FCC Part 15: The right category for FCC Part 15 Subpart B or Subpart C

[safetylink]

We need to find the category our product needs to be certified under:

1. FCC Part 15 Subpart B– Unintentional Radiators, Or
2. FCC Part 15 Subpart C – Intentional Radiators.

Our product consists of two PCBs (Printer Circuit Boards) coupled with a pin connector.

1. PCB 1 is off the shelf commercially available SBC (Single Board Computer). This PCB has an FCC ID in Equipment Class: DSS - Part 15 Spread Spectrum Transmitter. Hence it is approved to be used in the US.
2. PCB 2 is our custom PCB and does not emit intentional radiations hence would be an Unintentional Radiator.

Our product is to be use at home and in business organizations. Note that the PCB with intentional radiation has already obtained OEM certification under FCC Part 15 Spread Spectrum Transmitter. We do not have the ability to provide radiation information about PCB 1 as it does not belong to us.

In such a case which category would our product fall into:

1. FCC Part 15 Subpart B - Unintentional Radiators. Or
2. FCC Part 15 Subpart C – Intentional Radiators

 

[gophert]

When dealing with federal regulations, the cost of being wrong is so much higher than the cost of a professional/expert consultant. There is no reason to waste a day searching and guessing or hoping some random person on the internet will pick A or B for you. Just hire an expert.

Remember, my cost of being wrong is $0.00

If you want someone to be wrong on your behalf, I will happily pick A or B for you but you will have to pay the penalties.

 

[alec_t]

Have you contacted the regulatory authority directly for an opinion?

 

[RadioRon]

I could give you my opinion, but in this case your question is important enough that you should have an expert reply. Contact a certification test lab of which there are many:

https://apps.fcc.gov/oetcf/eas/reports/TestFirmSearch.cfm

These labs are usually empowered to issue/approve FCC certifications and approvals for Part 15 products, so you are getting your info straight from the horses' mouth, so to speak. To be sure, look for the designation "TCB" in the lab's literature. This means it is a Telecommunication Certification Body, designated by the FCC.

My opinion is that it depends on what certification the computer board has. If it has a "modular" approval for its wireless communication function, then other boards can be added and the entire combination retested as a subpart B device only, which is less onerous. However, if the computer board subpart C approval is not modular, I suspect the entire combination has to be recertified as a subpart C device.

Here is an fcc description of "modular" authorization:

https://apps.fcc.gov/kdb/GetAttachment.html?id=iL3CDxZIRRPc1UBc25AGsQ==

 

[unclejed613]

remember these are regulations from a government agency. the regulations will say there are NO exceptions, while clearly stating at the same time that there ARE exceptions. if you find this confusing, you know nothing about government agencies.

 

[gophert]

The regulations will say there are NO exceptions, while clearly stating at the same time that there ARE exceptions. if you find this confusing, you know nothing about government agencies.

British and German regulations seem to be written by experts in a way most readers understand.

American regulations seem to be recommended by experts, drafted by marketing people, edited by lobbyists and published by politicians.