read about FCC certification, including similar questions here, it's needed by nearly all electronic devices that oscillate above 9 kHz.


So, if I understand this correctly, my custom daughter board wouldn't require FCC certification? The Arduino Nano contains a clock that oscillates at 16 MHz, but I believe it already has FCC certification. Does my composite device constitute something that needs to be re-certified by an FCC approved testing lab? I'm not sure how much I'll be able to sell the device for, and don't expect to make much money, so if I can avoid wasting $10,000 on worthless certification for an unintentional emitter, I'd like to do so.



I'm not sure if this is an appropriate question for this site. If it's not, where could I find an answer to this? I've checked the FCC's website, but aside from vague FAQs, I can't find any way to contact anyone with a clue. I've seen some test labs offering to give me a quote to answer this question, but since they have nothing to gain by telling me "no don't bother paying us thousands to test your device", I'm hesitant to trust a response from them.



Answer



You are confusing certification and emissions requirements. Only intentional radiators need to be certified. From your description, your device is not a intentional radiator.


However, you are still obligated to ensure it does not radiate excessively. The limits are defined in part 15 of the FCC rules.


How you determine for yourself and ensure that the device does not radiate more than allowed is up to you. The FCC doesn't go looking at the millions of devices that are unintentional radiators and test them for compliance. However, your competitors might. If they find your device radiates illegally, they can file a complaint with the FCC.


The worst case is if some communication got interfered with, the FCC investigates, and finds one of your devices causing the problem. Then it gets serious fast.


Large resellers may require a recognized lab to certify that your device radiates legally, or they won't carry it.


All that said, for a little guy selling a few 100 gizmos a year off some web site, there is very little chance anyone is going to check whether the device radiates within the limits. If you follow best practices, like a good overall grounding strategy, filtering of external wires, etc, chances are very low your device will radiate enough past the limits for anyone to notice or to care.


As Dirty Harry would say: "you've got to ask yourself one question: 'Do I feel lucky?' Well, do ya, punk?"


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