How to validate a market with development boards and SD cards(flyingcarcomputer.com)
flyingcarcomputer.com
How to validate a market with development boards and SD cards
https://flyingcarcomputer.com/posts/how-to-validate-market-with-development-board/
118 comments
The first rule of knowing if a market exists is to define what you are making and then figure out who it's for. Then pitch to that person the benefits of your product.
Alas the FAQ page lacks both of these questions. I'm left with no idea -why- I'd buy this thing. What utility does it have? What is it supposed to replace?
I think you can stop worrying about the FCC issues with it. You won't sell any of these (at least not with this FAQ page). Your whole "discussion" is technical and doesn't mention utility once.
It sounds to me like you're building this because it's fun to build and scratches an itch. But it's not a product, much less requires you to start building and designing new hardware. So well done on at least skipping that investment.
If you want to make a hardware product then early about utility first. If it's useful then other things flow from that. Not the other way around.
Alas the FAQ page lacks both of these questions. I'm left with no idea -why- I'd buy this thing. What utility does it have? What is it supposed to replace?
I think you can stop worrying about the FCC issues with it. You won't sell any of these (at least not with this FAQ page). Your whole "discussion" is technical and doesn't mention utility once.
It sounds to me like you're building this because it's fun to build and scratches an itch. But it's not a product, much less requires you to start building and designing new hardware. So well done on at least skipping that investment.
If you want to make a hardware product then early about utility first. If it's useful then other things flow from that. Not the other way around.
> The first rule of knowing if a market exists is to define what you are making and then figure out who it's for. Then pitch to that person the benefits of your product.
I would switch that order. Figure out your customer before you define what you're making.
I would switch that order. Figure out your customer before you define what you're making.
Yes, that's even better.
Why is it so expensive though? Also, why not fine or ban products that cause problems rather than requiring certification. It seems that would be a lot more efficient.
It's not expensive. What does a week of a good hardware engineer's time cost?
It's not even necessarily that expensive: $3K-$5K is a good budgetary range if you don't have any pre-compliance test and engineering capability because you might need 2-3 trips to a certified test lab to pass. If you have experience in your product space and good pre-compliance testing, you can definitely be one-and-done for less than that.
It's not even necessarily that expensive: $3K-$5K is a good budgetary range if you don't have any pre-compliance test and engineering capability because you might need 2-3 trips to a certified test lab to pass. If you have experience in your product space and good pre-compliance testing, you can definitely be one-and-done for less than that.
[deleted]
"We've just bought 50,000 new whatevers for our worldwide chain of stores... Oh, oops, they cause EM interference, throw them away I guess."
(More realistically, you'd just see extremely slow adoption in any important use-case.)
(More realistically, you'd just see extremely slow adoption in any important use-case.)
> Also, why not fine or ban products that cause problems rather than requiring certification
Because people could get hurt or killed in the meantime. See the 737max for example.
Now it is a dramatic example, but think about any device unwillingly emitting too much electromagnetic radiation potentially being harmful to kids or messing with people pacemakers.
Because people could get hurt or killed in the meantime. See the 737max for example.
Now it is a dramatic example, but think about any device unwillingly emitting too much electromagnetic radiation potentially being harmful to kids or messing with people pacemakers.
You could make similar arguments for basically any product, doesn't seem worth it to get every product certified though.
Also, didn't the 737max pass certifications?
Also, didn't the 737max pass certifications?
Almost every product is certified in the EU (CE marking), although if you look closely it's self-certification and it's not always clear which sets of certification might be required for a product.
(I'm on the fence about this; personally I think there need to be far more small company / small production run exemptions from these requirements, but on the other hand I don't want a loophole for recklessly dangerous products)
(I'm on the fence about this; personally I think there need to be far more small company / small production run exemptions from these requirements, but on the other hand I don't want a loophole for recklessly dangerous products)
Worst of all: if you package certified CE product... you need to certify the whole package too!!! Think about using some certified CE PC in a cabinet for example...
On the other side: if you forget ventilation in the cabinet, the certified PC might burn... so packaging CE certified components doesn't mean that the whole is risk-free
On the other side: if you forget ventilation in the cabinet, the certified PC might burn... so packaging CE certified components doesn't mean that the whole is risk-free
> Worst of all: if you package certified CE product... you need to certify the whole package too!!!
Yes. This is a significant difference from the US, where FCC compliance testing for modules is much more reasonable.
The US also appears to contract out basic electrical safety to the insurance industry (Underwriter's Laboratories).
Yes. This is a significant difference from the US, where FCC compliance testing for modules is much more reasonable.
The US also appears to contract out basic electrical safety to the insurance industry (Underwriter's Laboratories).
The NFPA writes the national electric code. They also came out of the insurance industry, and like UL and FM, predate adoption of their standards in regulation. FM is an actual insurance company but it is not OSHA. The history is similar to European organizations like the German TUeV, which came out of the boiler industry. All of them have their roots in disasters of the industrial revolution.
Governments today generally don't operate test laboratories, standards organizations, or certification bodies. DIN, ISO, IEC, BSI etc are not government organizations.
You're right, though, that there's more history of insurance industry involvement in developing safety standards and testing in the US.
Governments today generally don't operate test laboratories, standards organizations, or certification bodies. DIN, ISO, IEC, BSI etc are not government organizations.
You're right, though, that there's more history of insurance industry involvement in developing safety standards and testing in the US.
There used to be. But they've been almost completely stripped away because of rampant abuse.
> Almost every product is certified in the EU (CE marking), although if you look closely it's self-certification and it's not always clear which sets of certification might be required for a product.
Not to be confused with the Chinese Export marking: https://www.kimuagroup.com/news/differences-between-ce-and-c...
Not to be confused with the Chinese Export marking: https://www.kimuagroup.com/news/differences-between-ce-and-c...
The amount of misinformation on the internet is worryingly high but not unexpected. No such thing as Chinese Export logo exist. It cannot officially exist in the EU since the CE sign is protected. Whatever this website is sharing is FUD and misinformation.
It doesn't mean that nobody fraudulently puts those markings on devices without a testing certificate backing it. However anybody who puts CE mark on a product without complying is risking being punished by EU member states. As an importer and distributer of such goods you'll be punished as well. CE certification is indeed self disclosed but it doesn't mean that you would get away with noncompliance.
Source: https://www.europarl.europa.eu/doceo/document/P-6-2007-5938-...
It doesn't mean that nobody fraudulently puts those markings on devices without a testing certificate backing it. However anybody who puts CE mark on a product without complying is risking being punished by EU member states. As an importer and distributer of such goods you'll be punished as well. CE certification is indeed self disclosed but it doesn't mean that you would get away with noncompliance.
Source: https://www.europarl.europa.eu/doceo/document/P-6-2007-5938-...
The "China Export" logo is extremely funny as it's basically a Chinese response to "you need a label? OK, fine, we'll give you a label" with none of the underlying bureaucracy.
The "UKCA" one, on the other hand, is real but tragic.
The "UKCA" one, on the other hand, is real but tragic.
Using fraud as a counter example, where the self certifying manufacturer admitted to the crime before Congress, kinda seems like missing the point.
Ditto Dieselgate.
Doesn't negate the need for testing. Rather, it shows the need for effective oversight.
Ditto Dieselgate.
Doesn't negate the need for testing. Rather, it shows the need for effective oversight.
> Also, why not fine or ban products that cause problems rather than requiring certification.
Because certifying upfront is cheaper than trying to find products that cause problems in the field, do lots of testing and find somebody and recall all the other products that are in the field
Because certifying upfront is cheaper than trying to find products that cause problems in the field, do lots of testing and find somebody and recall all the other products that are in the field
It seems like fining or banning problems found problems 'in the wild' would require customer troubleshooting to find the cause, manufacturers would lose the product development cost for banned products, and the regulator(s) would have to staff for discovery in the field rather than in the lab. IMO, this seems like it could be more expensive than finding potential problems early.
Certification requires testing in a specialized lab that has a special anechoic chamber along with equipment that runs tens of thousands to hundreds of thousands of dollars. You also need an engineer or highly trained technician to run the test and/or interpret the results. You also have to wire up and instrument every device that comes in and they do vary a little. That's why the cost is in the thousands of dollars. There is a profit margin for the labs but it's also not a cheap service.
It is not efficient policing bad devices after the fact. You can have a bad device interfere with RF communications for miles. It then requires dispatching a team of humans with RF probing equipment and escalating to the Feds if the person refuses to comply. It does happen but it is time consuming.
Leaky RF can cause mass events such as https://www.cbc.ca/news/canada/calgary/carstairs-westview-co...
Here's a IEEE Video on the process of interference hunting: https://www.youtube.com/watch?v=elUDfDmIHLs
A short article on how some equipment on a tug boat was interfering with a town: https://www.verizon.com/about/news/verizon-test-force-braves...
And this is the interference hunting that has to happen now with devices certified. It would be an absolute hell if devices could just be introduced willynilly.
It is not efficient policing bad devices after the fact. You can have a bad device interfere with RF communications for miles. It then requires dispatching a team of humans with RF probing equipment and escalating to the Feds if the person refuses to comply. It does happen but it is time consuming.
Leaky RF can cause mass events such as https://www.cbc.ca/news/canada/calgary/carstairs-westview-co...
Here's a IEEE Video on the process of interference hunting: https://www.youtube.com/watch?v=elUDfDmIHLs
A short article on how some equipment on a tug boat was interfering with a town: https://www.verizon.com/about/news/verizon-test-force-braves...
And this is the interference hunting that has to happen now with devices certified. It would be an absolute hell if devices could just be introduced willynilly.
Agreed, but I can't find that quote in TFA so I can't entirely tell which point you're rebutting. Did the author remove it?
EDIT: Oh, I see you meant to reply to some top-level comment further down.
EDIT: Oh, I see you meant to reply to some top-level comment further down.
Now, how to get the SD card in the hands of the customer? Mail it to them!
I worked on a equipment project for a large restaurant chain about a decade ago. The core application and related assets/recipes/files were all on an SD card. When it was time to upgrade the app or release new seasonal recipes, every store got a new SD card in the mail with instructions to wait for a certain date, power down, swap cards, power back on, dispose of the old card.
It was way cheaper to send updates that way than bother with encryption, networking, corrupted disks, etc. A bricked machine lost a hundred dollars or more per hour. If the new card failed, the operator could continue with the old one until a replacement could be sent.
One major problem was suppliers always trying to swap to lower cost SD cards, even counterfeit ones (c.f. Bunnie), and things would go south really fast. The Linux system and hardware were both pretty old and had MMC stack issues when the cards showed shaky margins on the timing. Or, capacity wasn't what was advertised (c.f Bunnie). We had to spend a cycle or two qualifying each mailing release to make sure a shitty batch of cards didn't make its way into the stream.
SD has its uses, although I still prefer a read-only eMMC partition to hold the bootloader and O/S. I don't get why RPi users put themselves through such misery to save $20 on their SBC.
I worked on a equipment project for a large restaurant chain about a decade ago. The core application and related assets/recipes/files were all on an SD card. When it was time to upgrade the app or release new seasonal recipes, every store got a new SD card in the mail with instructions to wait for a certain date, power down, swap cards, power back on, dispose of the old card.
It was way cheaper to send updates that way than bother with encryption, networking, corrupted disks, etc. A bricked machine lost a hundred dollars or more per hour. If the new card failed, the operator could continue with the old one until a replacement could be sent.
One major problem was suppliers always trying to swap to lower cost SD cards, even counterfeit ones (c.f. Bunnie), and things would go south really fast. The Linux system and hardware were both pretty old and had MMC stack issues when the cards showed shaky margins on the timing. Or, capacity wasn't what was advertised (c.f Bunnie). We had to spend a cycle or two qualifying each mailing release to make sure a shitty batch of cards didn't make its way into the stream.
SD has its uses, although I still prefer a read-only eMMC partition to hold the bootloader and O/S. I don't get why RPi users put themselves through such misery to save $20 on their SBC.
Glad to hear that this passed muster in the food industry. Do you by any chance remember how the SD card was packaged or protected from damage while in transport?
They're pretty durable. It can survive in a padded envelope just fine. I've had them in the pockets of my jeans after a washing machine cycle.
> Normally, market forces would dictate that by now it would be straightforward, fast, and affordable to get your product tested as frequently as desired. However, in reality, the labs are “too busy” to respond or reply very late and generally sound less than eager to work with you. Not to mention, the fees that they quote are rarely palatable to a bootstrapping startup.
The various test labs I’ve worked with haven’t been “too busy” to respond. However, they are generally hesitant to work with people who don’t really know what they’re doing.
If you are an engineer with knowledge about the process and who needs a lab to partner with, it’s not hard to get in somewhere.
However, if you don’t have the knowledge or experience, the lab might sense that you’re looking for someone to hold your hand heavily through the process. They may be less than enthusiastic to take on a one-off customer who might require an abnormally high amount of communication and hand-holding when they can fill that same spot with a repeat customer who needs nothing more than to book the time at the lab and can show up prepared and ready to go.
I suggest teaming up with a local consultant for your first round. Not only will they help you through the process, they’ll have connections and reputation to get you into the labs.
The lab fees aren’t extraordinary high for a hardware startup, really. It’s not free, but it’s not much relative to the up front costs of building hardware inventory.
The various test labs I’ve worked with haven’t been “too busy” to respond. However, they are generally hesitant to work with people who don’t really know what they’re doing.
If you are an engineer with knowledge about the process and who needs a lab to partner with, it’s not hard to get in somewhere.
However, if you don’t have the knowledge or experience, the lab might sense that you’re looking for someone to hold your hand heavily through the process. They may be less than enthusiastic to take on a one-off customer who might require an abnormally high amount of communication and hand-holding when they can fill that same spot with a repeat customer who needs nothing more than to book the time at the lab and can show up prepared and ready to go.
I suggest teaming up with a local consultant for your first round. Not only will they help you through the process, they’ll have connections and reputation to get you into the labs.
The lab fees aren’t extraordinary high for a hardware startup, really. It’s not free, but it’s not much relative to the up front costs of building hardware inventory.
In my limited experience, it was the other way around. I had to hold the technician's hand through most of the testing and onboard several technicians due to a staggering amount of employee churn in the test house. What should take an afternoon would take months of intermittent testing at very inconvenient times (night slots). Next time I might just show up outside their door with a sleeping bag and refuse to leave until the tests are completed.
Maybe we were the problem and our documentation was insufficient, but we never had a chance to do a "post-mortem" with the test house and learn how we could do better next time.
Maybe we were the problem and our documentation was insufficient, but we never had a chance to do a "post-mortem" with the test house and learn how we could do better next time.
[deleted]
As someone who has built relationships with labs to the point where I had "special privileges" the most important thing you can do is:
Make your test setup as easy as possible.
To expand on that:
1) Realise that you're mostly working with testing technicians NOT engineers. They see all sorts of weird and wild stuff. They often have to parse poorly written and complicated manuals written by engineers who don't have a clue about writing manuals and make poor implicit assumptions about the "target audience".
2) It's frankly, often soul destroying work (hence the churn, especially at the bigger labs). They use the crappy manuals for crappy products (but everyone thinks their product is the bees knees) try and set it all up. Then it doesn't work. Or it fails because the customer didn't do any pre-compliance work and was "hoping it would just pass". Well time is money, now they have to break the setup down because they've wasted 1 hour on the phone to some engineer who doesn't know what's wrong and is trying to trouble shoot through the phone. Now they get to do ALL that again with one else's crappy product.
So how do you make it as easy as possible for them?
1) Your setup should be plug and play and I mean TRULY plug and play. No manual should be required for putting the device into some hacky test state. Get the software engineers to automate it.
Does a button need pushing? Automate it or just remove the requirement somehow.
Does it need wiring up? Nail it all down on a giant piece of ply wood. Zip tie down all the cables. All the dummy loads. Any other devices. The only thing they should need to connect is the power cable.
Does a laptop need to drive it? Automate everything on there. ONE SCRIPT, maybe a menu in there depending on what test they are running. Make the laptop bullet proof. Get a nice laptop that boots and runs fast (not the one at the bottom of the IT donor pile). Give them a mouse to use.
Remove ALL of these barriers. AUTOMATE it ALL. Don't require them to baby sit it. That's a waste of their time.
PLUG AND PLAY.
2) Make it easy for a technician to see if and when the device is working VS it's not working. Don't give them instructions on "open this menu, do this, do that ..." no.
Put a red LED on it and a green one. Don't have one in your product? Be creative, Retrofit something. Have a special test UX on the device. Hell you should have special test firmware as a reference point.
They should be able to, at a single glance, look at the product and know: "Is it still working/running?"
So now imagine you have done all of that effort. Now put yourself in the shoes of that technician. One of the test stands is available early because a crappy product failed. They gaze towards the giant pile of crap they have to get through. Many are a a giant plastic box with tangles of cable, hand written crappy instructions, an IBM thinkpad from 1995 to drive it, no labels on any of the cables ....
... but amongst it they see your PLUG AND PLAY testable product. It's all mounted on a plywood stand, ready to go. There is almost a light from heaven illuminating it, it's so beautiful, it's so easy throw on a test stand and GO (and then do something else).
Guess which one is jumping the queue and going on that test stand? (And time is money remember. A test stand not testing is loosing money).
Make your test setup as easy as possible.
To expand on that:
1) Realise that you're mostly working with testing technicians NOT engineers. They see all sorts of weird and wild stuff. They often have to parse poorly written and complicated manuals written by engineers who don't have a clue about writing manuals and make poor implicit assumptions about the "target audience".
2) It's frankly, often soul destroying work (hence the churn, especially at the bigger labs). They use the crappy manuals for crappy products (but everyone thinks their product is the bees knees) try and set it all up. Then it doesn't work. Or it fails because the customer didn't do any pre-compliance work and was "hoping it would just pass". Well time is money, now they have to break the setup down because they've wasted 1 hour on the phone to some engineer who doesn't know what's wrong and is trying to trouble shoot through the phone. Now they get to do ALL that again with one else's crappy product.
So how do you make it as easy as possible for them?
1) Your setup should be plug and play and I mean TRULY plug and play. No manual should be required for putting the device into some hacky test state. Get the software engineers to automate it.
Does a button need pushing? Automate it or just remove the requirement somehow.
Does it need wiring up? Nail it all down on a giant piece of ply wood. Zip tie down all the cables. All the dummy loads. Any other devices. The only thing they should need to connect is the power cable.
Does a laptop need to drive it? Automate everything on there. ONE SCRIPT, maybe a menu in there depending on what test they are running. Make the laptop bullet proof. Get a nice laptop that boots and runs fast (not the one at the bottom of the IT donor pile). Give them a mouse to use.
Remove ALL of these barriers. AUTOMATE it ALL. Don't require them to baby sit it. That's a waste of their time.
PLUG AND PLAY.
2) Make it easy for a technician to see if and when the device is working VS it's not working. Don't give them instructions on "open this menu, do this, do that ..." no.
Put a red LED on it and a green one. Don't have one in your product? Be creative, Retrofit something. Have a special test UX on the device. Hell you should have special test firmware as a reference point.
They should be able to, at a single glance, look at the product and know: "Is it still working/running?"
So now imagine you have done all of that effort. Now put yourself in the shoes of that technician. One of the test stands is available early because a crappy product failed. They gaze towards the giant pile of crap they have to get through. Many are a a giant plastic box with tangles of cable, hand written crappy instructions, an IBM thinkpad from 1995 to drive it, no labels on any of the cables ....
... but amongst it they see your PLUG AND PLAY testable product. It's all mounted on a plywood stand, ready to go. There is almost a light from heaven illuminating it, it's so beautiful, it's so easy throw on a test stand and GO (and then do something else).
Guess which one is jumping the queue and going on that test stand? (And time is money remember. A test stand not testing is loosing money).
I would be embarrassed to publish this. It is a stunning display of ego and ignorance of how this part of the world works that boils down to the author being too cheap to put in the work and too lazy to understand why regulations exist.
It's wild to me that everyone here is taking this seriously. This is high school science fair level stuff.
You can find statements and notices and citations and such on the FCC web site to see what happens if you get caught out. If you're interested in that kind of thing, they're interesting reading.
Here is a pretty bad scenario for apparently willful unintentional radiator violations, where an ultrasonic foot bath company was at best unorganized and slow to comply with testing and labeling requirements: https://docs.fcc.gov/public/attachments/FCC-18-67A1.pdf
Here is a better scenario, where an LED sign manufacturer was a bit more on the ball: https://docs.fcc.gov/public/attachments/DA-22-1136A1.pdf
Note in both cases there is no mention that these devices emitted RF above allowed limits for unintentional radiators. These companies simply didn't test and didn't label their devices appropriately.
Here's one for Asus, where they got WiFi products certified, and then changed something, probably firmware, that allowed those devices to transmit more power than allowed: https://docs.fcc.gov/public/attachments/FCC-24-69A1.pdf
Here is a pretty bad scenario for apparently willful unintentional radiator violations, where an ultrasonic foot bath company was at best unorganized and slow to comply with testing and labeling requirements: https://docs.fcc.gov/public/attachments/FCC-18-67A1.pdf
Here is a better scenario, where an LED sign manufacturer was a bit more on the ball: https://docs.fcc.gov/public/attachments/DA-22-1136A1.pdf
Note in both cases there is no mention that these devices emitted RF above allowed limits for unintentional radiators. These companies simply didn't test and didn't label their devices appropriately.
Here's one for Asus, where they got WiFi products certified, and then changed something, probably firmware, that allowed those devices to transmit more power than allowed: https://docs.fcc.gov/public/attachments/FCC-24-69A1.pdf
Their FAQ here[0] explain some things about these devices they are building, except for the main question: what are they for? It says personal computers but no audio, video or games. So for reading?
[0] https://flyingcarcomputer.com/posts/a-new-personal-computer/
[0] https://flyingcarcomputer.com/posts/a-new-personal-computer/
Reading this, it doesn’t seem like they’re really doing anything more than building a glorified raspberry pi with their own self-spun BSD distro preinstalled. Also the FAQ being mostly Q: „why not use X?“, A: „I don’t know X and thus it’s bloated/I don’t like it“ doesn’t inspire a lot of confidence.
I admire their dedication and it seems like a fun project. I don’t think it’s something a lot of people will pay money for though.
I admire their dedication and it seems like a fun project. I don’t think it’s something a lot of people will pay money for though.
Looks very weird. No LCD screen, but presumably it’ll plug into a monitor? Seems like just pointing out expected use cases would go a long way.
"The testing and certification industry is odd. In theory, it exists to serve the public good and uphold consumer protection laws. On the other hand, its customers are in the private sector. Normally, market forces would dictate that by now it would be straightforward, fast, and affordable to get your product tested as frequently as desired. However, in reality, the labs are “too busy” to respond or reply very late and generally sound less than eager to work with you. Not to mention, the fees that they quote are rarely palatable to a bootstrapping startup. And yet, working with them is generally required to get your product to market."
Market forces naturally determined this outcome though. If you're big companies you naturally want to limit the threat of new competition. Making compliance more costly achieves this.
Market forces naturally determined this outcome though. If you're big companies you naturally want to limit the threat of new competition. Making compliance more costly achieves this.
I used to work at a place that did some custom hardware development. Usually one-off or very limited run. Any time we fabricated a case and plugged in off-the-shelf devices, certification was not necessary. If we did custom wiring we got ETL certified. I didn't run the process myself but I recall it being easy and not very costly (few thousand?) It's a barrier but a pretty low one. Our electronic work was like advanced amateur level and it still passed with minimal modifications.
> Market forces naturally determined this outcome though. If you're big companies you naturally want to limit the threat of new competition. Making compliance more costly achieves this.
Compliance for basic products isn’t costly, though. It’s a rounding error relative to the wages you have to pay engineers and the costs involved in manufacturing the product.
Compliance for basic products isn’t costly, though. It’s a rounding error relative to the wages you have to pay engineers and the costs involved in manufacturing the product.
It is a high cost to certify when you're not paying yourself and you're the only person in your startup/hobby.
Cost of DIY hardware design: 0 Cost of PCBA from China: rougly 100 to 2000 USD depending on complexity and nr of runs. Cost of DIY firmware and software: 0
Cost of external certification/compliance tests: 5000 to 25000 USD depending on the amount of runs it take to make it pass and what needs to be checked and what the industry is (battery management safety, medical, aerospace, FCC and/or CE, RED and/or others, etc).
So yeah, an RnD department wouldn't really care, but "guy in mom's basement" would.
Cost of DIY hardware design: 0 Cost of PCBA from China: rougly 100 to 2000 USD depending on complexity and nr of runs. Cost of DIY firmware and software: 0
Cost of external certification/compliance tests: 5000 to 25000 USD depending on the amount of runs it take to make it pass and what needs to be checked and what the industry is (battery management safety, medical, aerospace, FCC and/or CE, RED and/or others, etc).
So yeah, an RnD department wouldn't really care, but "guy in mom's basement" would.
This. The compliance requirements take out an entire tier of small companies and short run products. This eliminates a lot of potential startups at the first stage.
You don't get quite so many big companies without going through the small company stage. You're limited to VCs and spinoffs of other megacorps.
But I guess everyone is happy with the equilibrium that's actually emerged (buy your unregulated short run electronics from China).
You don't get quite so many big companies without going through the small company stage. You're limited to VCs and spinoffs of other megacorps.
But I guess everyone is happy with the equilibrium that's actually emerged (buy your unregulated short run electronics from China).
$10k is peanuts for starting a small business in many industries. It does not even buy you a truck. You don't need VC or a megacorp; this is well within the range of standard business loans.
If the project is actually just a hobby, then CE and probably FCC testing is not needed.
If the project is a startup, then the cost of labor is not zero, at least not if people are not deluding themselves (i.e. at least opportunity costs should be considered).
Personally, as a consumer, I'm pretty happy that I can buy e.g. a wireless mouse or a bluetooth speaker and can reasonably assume that they actually work and aren't accidently jammed by some "startup"'s hardware.
If the project is a startup, then the cost of labor is not zero, at least not if people are not deluding themselves (i.e. at least opportunity costs should be considered).
Personally, as a consumer, I'm pretty happy that I can buy e.g. a wireless mouse or a bluetooth speaker and can reasonably assume that they actually work and aren't accidently jammed by some "startup"'s hardware.
> If the project is actually just a hobby, then CE and probably FCC testing is not needed.
That's the entire problem: According to the law, it is! There are extremely few exception, and the exceptions that do exist are essentially useless for hobbyists. Everyone selling small-scale prototypes on websites like Tindie is just rolling the dice and hope they don't get get a life-ruining fine.
There are plenty of $5-$50 trinkets I'd like to design and sell as a hobby to fellow enthusiasts, due to their niche nature probably only a few dozen of each. But there's no way I can afford a $5000-$10.000 testing & certification fee on each one of those, and without that I'd be breaking the law.
That's the entire problem: According to the law, it is! There are extremely few exception, and the exceptions that do exist are essentially useless for hobbyists. Everyone selling small-scale prototypes on websites like Tindie is just rolling the dice and hope they don't get get a life-ruining fine.
There are plenty of $5-$50 trinkets I'd like to design and sell as a hobby to fellow enthusiasts, due to their niche nature probably only a few dozen of each. But there's no way I can afford a $5000-$10.000 testing & certification fee on each one of those, and without that I'd be breaking the law.
You can sell kits, because companies do. Kits are only required to be authorized in very specific rules for specific types of kits. However, devices assembled from kits are not exempt from FCC authorization requirements. Home built devices not assembled from kits do get an exemption. You figure out the contradictions here - i.e. this is not advice.
The FCC has fined people for assembling and selling uncertified radio transmitters from other's kits. Like this guy: https://docs.fcc.gov/public/attachments/DA-12-574A1.pdf Note that the company that sells the kit he was assembling is still selling the same kit that results in an uncertified AM-band transmitter when assembled.
The FCC has fined people for assembling and selling uncertified radio transmitters from other's kits. Like this guy: https://docs.fcc.gov/public/attachments/DA-12-574A1.pdf Note that the company that sells the kit he was assembling is still selling the same kit that results in an uncertified AM-band transmitter when assembled.
It's easy to blow $500K or more on certification of even a well-designed product, especially if you actually use UL for your testing (never again!) Yep, I've worked at a startup that did that.
If you don't have everythign done in China, certification is a racket: In addition to at least $60-80K minimum (for CE, which helps get UL/ETL if you need them), you'll be paying $5K/Quarter/factory for audits, and $2-5K just to open the report for any changes, including things like changing your company address!
You can't hate the bastards that run this industry enough. I have no problem with complying with reasoniable rules, but I have a big problem with shakedown protection rackets, which is what this is...
If you don't have everythign done in China, certification is a racket: In addition to at least $60-80K minimum (for CE, which helps get UL/ETL if you need them), you'll be paying $5K/Quarter/factory for audits, and $2-5K just to open the report for any changes, including things like changing your company address!
You can't hate the bastards that run this industry enough. I have no problem with complying with reasoniable rules, but I have a big problem with shakedown protection rackets, which is what this is...
Big companies are often outside "the market", in that they have internal labs which are accredited to test their own products.
Also, by definition, testing and certification companies have a captive market and will tend towards being lazy and exploitative. Any competition that springs up might temporarily improve things but then it too will get used to having a captive market and start sliding in the same direction.
a.k.a. "regulatory capture" - https://en.wikipedia.org/wiki/Regulatory_capture
Enforcing basic device safety is hardly regulatory capture. I was part of preparing devices for CE tests, the requirements are essentially: nobody gets killed if the hardware is plugged in, you haven't accidently created an rf transmitter, and if you want to advertise IP67 it should survive being placed under water.
You do know many devices like Raspberry CM have FCC/IC modular pre-compliance, and thus usually only require LAB EMI testing under the rules.
The primary problem with mystery-parts is they tend to have issues with RoHS documentation, complex customs clearance requirements, and unknown specifications.
DIY evaluation kits people assemble do fall under a sort of gray area, but if your hardware does splatter the RF spectrum it is a $1m fine in the US, and a $5k fine + up to 5 years in jail in Canada.
Unshielded RAM, USB/PCI to Ethernet, and Video GPU chips will often just barely pass EMI testing under ideal circumstances. Cheap stuff from the mystery bins will usually just glean the FCC id off a refrigerator to get through customs.
Have a nice day, =3
The primary problem with mystery-parts is they tend to have issues with RoHS documentation, complex customs clearance requirements, and unknown specifications.
DIY evaluation kits people assemble do fall under a sort of gray area, but if your hardware does splatter the RF spectrum it is a $1m fine in the US, and a $5k fine + up to 5 years in jail in Canada.
Unshielded RAM, USB/PCI to Ethernet, and Video GPU chips will often just barely pass EMI testing under ideal circumstances. Cheap stuff from the mystery bins will usually just glean the FCC id off a refrigerator to get through customs.
Have a nice day, =3
Ok so as someone working on something vaguely similar (portable computer, slightly different market, more RF focus) I assure you this person is just rambling on a blog.
Basically everything on their blog/faq ranges from inept to dangerously misleading.
Basically everything on their blog/faq ranges from inept to dangerously misleading.
> Variations of the FCC exist in pretty much every developed economy. Putting a poorly tested hardware product on the market immediately puts a target on your back. Maybe you’ll get lucky, but chances are that someone somewhere will report you. And, unless you are operating entirely out of China, it will hurt. A lot. Both your company and maybe even you, personally.
And that for good reason. Any bad actor on the RF spectrum can be an actual, significant and direct threat to people's lives - particularly the EMS bands as well as the rail, marine and flight safety/coordination channels are absolutely vital. Up next is stuff like GPS, radio and television where disturbances affect a lot of people, and then there's local stuff like wifi, Bluetooth, Zigbee, door openers and whatnot that only affects very few people.
Unfortunately it is very, very easy to be a bad actor on the airwaves. Powerline/PLC is hated by radio amateurs for a reason, and that one is actually even licensed. The other stuff is much, much worse.
And that for good reason. Any bad actor on the RF spectrum can be an actual, significant and direct threat to people's lives - particularly the EMS bands as well as the rail, marine and flight safety/coordination channels are absolutely vital. Up next is stuff like GPS, radio and television where disturbances affect a lot of people, and then there's local stuff like wifi, Bluetooth, Zigbee, door openers and whatnot that only affects very few people.
Unfortunately it is very, very easy to be a bad actor on the airwaves. Powerline/PLC is hated by radio amateurs for a reason, and that one is actually even licensed. The other stuff is much, much worse.
I wonder how much research this person did. At least in Germany, cheap DIY kits are everywhere !!!
https://www.pollin.de/p/bausatz-led-wechselblinker-810051
German company selling a German-made electronics kits in Germany without CE certification. And they have lots of them:
https://www.pollin.de/bauelemente/bausaetze-module/bausaetze...
As long as you don't connect to mains power and you don't ship a finished product, you're exempt from CE certification. So use an USB plug as your power supply and sell it as DIY kit to be assembled by the customer and you're good to go.
https://www.pollin.de/p/bausatz-led-wechselblinker-810051
German company selling a German-made electronics kits in Germany without CE certification. And they have lots of them:
https://www.pollin.de/bauelemente/bausaetze-module/bausaetze...
As long as you don't connect to mains power and you don't ship a finished product, you're exempt from CE certification. So use an USB plug as your power supply and sell it as DIY kit to be assembled by the customer and you're good to go.
The US and EU regulatory systems are quite different.
This exact blog also complained about EU regulation and selling stuff in EU. I think they basically don't know what they are doing.
https://flyingcarcomputer.com/posts/strategy-for-eu-bootstra... ?
I agree about the ambiguity of CE marking. It's pretty impenetrable as a non-expert. I wonder if he's referring to Fabius the Delayer.
> It even made me suspect that it is easier for a non-EU country to sell to customers in the EU than it is for an EU company to do the same. An advantage that Chinese businesses surely enjoy.
100% correct. There's way too many small parcels for customs to check them; the major nuisance is the recipient having to pay the tax themselves.
> If one were to incorporate in Estonia but not sell to anyone in Estonia, or any member of the European Union for that matter, that company would theoretically be exempt from a whole cluster of legal and tax headaches.
.. but why would you do that? This guy appears to be a US national, he should just register in Delaware like everyone else. The Estonian company and "E-Estonia" system is primarily useful if you do want to do business in the EU and have a presence there.
If you're not in the EU and want a flag of convenience company registration, the usual places like Grand Cayman offer their services.
I agree about the ambiguity of CE marking. It's pretty impenetrable as a non-expert. I wonder if he's referring to Fabius the Delayer.
> It even made me suspect that it is easier for a non-EU country to sell to customers in the EU than it is for an EU company to do the same. An advantage that Chinese businesses surely enjoy.
100% correct. There's way too many small parcels for customs to check them; the major nuisance is the recipient having to pay the tax themselves.
> If one were to incorporate in Estonia but not sell to anyone in Estonia, or any member of the European Union for that matter, that company would theoretically be exempt from a whole cluster of legal and tax headaches.
.. but why would you do that? This guy appears to be a US national, he should just register in Delaware like everyone else. The Estonian company and "E-Estonia" system is primarily useful if you do want to do business in the EU and have a presence there.
If you're not in the EU and want a flag of convenience company registration, the usual places like Grand Cayman offer their services.
What an odd person. I can't figure the Estonia thing out either. I think the idea is to provide plausible deniability that the company is operating in the EU??? By incorporating in the EU but doing nothing else there? I can't imagine what specific legal and tax headaches one would escape that way.
The CE marking is super simple in principle, right? Just self-certify that you meet all applicable European regulations, and that's when the fun starts. It would be impenetrable to do from scratch but as "negative zero" points out, you can bootstrap from looking at competing products' declarations of conformity.
The CE marking is super simple in principle, right? Just self-certify that you meet all applicable European regulations, and that's when the fun starts. It would be impenetrable to do from scratch but as "negative zero" points out, you can bootstrap from looking at competing products' declarations of conformity.
DIY/parts are a fuzzy area and might not need the certification, but the board at your first link does have a huge CE print near the LEDs.
Edit: I found this Make article (paywalled and in German) a good overview for makers wanting to sell hardware in the EU: https://www.heise.de/select/make/2017/6/1513996282631753
Edit: I found this Make article (paywalled and in German) a good overview for makers wanting to sell hardware in the EU: https://www.heise.de/select/make/2017/6/1513996282631753
There are plenty of products which ought to be certified but are not, and plenty of products that probably do not need to be that are.
This is across large and small companies, so I'm going to take a guess and say that in the AliExpress and Temu age, simply mailing the device from China will solve all of your problems.
This is across large and small companies, so I'm going to take a guess and say that in the AliExpress and Temu age, simply mailing the device from China will solve all of your problems.
> so I'm going to take a guess and say that in the AliExpress and Temu age, simply mailing the device from China will solve all of your problems.
Your guess would be wrong. The regulatory agencies aren’t inept. They’ll figure out where the headquarters is, not just where the products are being shipped from.
So unless you’re moving the entire company, and your bank accounts, to China and you have a backup plan for what happens when they start seizing your shipments at the border, this isn’t a solution.
Your guess would be wrong. The regulatory agencies aren’t inept. They’ll figure out where the headquarters is, not just where the products are being shipped from.
So unless you’re moving the entire company, and your bank accounts, to China and you have a backup plan for what happens when they start seizing your shipments at the border, this isn’t a solution.
Do you actually have an example of something like this actually happening? From what I can tell, at least in Canada, absolutely nothing from China I've bought has ever even been opened for inspection, and it's all tagged as a gift worth ten cents and a battery cover or something inane like that.
Anything from half a kilowatt hours of laptop batteries to miscellaneous electronics has passed through, so I don't think there is any inspection going on at all.
Anecdotally based on the number of things that I see without any FCC ID (tbf you can abuse the SDoC process which is self declared [this is why the CE certification is worthless btw] ), I'm just uncertain the FCC actually does any enforcement. And Amazon sellers are also an example of this not being an issue.
Anything from half a kilowatt hours of laptop batteries to miscellaneous electronics has passed through, so I don't think there is any inspection going on at all.
Anecdotally based on the number of things that I see without any FCC ID (tbf you can abuse the SDoC process which is self declared [this is why the CE certification is worthless btw] ), I'm just uncertain the FCC actually does any enforcement. And Amazon sellers are also an example of this not being an issue.
Yep. Fluke, an electrical instrument manufacturer, has a copyright on the look and feel of its handheld digital voltmeters (DVMs). Anyone in the industry will immediately know a Fluke by what it looks like. And they are pretty much the gold standard of handheld DVMs.
Some years ago, a containerload of cheap DVMs from China arrived with a similar appearance, but not made by Fluke. Customs seized the lot and informed them. I forget the details of what happened next, but they were not allowed to be sold in the US since they were in violation of the Fluke copyright.
Some years ago, a containerload of cheap DVMs from China arrived with a similar appearance, but not made by Fluke. Customs seized the lot and informed them. I forget the details of what happened next, but they were not allowed to be sold in the US since they were in violation of the Fluke copyright.
Regulatory certification is a shakedown racket that makes the Ticketmaster monopoly discussed a few items down look like a friendly environment.
Do you wonder why all of your new electronics are made in China? One big reason is that China has its own regulatory labs (which may or may not do testing - who knows?) that are literally at least an order of magnitude cheaper than getting certification done in the US or Europe.
I'm working on two client products now that I and the clients would prefer to have made here in the US, but both will be made in China because the companies literally cannot afford the rapacious cost of getting them certified here. (And China mfg is way cheaper, too - partly because of parts distribution models: It's literally cheaper to buy a finished product from China than to buy the components here to assemble the same product!)
Do you wonder why all of your new electronics are made in China? One big reason is that China has its own regulatory labs (which may or may not do testing - who knows?) that are literally at least an order of magnitude cheaper than getting certification done in the US or Europe.
I'm working on two client products now that I and the clients would prefer to have made here in the US, but both will be made in China because the companies literally cannot afford the rapacious cost of getting them certified here. (And China mfg is way cheaper, too - partly because of parts distribution models: It's literally cheaper to buy a finished product from China than to buy the components here to assemble the same product!)
We've been developing a wearable, which is classified as a medical device, so we've been looking at the FCC/CE/etc regulations for a while.
We're using ESP32s, and are currently going through ethics approval, which, from what I understand, means we can use the device prior to sale, but maybe we've got that wrong. I can't imagine having to have each hardware iteration certified by the FCC.
What struck me more about this article is the subject of marketing.
For companies that are doing pre-sales, and are still in development, and likely haven't been certified yet. Isn't that considered marketing? How are other companies handling this? We're looking to run a marketing trial in a few months, and marketing is part of the recruitment process for a trial.
We're using ESP32s, and are currently going through ethics approval, which, from what I understand, means we can use the device prior to sale, but maybe we've got that wrong. I can't imagine having to have each hardware iteration certified by the FCC.
What struck me more about this article is the subject of marketing.
For companies that are doing pre-sales, and are still in development, and likely haven't been certified yet. Isn't that considered marketing? How are other companies handling this? We're looking to run a marketing trial in a few months, and marketing is part of the recruitment process for a trial.
Ethics approval for a medical device is a completely different thing from EMC regulations (which is what normally people mean when talking about FCC and CE for a device).
"I can't imagine having to have each hardware iteration certified by the FCC."
Depending on your device and the magnitude of the changes, this might simply be the reality for you. This is why I always try to tell people that you need compliance at the table from the start or you really risk making life very difficult for yourself. Find yourself a compliance specialist or at least a hardware engineer who is familiar with the regulations.
EDIT: You CAN'T just iterate ad-infinitum for free without consequence like you do for software. This thinking and approach, only works in software land. No where else.
It would be ridiculous to build a house and having the builder iterate on your house over 2-3 years to finish it, no?
"I can't imagine having to have each hardware iteration certified by the FCC."
Depending on your device and the magnitude of the changes, this might simply be the reality for you. This is why I always try to tell people that you need compliance at the table from the start or you really risk making life very difficult for yourself. Find yourself a compliance specialist or at least a hardware engineer who is familiar with the regulations.
EDIT: You CAN'T just iterate ad-infinitum for free without consequence like you do for software. This thinking and approach, only works in software land. No where else.
It would be ridiculous to build a house and having the builder iterate on your house over 2-3 years to finish it, no?
You can get an experimental license from the FCC. Clinical trials are a specific example of what that process is for:
https://apps.fcc.gov/oetcf/els/help/442_License_Types.html
https://apps.fcc.gov/oetcf/els/help/442_License_Types.html
I never understood the nuance here. If I put a rasp pi in a box, does it need certification? What about with connections soldered on if all connections are already certified? How about the logical next step of a board with certified components?
I’m no expert but I think the problem is that once you start combining certified components in a new configuration that it’s theoretically possible for the sum of the parts to be non-compliant. Perhaps a wire you added becomes, in essence, a transmission antenna of the noise in the circuit and thus could interfere with other devices.
As far as I understand, modules like an ESP32 for example, carry their own FCC certification. If you include them in your product, you do still need certification of the product overall, but you don't have to worry about the radio certification, just unintentional radiators.
For instance, if your widget includes an ESP32 and a switching power supply, you are (notionally) guaranteed to never fail certification due to bad behavior from the ESP, but if you botch your power supply design and are spewing out noise in the KHz to MHz range, you still fail certification.
Even if every individual component in your device carry their own certification, you still have to certify the product as a whole. Poor PCB design can produce bad EMI. Maybe you're running SPI over a long wire or your traces are routed in a way that accidentally creates an antenna at your SPI clock frequency. Hell, even something as simple as toggling a GPIO pin once a second can emit high frequency EMI under the right conditions.
There are a lot of ways to unintentionally produce harmful EMI, and that's exactly why FCC certification is required for everything. This stuff is hard to get right and there are endless gotchas and exceptions and edge cases and you have to know about and account for all of them.
For instance, if your widget includes an ESP32 and a switching power supply, you are (notionally) guaranteed to never fail certification due to bad behavior from the ESP, but if you botch your power supply design and are spewing out noise in the KHz to MHz range, you still fail certification.
Even if every individual component in your device carry their own certification, you still have to certify the product as a whole. Poor PCB design can produce bad EMI. Maybe you're running SPI over a long wire or your traces are routed in a way that accidentally creates an antenna at your SPI clock frequency. Hell, even something as simple as toggling a GPIO pin once a second can emit high frequency EMI under the right conditions.
There are a lot of ways to unintentionally produce harmful EMI, and that's exactly why FCC certification is required for everything. This stuff is hard to get right and there are endless gotchas and exceptions and edge cases and you have to know about and account for all of them.
>This stuff is hard to get right and there are endless gotchas and exceptions and edge cases and you have to know about and account for all of them.
And this is also a major source of the cost of the testing. You're not just paying $5k+ for a piece of paper that says "FAIL" on it, and "better luck next time". The test engineers want you to pass, ultimately (if for no other reason than because you can't get repeat business from a customer who goes out of business), so they're going to point out the common sources of harmful EMI they've seen in other designs.
And this is also a major source of the cost of the testing. You're not just paying $5k+ for a piece of paper that says "FAIL" on it, and "better luck next time". The test engineers want you to pass, ultimately (if for no other reason than because you can't get repeat business from a customer who goes out of business), so they're going to point out the common sources of harmful EMI they've seen in other designs.
This makes sense. Thanks for ELI5.
Presumably EMI certification is easier than the FCC RF certification.
Presumably EMI certification is easier than the FCC RF certification.
[deleted]
Is there such a thing as low-cost testing and certification services operating overseas?
There are labs in China that will wink wink pass any product you send them for a flat fee.
The problem is that having passing test results from a random lab doesn’t help you if the FCC (or one of your competitors) discovers that your device is not actually compliant. So you have to be careful about what you’re getting.
The problem is that having passing test results from a random lab doesn’t help you if the FCC (or one of your competitors) discovers that your device is not actually compliant. So you have to be careful about what you’re getting.
Yes. The FCC has a list of accredited testing labs here: https://apps.fcc.gov/oetcf/eas/reports/TestFirmSearch.cfm
Many are in China and have reasonable prices.
That's a TERRIFIC idea and a great business model.
Actually, I'd use such a service myself.
> I don’t need to sell the development boards. I just have to tell my customers which boards to buy and how to set them up. This way, the electronic device liability will fall on the manufacturer, and the magic of ~friendship~ EULA should afford me enough protection to make this a pure software play.
Parasite of the economy, right there
Parasite of the economy, right there
I have rarely seen someone this happy to add friction that prevents his customers from buying his product.
Is it possible to couple compliance testing with an LLM? I smell a new business model.
This was a missed marketing opportunity to say what the product is.
Subscribe to the mailing list and you'll be the first one to find out! Seriously, though, HN is not my target market. I just needed a sounding board. Although, getting to the front page did grow the subscriber count from 7 to 48 people in 24 hours.
EEE here with 16 years experience and having to deal with compliance from day 1 of my career. I now consult on product compliance. Author you are welcome to contact me.
Disclaimer: Nothing below is meant as legally relevant compliance advice. This is just my opinion on the matter.
Going to snark:
"The testing and certification industry is odd"
Except, outside the software world, the real world, where there are real consequences, it's not really.
"The line about CES, in particular, made my hair stand up."
Why? Absolutely the unauthorised device at CES is should NOT be allowed. What if said device caused too much interference on cell phone frequencies and suddenly nobody at CES can dial the local emergency number?
If that made "your hair stand up", here's one from personal experience that will freeze your blood:
I worked as a teen for a certain electronics chain. Said chain was selling a wireless weather station imported from China. A government department that monitored the country for Earthquakes noticed that this device impinged on their frequencies. After the spectrum regulator confirmed the finding, a nice gentleman from them visited us a told us the following:
1) As of this moment this device can no longer be sold. Move it off the floor immediately (he stayed and made sure we did exactly that).
2) That we will immediately issue a recall of said device at your own cost and issue full refunds to the customers.
3) He will return when we decide on further enforcement action which may include punitive fines and recommendations for further remedial action you will need to undertake.
"In theory, it exists to serve the public good and uphold consumer protection laws."
Well here's a (very simplistic) tidbit for the author: In the US, part of the gestation and formation of standards bodies and testing was "market forces", not for the public good. It was to help protect companies from litigation. If you followed the standards, tested and certed to them, paid the fees etc you then had the standards entity bat for you in court (UL is short for Underwriters Laboratory. That name was not chosen for funsies).
"However, in reality, the labs are “too busy” to respond or reply very late and generally sound less than eager to work with you."
Well you don't sound like a serious customer. AND the Labs are not there to give you advice. They're there to do INDEPENDENT testing.
"Variations of the FCC exist in pretty much every developed economy. Putting a poorly tested hardware product on the market immediately puts a target on your back. Maybe you’ll get lucky, but chances are that someone somewhere will report you. And, unless you are operating entirely out of China, it will hurt. A lot. Both your company and maybe even you, personally."
As it should. The electromagnetic spectrum is a very precious and very limited commodity and IMO, the best regulated "commons" in human civilisation (though still not perfect). So no, you are not welcome to just urinate in it willy nilly with your hustler start up product.
"I did not want to spend so much money on testing before I validated the market or gathered a community of believers."
And there it is.
"This way, the electronic device liability will fall on the manufacturer, and the magic of friendship EULA should afford me enough protection to make this a pure software play."
No. That's not how this works.
1) I assume the author is from the US (as they speak about the FCC). I had a 30 second look at these dev boards and their instructions. There is no FCC conformity declarations or markings, so US customers can't use it.
2) It has CE and UKCA though, so customers from EU+UK (and some other countries) can buy them but the certs only cover the dev boards AS SOLD. (i.e without the authors software)
3) Author is modifying the product behavior with their software. So yes author. You are still liable. Technically, your customers are first in the line of fire. But the likely sequence of steps is: Friendly Spectrum Representative will visit them first, have a chat, ask them to stop using the device, then leave them a lone and then come for YOU.
4) What the author has actually done is "buy down" their risk. It is simply less likely that the product will become non-compliant when their software is loaded. But it is still possible. At second glance, those dev boards don't come with a power supply. What is your recommended power supply to use Author? Have you tested your setup with said power supply and have test reports at the ready for when Friendly Spectrum Person comes knocking?
5) Sure it seems clever but Friendly Spectrum Agencies actually have quite far reaching and scary powers. Don't think that your little sleight of hand here is clever and protects you. Fundamentally: You are repackaging + modifying an existing product. The steps you are taking in between to "launder" your liability are irrelevant.
Frankly, it's shit like this, that makes it harder for everyone else playing by the rules. It did actually used to be easier. There used to be exemptions for "low volume" products. But all of those were seen as loopholes and HEAVILY abused. Now these toys have been taken away, with more to follow.
Disclaimer: Nothing below is meant as legally relevant compliance advice. This is just my opinion on the matter.
Going to snark:
"The testing and certification industry is odd"
Except, outside the software world, the real world, where there are real consequences, it's not really.
"The line about CES, in particular, made my hair stand up."
Why? Absolutely the unauthorised device at CES is should NOT be allowed. What if said device caused too much interference on cell phone frequencies and suddenly nobody at CES can dial the local emergency number?
If that made "your hair stand up", here's one from personal experience that will freeze your blood:
I worked as a teen for a certain electronics chain. Said chain was selling a wireless weather station imported from China. A government department that monitored the country for Earthquakes noticed that this device impinged on their frequencies. After the spectrum regulator confirmed the finding, a nice gentleman from them visited us a told us the following:
1) As of this moment this device can no longer be sold. Move it off the floor immediately (he stayed and made sure we did exactly that).
2) That we will immediately issue a recall of said device at your own cost and issue full refunds to the customers.
3) He will return when we decide on further enforcement action which may include punitive fines and recommendations for further remedial action you will need to undertake.
"In theory, it exists to serve the public good and uphold consumer protection laws."
Well here's a (very simplistic) tidbit for the author: In the US, part of the gestation and formation of standards bodies and testing was "market forces", not for the public good. It was to help protect companies from litigation. If you followed the standards, tested and certed to them, paid the fees etc you then had the standards entity bat for you in court (UL is short for Underwriters Laboratory. That name was not chosen for funsies).
"However, in reality, the labs are “too busy” to respond or reply very late and generally sound less than eager to work with you."
Well you don't sound like a serious customer. AND the Labs are not there to give you advice. They're there to do INDEPENDENT testing.
"Variations of the FCC exist in pretty much every developed economy. Putting a poorly tested hardware product on the market immediately puts a target on your back. Maybe you’ll get lucky, but chances are that someone somewhere will report you. And, unless you are operating entirely out of China, it will hurt. A lot. Both your company and maybe even you, personally."
As it should. The electromagnetic spectrum is a very precious and very limited commodity and IMO, the best regulated "commons" in human civilisation (though still not perfect). So no, you are not welcome to just urinate in it willy nilly with your hustler start up product.
"I did not want to spend so much money on testing before I validated the market or gathered a community of believers."
And there it is.
"This way, the electronic device liability will fall on the manufacturer, and the magic of friendship EULA should afford me enough protection to make this a pure software play."
No. That's not how this works.
1) I assume the author is from the US (as they speak about the FCC). I had a 30 second look at these dev boards and their instructions. There is no FCC conformity declarations or markings, so US customers can't use it.
2) It has CE and UKCA though, so customers from EU+UK (and some other countries) can buy them but the certs only cover the dev boards AS SOLD. (i.e without the authors software)
3) Author is modifying the product behavior with their software. So yes author. You are still liable. Technically, your customers are first in the line of fire. But the likely sequence of steps is: Friendly Spectrum Representative will visit them first, have a chat, ask them to stop using the device, then leave them a lone and then come for YOU.
4) What the author has actually done is "buy down" their risk. It is simply less likely that the product will become non-compliant when their software is loaded. But it is still possible. At second glance, those dev boards don't come with a power supply. What is your recommended power supply to use Author? Have you tested your setup with said power supply and have test reports at the ready for when Friendly Spectrum Person comes knocking?
5) Sure it seems clever but Friendly Spectrum Agencies actually have quite far reaching and scary powers. Don't think that your little sleight of hand here is clever and protects you. Fundamentally: You are repackaging + modifying an existing product. The steps you are taking in between to "launder" your liability are irrelevant.
Frankly, it's shit like this, that makes it harder for everyone else playing by the rules. It did actually used to be easier. There used to be exemptions for "low volume" products. But all of those were seen as loopholes and HEAVILY abused. Now these toys have been taken away, with more to follow.
>> 3) Author is modifying the product behavior with their software. So yes author. You are still liable. Technically, your customers are first in the line of fire. But the likely sequence of steps is: Friendly Spectrum Representative will visit them first, have a chat, ask them to stop using the device, then leave them a lone and then come for YOU.
Few questions related to this. - Does this meant that recertification is required every time we load a different version of the software ? - How does this work for Computers and mobile phones ? The hardware is certified but you are loading different software daily.
Few questions related to this. - Does this meant that recertification is required every time we load a different version of the software ? - How does this work for Computers and mobile phones ? The hardware is certified but you are loading different software daily.
It's complicated!
If it's not a transmitter, then it's not certified (this has a meaning), you just need to have acceptable data on hand for your Supplier's Declaration of Conformity (SDoC). Then if you make any changes to your product after test, it is a judgement call whether you need to retest. Ultimately you are responsible for compliance, so this is not a free pass. In principle your computer or cell phone manufacturer could get fined if it is possible to operate their device with new user software in a way that emits RF above allowable levels.
If it is a transmitter and you-the-manufacturer make changes to software that operates the transmitter, the FCC has specific rules. Look at the KDBs for permissive changes and for Software Defined Radio Applications. Note that the FCC has a somewhat unique idea of what constitutes an SDR. Some software changes to radio firmware will require recertification but some just will require a permissive change. Some permissive changes are handled in a way similar to SDoCs, where you just get yourself a report with acceptable data, some require filing that data with the FCC.
If it's not a transmitter, then it's not certified (this has a meaning), you just need to have acceptable data on hand for your Supplier's Declaration of Conformity (SDoC). Then if you make any changes to your product after test, it is a judgement call whether you need to retest. Ultimately you are responsible for compliance, so this is not a free pass. In principle your computer or cell phone manufacturer could get fined if it is possible to operate their device with new user software in a way that emits RF above allowable levels.
If it is a transmitter and you-the-manufacturer make changes to software that operates the transmitter, the FCC has specific rules. Look at the KDBs for permissive changes and for Software Defined Radio Applications. Note that the FCC has a somewhat unique idea of what constitutes an SDR. Some software changes to radio firmware will require recertification but some just will require a permissive change. Some permissive changes are handled in a way similar to SDoCs, where you just get yourself a report with acceptable data, some require filing that data with the FCC.
The "software" in these cases is localized to the drivers/firmware. This is why you basically can't get a RF peripheral for Linux with truly open firmware and they all use binary blobs: to prevent you modifying it.
In the purest theoretical sense yes, in practice no. So that you don't have to recert everytime, you
1) test and exercise your product to extremes so that you can say with high certainty that: no matter what the customer loads, it won't breach the rules.
2) As pjc50 mentioned: Lock down the parts which the user could potentially cause the most damage with. i.e lock down that radio firmware (why is why none of it is open source).
If you do (1) and (2) and a few other things, you buy down your risk sufficiently that you can confidently demonstrate that re-certs are not needed.
The Author of the parent article IMO is doing the exact opposite.
There are also half-way houses: Just doing "pre-compliance testing". So not a formal cert, your just doing a quick test in an anaechoic chamber or even on a table top scanner. Of course this only applies to things you can self-certify. Some things, like radios (WiFi, Bluetooth etc.), you cannot self-certify. That's why almost everyone buys the radio as a module (To buy down their risk). By consequence: That's why those radio module manufacturers have the firmware locked down hard and engineer and cert the radios to have big margins.
There are a lot of rules yes, but there is actually a lot of flexibility and common sense in the system too (but it is still imperfect, absolutely). But that flexibility does not allow for horsing around. If you can demonstrate to Friendly Spectrum Agency all this due diligence, you are going to have a MUCH better time.
1) test and exercise your product to extremes so that you can say with high certainty that: no matter what the customer loads, it won't breach the rules.
2) As pjc50 mentioned: Lock down the parts which the user could potentially cause the most damage with. i.e lock down that radio firmware (why is why none of it is open source).
If you do (1) and (2) and a few other things, you buy down your risk sufficiently that you can confidently demonstrate that re-certs are not needed.
The Author of the parent article IMO is doing the exact opposite.
There are also half-way houses: Just doing "pre-compliance testing". So not a formal cert, your just doing a quick test in an anaechoic chamber or even on a table top scanner. Of course this only applies to things you can self-certify. Some things, like radios (WiFi, Bluetooth etc.), you cannot self-certify. That's why almost everyone buys the radio as a module (To buy down their risk). By consequence: That's why those radio module manufacturers have the firmware locked down hard and engineer and cert the radios to have big margins.
There are a lot of rules yes, but there is actually a lot of flexibility and common sense in the system too (but it is still imperfect, absolutely). But that flexibility does not allow for horsing around. If you can demonstrate to Friendly Spectrum Agency all this due diligence, you are going to have a MUCH better time.
"Author is modifying the product behavior with their software."
I would say that the end user is modifying the behavior of the hardware, that they own and are fully in control of, by choosing to run software that they purchased. But I'm fully aware that regulatory agencies probably have their own way of thinking about that.
Point taken about how we need some regulations, but isn't everyone sitting in an MBA program right now being trained to identify this exact kind of workaround?
As for displaying a device that isn't certified yet, who's the victim? What's wrong with saying "We can't take orders on this yet, but we're working on getting cool new product certified as fast as possible"? The article said displaying a device, not turning it on.
From your post, it seems like you're painting this guy as a malicious bad actor who going to destroy society when, to me, he seems like someone who's trying to find an efficient way to sell a solution to people who might find it valuable.
I would say that the end user is modifying the behavior of the hardware, that they own and are fully in control of, by choosing to run software that they purchased. But I'm fully aware that regulatory agencies probably have their own way of thinking about that.
Point taken about how we need some regulations, but isn't everyone sitting in an MBA program right now being trained to identify this exact kind of workaround?
As for displaying a device that isn't certified yet, who's the victim? What's wrong with saying "We can't take orders on this yet, but we're working on getting cool new product certified as fast as possible"? The article said displaying a device, not turning it on.
From your post, it seems like you're painting this guy as a malicious bad actor who going to destroy society when, to me, he seems like someone who's trying to find an efficient way to sell a solution to people who might find it valuable.
> we need some regulations, but isn't everyone sitting in an MBA program right now being trained to identify this exact kind of workaround?
Just because there are some bad actors out there, it does not mean that you should behave the same way.
Just because there are some bad actors out there, it does not mean that you should behave the same way.
Absolutely amazing response. I love it when a real engineer comes and explains the real world to software "engineers".
I think that both sides (SW and HW) can learn to coexist better, and tbh, there is really a necessity for them to.
The reality is that the reason software is currently the top industry/value creator when it comes to revenue is an artifact of an open ecosystem where the barriers to entry are low, and where there is space for many to experiment.
Traditionally, the engineering world doesn't see things the same way. Part of this is culture, and that's hard to change - engineers see what they do as an art, and this is fine,and it's a good thing as some engineering systems do have a disproportionate impact, but I think the tone of the response also does reflect an attitude of perfectionism and "this at any cost" that I think holds the field back.
I think the solution is not rather to "just let people run amok" (though as it happens, this is the strategy China is testing for us and it appears to not have broken too much yet - the land of trillions of SOIC-8 Bluetooth MCUs with no shielding and a 5-line BOM) but rather for the engineering world to embrace the software developers and provide a happy path to compliance.
If you want North America to compete with China on having ubiquitous technologies everywhere (this is the only way to build out the supply chain), we have to come up with a way to fix certification and part of the attitude has to be "we're going to teach you how to cheaply get your product to market in a way that respects the spectrum", and not "it's expensive, deal with it". This one is tough for people to accept but we cannot ever go back to stuff being expensive, as the floodgates have already been opened.
This is something that the government has to do, probably - provide funding to run (at least, cut down versions of the labs for precompliance) cheaply, put out good resources. Encourage or fund the creation of low-cost and easy to understand paths to compliance. As anyone knows, if you try to hold your nose to stop a nosebleed, the blood just goes down your throat. Same with all of the stuff from China. If you want to meaningfully improve device compliance, making the process hard and painful will just increase the number of random Amazon/Temu Bluetooth nonsense with a total lack of attention to design at all. If we made the process more accessible, it's possible that this would drive the industry to create solutions that might not even cost more, but are more compliant - which would be a win overall.
The reality is that the reason software is currently the top industry/value creator when it comes to revenue is an artifact of an open ecosystem where the barriers to entry are low, and where there is space for many to experiment.
Traditionally, the engineering world doesn't see things the same way. Part of this is culture, and that's hard to change - engineers see what they do as an art, and this is fine,and it's a good thing as some engineering systems do have a disproportionate impact, but I think the tone of the response also does reflect an attitude of perfectionism and "this at any cost" that I think holds the field back.
I think the solution is not rather to "just let people run amok" (though as it happens, this is the strategy China is testing for us and it appears to not have broken too much yet - the land of trillions of SOIC-8 Bluetooth MCUs with no shielding and a 5-line BOM) but rather for the engineering world to embrace the software developers and provide a happy path to compliance.
If you want North America to compete with China on having ubiquitous technologies everywhere (this is the only way to build out the supply chain), we have to come up with a way to fix certification and part of the attitude has to be "we're going to teach you how to cheaply get your product to market in a way that respects the spectrum", and not "it's expensive, deal with it". This one is tough for people to accept but we cannot ever go back to stuff being expensive, as the floodgates have already been opened.
This is something that the government has to do, probably - provide funding to run (at least, cut down versions of the labs for precompliance) cheaply, put out good resources. Encourage or fund the creation of low-cost and easy to understand paths to compliance. As anyone knows, if you try to hold your nose to stop a nosebleed, the blood just goes down your throat. Same with all of the stuff from China. If you want to meaningfully improve device compliance, making the process hard and painful will just increase the number of random Amazon/Temu Bluetooth nonsense with a total lack of attention to design at all. If we made the process more accessible, it's possible that this would drive the industry to create solutions that might not even cost more, but are more compliant - which would be a win overall.
EMC compliance rules are needed so that all our electronic devices (running software mind you) can continue to function. Part of the rules are about squeezing as much "performance" as possible out of the "thing" that is the electromagnetic spectrum. It's simple physics.
The other part of the rules are for human safety. Devices can directly hurt people (like a microwave) or indirectly (like a crappy device that prevented ambulance phone calls going through).
It's as simple as that (and not perfectionism or being mean to the poor software people).
""we're going to teach you how to cheaply get your product to market in a way that respects the spectrum" I'm available to do exactly that for you at my hourly rate :D
The other part of the rules are for human safety. Devices can directly hurt people (like a microwave) or indirectly (like a crappy device that prevented ambulance phone calls going through).
It's as simple as that (and not perfectionism or being mean to the poor software people).
""we're going to teach you how to cheaply get your product to market in a way that respects the spectrum" I'm available to do exactly that for you at my hourly rate :D
hard agree, it sucks immensely that I can design a cool 4 layer PCB with multicore processor in an afternoon, throw on a standard bluetooth module, and have it manufactured and shipped to me in a week for like $100, but heaven forbid I want to sell five of them to fellow nerds on a niche forum without breaking multiple laws, and the path to compliance is, uh, find a consultant with EMI testing experience and industry connections and/or spend $5000?
and then amazon is full of absolutely noncompliant untested stuff with no consequences
and then amazon is full of absolutely noncompliant untested stuff with no consequences
Don't forget having to spend $X000 for the privilege of being allowed to read the standards you're required to follow, and needing a consultant to tell you which standards you have to follow in the first place.
Hard agree that pricing for standards is generally insane. IMO if the law requires it, it should be free + maybe a $10 admin. Anything else is BS. Standards bodies already make a killing off their membership fees. There are alternatives and workarounds though, here is one: https://news.ycombinator.com/item?id=36452660
If you don't want to hire a consultant then don't. You can do it yourself. Go get a EEE degree and then spend 5-15 years working as a EEE in product development and certification. Then you'll be good to go :)
Or just blind self certify and pay the lawyers, Friendly Spectrum Agency and other spectrum users (like cell phone companies) when they come knocking and asking for damages from you.
Here is a free primer I replied with earlier today: https://news.ycombinator.com/item?id=40926870
If you don't want to hire a consultant then don't. You can do it yourself. Go get a EEE degree and then spend 5-15 years working as a EEE in product development and certification. Then you'll be good to go :)
Or just blind self certify and pay the lawyers, Friendly Spectrum Agency and other spectrum users (like cell phone companies) when they come knocking and asking for damages from you.
Here is a free primer I replied with earlier today: https://news.ycombinator.com/item?id=40926870
Amazon absolutely requires sellers to supply FCC certification and Suppliers' Declaration of Conformity documentation for FCC regulated devices. You can report any noncompliant products to them and they do remove them.
Just wait till you learn about say, product liability, CPSC regulations, "voluntary" safety standards, and so on
Just wait till you learn about say, product liability, CPSC regulations, "voluntary" safety standards, and so on
> The reality is that the reason software is currently the top industry/value creator when it comes to revenue is an artifact of an open ecosystem where the barriers to entry are low, and where there is space for many to experiment.
The reason software has more pay is because it scales really well. You write software once and then sell it, and your costs per copy is low. That means if you write software that increases productivity 20% that can sell for $$$$$$ while your costs are essentially fixed.
The reason software has more pay is because it scales really well. You write software once and then sell it, and your costs per copy is low. That means if you write software that increases productivity 20% that can sell for $$$$$$ while your costs are essentially fixed.
>"Author is modifying the product behavior with their software."
If this were a real concern, then every programmer everywhere would need FCC certification for any program they ever write. But that isn't the case so far as I know.
If this were a real concern, then every programmer everywhere would need FCC certification for any program they ever write. But that isn't the case so far as I know.
See my response to a similar question here: https://news.ycombinator.com/item?id=40926103
Thank you for this. It's possible that you've saved me and others a lot of pain by heading off ignorant mistakes.
I'm currently building a product that makes use of an ESP32 module with a built-in antenna. I've been operating under the naive assumption that since the modules are certified, the product I build with the module is certified (perhaps pending an EMF certification or something equally trivial). You've certainly put this issue on my radar.
That said, while I actually enjoyed the snark in your reply, there are those of us who actually do want to get this right and do the right thing, despite lacking years of experience and an infinite budget.
If you have any go-to resources to share that might qualify as accessible and perhaps written to an indie maker audience, I'll diligently consume anything you recommend.
I'm currently building a product that makes use of an ESP32 module with a built-in antenna. I've been operating under the naive assumption that since the modules are certified, the product I build with the module is certified (perhaps pending an EMF certification or something equally trivial). You've certainly put this issue on my radar.
That said, while I actually enjoyed the snark in your reply, there are those of us who actually do want to get this right and do the right thing, despite lacking years of experience and an infinite budget.
If you have any go-to resources to share that might qualify as accessible and perhaps written to an indie maker audience, I'll diligently consume anything you recommend.
The go-to resources are the FCC regulations and guidance documents. Be very careful with anything written to an indie maker audience. FCC regulations have the force of law and you are ultimately responsible for compliance: not the guy you read on the internet, not even your test laboratory.
https://www.fcc.gov/oet/ea/rfdevice https://www.fcc.gov/general/equipment-authorization-procedur... https://apps.fcc.gov/eas/comments/GetPublishedDocument.html?...
There are a number of things you could conceivably be doing that would complicate your compliance situation beyond simply using the module's certification, getting test data from a certified lab for unintentional radiation for the Supplier's Declaration of Conformance procedure, appropriate labeling, and so on. (You're right that's a reasonable assumption about your situation but it may not always be true). They include but are not limited to, say, using more than one pre-certified transmitter in your device.
https://www.fcc.gov/oet/ea/rfdevice https://www.fcc.gov/general/equipment-authorization-procedur... https://apps.fcc.gov/eas/comments/GetPublishedDocument.html?...
There are a number of things you could conceivably be doing that would complicate your compliance situation beyond simply using the module's certification, getting test data from a certified lab for unintentional radiation for the Supplier's Declaration of Conformance procedure, appropriate labeling, and so on. (You're right that's a reasonable assumption about your situation but it may not always be true). They include but are not limited to, say, using more than one pre-certified transmitter in your device.
The certification testers will give a definitive answer, but most manufacturers will pre-test their products before sending them out for testing to improve the chances of passing the first time. You can rent some of the testing tools if necessary.
This might be helpful to learn more: https://compliancetesting.com/how-to-measure-emi-electromagn...
This might be helpful to learn more: https://compliancetesting.com/how-to-measure-emi-electromagn...
No problems. You are very welcome :)
It sounds like you are actually doing some things right :) FCC, for example, have scope for "modular approval". Order a radio module (with modular approval), do exactly as the datasheet tells you and you can "piggy back" off the radio modules radio certs. But you will still need to test and cert for things like your own "unintentional emissions", maybe ESD and other things (NOT actual compliance advice btw, this is just to give a rough picture).
"That said, while I actually enjoyed the snark in your reply, there are those of us who actually do want to get this right and do the right thing, despite lacking years of experience and an infinite budget."
Oh I absolutely know you people are out there :) (I've consulted for them. I've also consulted for the ones who are learning the hard way...)
I don't intend to be mean with posts like this on HN, but some reality on these posts is just needed IMO. Especially given how much software dominates product development these days and people just don't know.
I think it's difficult for new comers, but I don't know how you fix that other than asking a consultant. The earlier the better. You can certainly make early feature and design choices to make your certs simpler (and cheaper) down the road.
That said, I think a good place to start for anyone is the following:
1) Find a product that is broadly similar to yours. Is it like a small computer? Is it a wired network device like a router? Maybe it's like a bluetooth dongle or smartwatch? Find one from a large reputable company and search said company's website for their "EU Declaration of Conformity". On these docs (even though it is not required) many companies list the standards that the device is compliant with. They have names like: EN 55022, EN 60950, IEC 61000-3-3.
NOTE - This is for EU only, but they have massive regulatory reach. Also many FCC and EU standards are very similar or even the same. Over time they have been converging more and more.
2) Do this for a few different devices of the same or similar category and you will notice many which are always there and some that are sometimes there. Now you have a starting template of standards that you might need.
3) With this starting template, you can now look up the standards names and often download the first few pages free to get an idea for what they are for.
4) Get a quote from a lab. They often do a lot of testing for product importers (as onus is also on said importers), so they can have "non-engineer friendly" forms that you can fill in. This will give you a price but also some information on what they think you need (they have to be careful though because they have to maintain their independence). Tell them you want CE (Europe) and FCC (North America). This covers much of the world for you. Many countries, even those with their own standards, also simply accept CE and FCC (again this is all in very very broad strokes). Many standards are also just copy and pasted between different regulatory domains but they change the name. So the original standards body will have their name for it. When the EU recognises it, it'll get an "EN" number for it's name (for example).
4b) Consider a hiring consultant for a short chat to "downsize" the standards you need and maybe they can point out any you might be missing. Good ones can also advise you on things you can do to avoid standards (and this is not in an illegal way). If you understand the rules well, you can sometimes make small changes and avoid whole sets of rules and testing (classic one IMO is a radio device. In VERY GENERAL TERMS, if it's going to be used more than 40cm from a human, then you don't need to test for human absorption of RF energy. My Chromecast, for example, has a disclaimer on it so that they can claim exactly this (IMO of course) ). How to find a good consultant? Well that's hard and I don't have a sure fire way sorry. Some labs have business cards of small local consultants.
5) Source copies of the standards and read them (Yes it'll likely be heavy reading). Most standards sellers (including the national ones) are crooks. Don't use them. Instead go to the Estonian Centre for Standardisation and Accreditation: https://www.evs.ee/en . They are the cheapest source I know of for standards in English (and only English matters). Further details in an old comment of mine here: https://news.ycombinator.com/item?id=36452660
These above steps are the same steps that I myself use.
Sources to read ... sadly I've not found many good ones. I think the best one that I would recommend is https://incompliancemag.com/ It's dry and does what it says on the tin. But their archives have some great articles by experts. They cover new standards, certing particular devices, testing technology etc. Even the ads can be kind of informative I think. It's good for learning the general layout of the field. Not a shallow learning curve but not steep either IMO (It's also free in digital form).
It sounds like you are actually doing some things right :) FCC, for example, have scope for "modular approval". Order a radio module (with modular approval), do exactly as the datasheet tells you and you can "piggy back" off the radio modules radio certs. But you will still need to test and cert for things like your own "unintentional emissions", maybe ESD and other things (NOT actual compliance advice btw, this is just to give a rough picture).
"That said, while I actually enjoyed the snark in your reply, there are those of us who actually do want to get this right and do the right thing, despite lacking years of experience and an infinite budget."
Oh I absolutely know you people are out there :) (I've consulted for them. I've also consulted for the ones who are learning the hard way...)
I don't intend to be mean with posts like this on HN, but some reality on these posts is just needed IMO. Especially given how much software dominates product development these days and people just don't know.
I think it's difficult for new comers, but I don't know how you fix that other than asking a consultant. The earlier the better. You can certainly make early feature and design choices to make your certs simpler (and cheaper) down the road.
That said, I think a good place to start for anyone is the following:
1) Find a product that is broadly similar to yours. Is it like a small computer? Is it a wired network device like a router? Maybe it's like a bluetooth dongle or smartwatch? Find one from a large reputable company and search said company's website for their "EU Declaration of Conformity". On these docs (even though it is not required) many companies list the standards that the device is compliant with. They have names like: EN 55022, EN 60950, IEC 61000-3-3.
NOTE - This is for EU only, but they have massive regulatory reach. Also many FCC and EU standards are very similar or even the same. Over time they have been converging more and more.
2) Do this for a few different devices of the same or similar category and you will notice many which are always there and some that are sometimes there. Now you have a starting template of standards that you might need.
3) With this starting template, you can now look up the standards names and often download the first few pages free to get an idea for what they are for.
4) Get a quote from a lab. They often do a lot of testing for product importers (as onus is also on said importers), so they can have "non-engineer friendly" forms that you can fill in. This will give you a price but also some information on what they think you need (they have to be careful though because they have to maintain their independence). Tell them you want CE (Europe) and FCC (North America). This covers much of the world for you. Many countries, even those with their own standards, also simply accept CE and FCC (again this is all in very very broad strokes). Many standards are also just copy and pasted between different regulatory domains but they change the name. So the original standards body will have their name for it. When the EU recognises it, it'll get an "EN" number for it's name (for example).
4b) Consider a hiring consultant for a short chat to "downsize" the standards you need and maybe they can point out any you might be missing. Good ones can also advise you on things you can do to avoid standards (and this is not in an illegal way). If you understand the rules well, you can sometimes make small changes and avoid whole sets of rules and testing (classic one IMO is a radio device. In VERY GENERAL TERMS, if it's going to be used more than 40cm from a human, then you don't need to test for human absorption of RF energy. My Chromecast, for example, has a disclaimer on it so that they can claim exactly this (IMO of course) ). How to find a good consultant? Well that's hard and I don't have a sure fire way sorry. Some labs have business cards of small local consultants.
5) Source copies of the standards and read them (Yes it'll likely be heavy reading). Most standards sellers (including the national ones) are crooks. Don't use them. Instead go to the Estonian Centre for Standardisation and Accreditation: https://www.evs.ee/en . They are the cheapest source I know of for standards in English (and only English matters). Further details in an old comment of mine here: https://news.ycombinator.com/item?id=36452660
These above steps are the same steps that I myself use.
Sources to read ... sadly I've not found many good ones. I think the best one that I would recommend is https://incompliancemag.com/ It's dry and does what it says on the tin. But their archives have some great articles by experts. They cover new standards, certing particular devices, testing technology etc. Even the ads can be kind of informative I think. It's good for learning the general layout of the field. Not a shallow learning curve but not steep either IMO (It's also free in digital form).
This is all good information. I'd only add:
You left out Canada. IC certs are kind of a pain because some of their rules are very slightly different plus you need a representative in Canada.
UL standards can be read (but not downloaded) for free on UL's standard store. These don't include IEC standards adopted by UL, but do include national differences for those standards for the US.
The specific procedures your test lab will use in the US for typical part 15 devices include procedures covered by ANSI C63.4 (unintentional radiators) and C63.10 (intentional radiators). These you can't get from the Estonians. You probably won't need them but they can be helpful if you get serious about pre-compliance testing or if you are puzzled by what the lab is doing. IEC CISPR standards overlap here. There is a list of measurement procedures on the FCC web site: https://www.fcc.gov/general/equipment-authorization-measurem...
You should have an engineer or "directly responsible individual" on site at the test lab during testing for all kinds of reasons, from building capability and understanding of the process to having someone there to clear up any misunderstandings. If you have a consultant do this for you, you or someone from your company should be there also.
For transmitters (intentional radiators) you can look up test reports and submittal information for competing products on the FCC's web site. That's one way to get an idea of what your test requirements and setups will look like. For unintentional radiators, you can find some test reports with a web search - companies are not required to make these public.
You left out Canada. IC certs are kind of a pain because some of their rules are very slightly different plus you need a representative in Canada.
UL standards can be read (but not downloaded) for free on UL's standard store. These don't include IEC standards adopted by UL, but do include national differences for those standards for the US.
The specific procedures your test lab will use in the US for typical part 15 devices include procedures covered by ANSI C63.4 (unintentional radiators) and C63.10 (intentional radiators). These you can't get from the Estonians. You probably won't need them but they can be helpful if you get serious about pre-compliance testing or if you are puzzled by what the lab is doing. IEC CISPR standards overlap here. There is a list of measurement procedures on the FCC web site: https://www.fcc.gov/general/equipment-authorization-measurem...
You should have an engineer or "directly responsible individual" on site at the test lab during testing for all kinds of reasons, from building capability and understanding of the process to having someone there to clear up any misunderstandings. If you have a consultant do this for you, you or someone from your company should be there also.
For transmitters (intentional radiators) you can look up test reports and submittal information for competing products on the FCC's web site. That's one way to get an idea of what your test requirements and setups will look like. For unintentional radiators, you can find some test reports with a web search - companies are not required to make these public.
Excellent additions.
Sadly for Canada, some companies I worked with didn't bother because of these differences. "US market is big enough for launching. Maybe we'll come back to Canada later." They rarely did.
In practice the guy was planning to sell piece of software, on an SD card, that is compatible with a piece of hardware, and it's up to the customer to actually combine those two. The plan is exactly not to sell the hardware at all—granted they SD cards are piece of hardware, but what if that too was just an image to download off a site?
If the customer cannot legally use that SD with their boards, which SD can they use?
Is this not exactly equivalent how I might buy a Raspberry Pi and install a non-Raspberry-authorized OS on it? Or equivalent on how I might buy a PC and install Linux on it? Or Android and LineageOS? Are those devices certified not only as SOLD but also as modified by the end-user with software, making them somehow different?
If the customer cannot legally use that SD with their boards, which SD can they use?
Is this not exactly equivalent how I might buy a Raspberry Pi and install a non-Raspberry-authorized OS on it? Or equivalent on how I might buy a PC and install Linux on it? Or Android and LineageOS? Are those devices certified not only as SOLD but also as modified by the end-user with software, making them somehow different?
That was not my read on it. My interpretation was that they wanted to sell a product, but didn't want to pay for an engineer who understands all this, labs for testing and doing all the paper work that it entails. So the plan became: "Customer buy this software, buy that hardware and put it together" => not liable => profit.
"Is this not exactly equivalent how I might buy a Raspberry Pi and install a non-Raspberry-authorized OS on it? Or equivalent on how I might buy a PC and install Linux on it? Or Android and LineageOS? Are those devices certified not only as SOLD but also as modified by the end-user with software, making them somehow different?"
Yes and no :) Very very succinctly: When you test and cert, it is best practice to create the worst case scenario for your product and pass like with healthy margins. Especially for something like a smartphone or PC, when it's in the test chamber (for something like radiated emissions), you run it at "full noise" (even if it's not a realistic use case). So all your clocks: maximum (don't use all of the clocks? Turn them all on anyway); Power draw: Maximum or more; Play seizure inducing video to exercise that screen; Connect peripherals that are likely to be used to make sure those don't screw you etc. PCs and phones, especially, are tested at these extremes so that the manufacturer can be confident that despite what software the end-user loads, the device will remain compliant (this is also why the radio firmware is kept locked down hard).
Now in the case of this article, sure, the dev boards have CE, but what does that mean? How did they test it? Where all the peripherals running? What did the physical test setup look like? Under CE they are required to keep a compliance folder and to provide the information on request.
My experience with, dev boards that are "compliant". They just powered it up and maybe ran a simple program. Low effort, low noise, easy pass, because the reality is that they don't need it and time is money.
So now you a third party integrator takes that dev board, and runs something that wasn't exercised or puts it into a state that is non compliant. That's on you. Just like it's on the Author of this article.
I might be wrong in this case. Maybe the dev boards have excellent test setups. I might look at the test docs and think: "oh we should be fine". And just do a pre-compliance test and self-certify. You have to evaluate the risk each time and make a call.
If Microsoft released a patch tomorrow that somehow caused a sizable percentage of PCs to start stepping on the cell phone bands they would VERY quickly be told (I emphasise told NOT asked) to fix it. Just like any software this Author could load. They have not sidestepped any responsibility.
"Is this not exactly equivalent how I might buy a Raspberry Pi and install a non-Raspberry-authorized OS on it? Or equivalent on how I might buy a PC and install Linux on it? Or Android and LineageOS? Are those devices certified not only as SOLD but also as modified by the end-user with software, making them somehow different?"
Yes and no :) Very very succinctly: When you test and cert, it is best practice to create the worst case scenario for your product and pass like with healthy margins. Especially for something like a smartphone or PC, when it's in the test chamber (for something like radiated emissions), you run it at "full noise" (even if it's not a realistic use case). So all your clocks: maximum (don't use all of the clocks? Turn them all on anyway); Power draw: Maximum or more; Play seizure inducing video to exercise that screen; Connect peripherals that are likely to be used to make sure those don't screw you etc. PCs and phones, especially, are tested at these extremes so that the manufacturer can be confident that despite what software the end-user loads, the device will remain compliant (this is also why the radio firmware is kept locked down hard).
Now in the case of this article, sure, the dev boards have CE, but what does that mean? How did they test it? Where all the peripherals running? What did the physical test setup look like? Under CE they are required to keep a compliance folder and to provide the information on request.
My experience with, dev boards that are "compliant". They just powered it up and maybe ran a simple program. Low effort, low noise, easy pass, because the reality is that they don't need it and time is money.
So now you a third party integrator takes that dev board, and runs something that wasn't exercised or puts it into a state that is non compliant. That's on you. Just like it's on the Author of this article.
I might be wrong in this case. Maybe the dev boards have excellent test setups. I might look at the test docs and think: "oh we should be fine". And just do a pre-compliance test and self-certify. You have to evaluate the risk each time and make a call.
If Microsoft released a patch tomorrow that somehow caused a sizable percentage of PCs to start stepping on the cell phone bands they would VERY quickly be told (I emphasise told NOT asked) to fix it. Just like any software this Author could load. They have not sidestepped any responsibility.
That bit about PCs and phones was surprising, but I guess not unexpected. I have built many "EMI test versions" of code so various products can be taken to the test house. We don't go to those extremes: typically, we'll run as close to worst case as we can get, but nothing unrealistic. Then again, no one but us is loading code onto our devices, so it's not like a PC where you have no control over what it's running.
One company I have worked with had an internal rule for "radiated emissions": You had to be 10dB (1 order of magnitude) underneath the limits before going for a formal cert. Non-negotiable.
Part of the reason for this rule was that they:
1) OEMed their products.
2) Sold products that could be used in complex and bespoke CAN networks with goodness knows what else.
3) There was a chance of interfering with Marine VHF radio which is used for emergencies. The EU rules were (still are) not actually strict enough for preventing interference with that band.
Part of the reason for this rule was that they:
1) OEMed their products.
2) Sold products that could be used in complex and bespoke CAN networks with goodness knows what else.
3) There was a chance of interfering with Marine VHF radio which is used for emergencies. The EU rules were (still are) not actually strict enough for preventing interference with that band.
I was actually under the impression that PC motherboards have the spread spectrum clock available exactly for compliance reasons, and indeed it's the default as well. But you can turn it off.
Maybe they do indeed test without it, and it's only for the benefit of integrators to make use of (and perhaps disable other options altogether), if they find their complete system emissions somehow exceed limits.
Now that I'm in position to ask ;), I've wondered about the glass/plastic window PC cases.. Surely a PC case itself would not be required to have any emission tests done on it, or would it? On the other hand, might the PC motherboard emissions be certified with the assumption that it will be placed inside a case?
And then finally comes a consumer (or even a small integrator) and sticks in a PC motherboard inside a windowed case—but in this case the case might not be doing much on the RF side. Or maybe the cases provide better RF protection than they look like or the MBs don't need a case for that reason in the first place :).
Maybe they do indeed test without it, and it's only for the benefit of integrators to make use of (and perhaps disable other options altogether), if they find their complete system emissions somehow exceed limits.
Now that I'm in position to ask ;), I've wondered about the glass/plastic window PC cases.. Surely a PC case itself would not be required to have any emission tests done on it, or would it? On the other hand, might the PC motherboard emissions be certified with the assumption that it will be placed inside a case?
And then finally comes a consumer (or even a small integrator) and sticks in a PC motherboard inside a windowed case—but in this case the case might not be doing much on the RF side. Or maybe the cases provide better RF protection than they look like or the MBs don't need a case for that reason in the first place :).
You are correct on the spread spectrum clocks. Outside of military, they really soley exist for compliance (specifically unintended electromagnetic emissions) and are increasingly everywhere out of necessity. If an integrator needs spread spectrum locked on, there is no doubt a BIOS available that does just that.
"Now that I'm in position to ask ;)"
Ask away :) This is boring for 99.99999% of the population so I don't get to talk about it often :)
"I've wondered about the glass/plastic window PC cases.. Surely a PC case itself would not be required to have any emission tests done on it, or would it?"
You're right, a PC case itself does not need EMC compliance, but a PC case that's sold with a power supply does. So does one with built in fans and lights or anything electronic. IMO and very much off the cuff, certing the case + lights and fans without a whole computer inside is probably reasonable. But I would personally try cert with a whole PC (defence in depth).
"On the other hand, might the PC motherboard emissions be certified with the assumption that it will be placed inside a case?"
Yes it can be certed that way. Generally if it is, the details have to be in the manual.
But also, legally, you don't really need to cert a motherboard because it will always be integrated into another thing. However the reality of the PC architecture is that it is extremely modular and reach module is extremely complex. It's simply not at all practical for any systems integrator to try to modify those modules to try and make a whole PC compliant so that they can sell it. Even sticking the whole thing in a metal case might not be enough because the case has cables attached to and unwanted emissions and get out via those.
So for practical purposes manufacturers of motherboards, graphics cards, PSUs, hard drives etc vigorously test and cert their products with decent margins so that no matter what cards are used or how a PC is put together, the sum will be compliant. And this rule holds pretty well in general at all scales, from the individual parts and submodules that come together to make a product up to several products wired together in your house with power and network cables.
And system integrators can demand these requirements because it's necessary for the industry to function. I found a few years ago on Dell's website their manual for part suppliers. It listed every standard they required, made stricter and even had additions of their own so that they could sell with your module everywhere in the world, because they sell everywhere. It basically a thick manual on making a computer "world compatible".
"And then finally comes a consumer (or even a small integrator) and sticks in a PC motherboard inside a windowed case—but in this case the case might not be doing much on the RF side. Or maybe the cases provide better RF protection than they look like or the MBs don't need a case for that reason in the first place :)."
And the consumer benefits from everything I explained earlier. They can buy parts and assemble a computer that will be compliant. It's also why computer shops can build you a PC and sell without a cert and it'll be fine. Just the sheer effort of all these manufacturers so that they have a market to sell into means that the problem is solved for small players in the traditional PC world. The traditional PC industry is quite unique in that way actually.
"Now that I'm in position to ask ;)"
Ask away :) This is boring for 99.99999% of the population so I don't get to talk about it often :)
"I've wondered about the glass/plastic window PC cases.. Surely a PC case itself would not be required to have any emission tests done on it, or would it?"
You're right, a PC case itself does not need EMC compliance, but a PC case that's sold with a power supply does. So does one with built in fans and lights or anything electronic. IMO and very much off the cuff, certing the case + lights and fans without a whole computer inside is probably reasonable. But I would personally try cert with a whole PC (defence in depth).
"On the other hand, might the PC motherboard emissions be certified with the assumption that it will be placed inside a case?"
Yes it can be certed that way. Generally if it is, the details have to be in the manual.
But also, legally, you don't really need to cert a motherboard because it will always be integrated into another thing. However the reality of the PC architecture is that it is extremely modular and reach module is extremely complex. It's simply not at all practical for any systems integrator to try to modify those modules to try and make a whole PC compliant so that they can sell it. Even sticking the whole thing in a metal case might not be enough because the case has cables attached to and unwanted emissions and get out via those.
So for practical purposes manufacturers of motherboards, graphics cards, PSUs, hard drives etc vigorously test and cert their products with decent margins so that no matter what cards are used or how a PC is put together, the sum will be compliant. And this rule holds pretty well in general at all scales, from the individual parts and submodules that come together to make a product up to several products wired together in your house with power and network cables.
And system integrators can demand these requirements because it's necessary for the industry to function. I found a few years ago on Dell's website their manual for part suppliers. It listed every standard they required, made stricter and even had additions of their own so that they could sell with your module everywhere in the world, because they sell everywhere. It basically a thick manual on making a computer "world compatible".
"And then finally comes a consumer (or even a small integrator) and sticks in a PC motherboard inside a windowed case—but in this case the case might not be doing much on the RF side. Or maybe the cases provide better RF protection than they look like or the MBs don't need a case for that reason in the first place :)."
And the consumer benefits from everything I explained earlier. They can buy parts and assemble a computer that will be compliant. It's also why computer shops can build you a PC and sell without a cert and it'll be fine. Just the sheer effort of all these manufacturers so that they have a market to sell into means that the problem is solved for small players in the traditional PC world. The traditional PC industry is quite unique in that way actually.
> I assume the author is from the US (as they speak about the FCC). I had a 30 second look at these dev boards and their instructions. There is no FCC conformity declarations or markings, so US customers can't use it.
Just order it off Aliexpress.
It's fine to have a really expensive compliance regime, so long as you understand how that drives the small end of the business offshore.
Just order it off Aliexpress.
It's fine to have a really expensive compliance regime, so long as you understand how that drives the small end of the business offshore.
Then it's on you as the importer. This is part of why lots of stuff on AliExpress and dodgy Amazon 3rd party supplies is cheap. It's non compliant stuff that is not even sold in China. It's export only, and for the wrong reasons.
Market forces alone didn't work. It's an externality, a cost paid by others not involved in the transaction. Market forces don't handle that. A 1970s Milton Bradley Big Trak and a Radio Shack TRS-80, both popular products in their day, will, if brought near to each other, both crash. Without fairly strict regulation of unwanted RF emissions, there would be many incompatible devices. There were before the FCC started requiring more testing in the 1970s. A world with a huge number of consumer devices emitting RF noise would have prevented low-power cellular phone and WiFi deployment.
It's not that hard. This is an "unintentional emitter" (it's not trying to send a radio signal). The rules for that are not too bad. Testing costs about $3000 to $5000.
You want to have some ability to pre-test. You might find something. Attaching a wire to something can give it an antenna and make it emit much more RF, so you do need to test. It's not too hard.[1] Actual FCC certification is $3000 to $5000, assuming you pre-tested and fixed any problems before getting a certification run.
From the project's FAQ:
"Given that this will initially be a niche product, the price will be quite high. I was once taught to ask myself the following question: Who is your rich customer? The type of person whom I have in mind has a high discretionary budget for personal electronics and willingness to pay a premium for novel ideas."
[1] https://www.nutsvolts.com/magazine/article/low-cost-emi-pre-...