@jackhumbert @Wilba @massdrop
I hope that the lack of response to my question is not indicative of a lack of FCC part 15 verification.
http://transition.fcc.gov/Bureaus/Engineering_Technology/Documents/bulletins/oet62/oet62rev.pdf
According to this document, keyboards are not exempt from verification, and penalties for selling unauthorized devices can be steep:
o forfeiture of all non-compliant equipment
o $100,000/$200,000 criminal penalty for an individual/organization
o a criminal fine totalling twice the gross gain obtained from sales of the non-compliant equipment
o an administrative fine totalling $10,000/day per violation
Additionally CISPR 22 certification may be needed if you are selling in Europe.
I hope olkb and massdrop are not putting themselves at risk.
They aren't selling a keyboard or a device. They are selling a "kit" ...which may be included in section 15.25?
...why bring it up? Are you concerned about emissions?
15.25 refers to TV kits and still requires verification. What they are selling would probably fit under FCC's description of a digital peripheral requiring verification.
I bring it up because of my curiosity about electrical engineering and the challenges of brining a product to market.
As others have mentioned, he's not selling a peripheral device because it isn't assembled. It's a kit and kits are typically treated differently than assembled products when it comes to regulation. For example, cars and planes assembled from kits aren't subject to most of the regs that a finished ready to use version is.
Also, the pcb is probably the only item that would fall under fcc jurisdiction and it probably qualifies as a sub assembly so it would be exempt. Now if he was selling a fully assembled board that might be a different scenario.
Pertaining to kits:
15.25(b) At least two units of the kit shall be assembled in exact accordance with the instructions supplied with the product to be marketed. If all components required to fully complete the kit (other than those specified in paragraph (a) of this section which are needed for compliance with the technical provisions and must be included with the kit) are not normally furnished with the kit, assembly shall be made using the recommended components. The assembled units shall be certified or authorized under the Declaration of Conformity procedure, as appropriate, pursuant to the requirements of this part.
Pertaining to subassemblies:
15.101(e)Subassemblies to digital devices are not subject to the technical standards in this part unless they are marketed as part of a system in which case the resulting system must comply with the applicable regulations.
From the explainer document: (Note, however, that circuit boards or cards that are connected to external devices or increase the operating or processing speed of a digital device are considered peripherals.)
From these descriptions it looks like this keyboard/kit/peripheral/subassembly would fit under the description of Class A digital devices and their peripherals which means it would be subject to FCC verification.
Thought that I had seen it all ... now I come across this self-taught armchair FCC regulations expert :D He's posting his expert knowledge in another drop too...
HAHAHAHAHAHAHAHA!!
We are following up with our legal and will definitely be meeting the full legal compliance requirements for the sale / distribution of these keyboards. No need to worry @SillySpinner
sorry man, you're cool. I was caught up in the moment of confusion when i first heard the news. fingers started pointing and some reply in the earlier posts pointed to what you said a few months ago and i thought somehow they remembered about the regulations just now and thus announced the delay.
I'm assuming you opt-in as well? You want some advil? Here gimme a hug bro.
Lol, thanks. This isn't the only project that I've opted in that has been hit by long delays struggling with compliance. I learned about this stuff waiting for the Ultimate Hacking Keyboard and reading their development blog.
Yeah we learn a thing or two everyday.
For the time being i'm gonna hold off on the drops on MD until my stuff arrive at my doorstep around late october. It's weird having to forget that i have spent significant amount of money on things that i wanted badly at the time but end up getting it way later when the desire died down somewhat.
I imagine the odd feeling i will have when i get it in the mail and be like meh i'll open it later. Then chucks it in the storage, ya know?
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http://transition.fcc.gov/Bureaus/Engineering_Technology/Documents/bulletins/oet62/oet62rev.pdf
According to this document, keyboards are not exempt from verification, and penalties for selling unauthorized devices can be steep: o forfeiture of all non-compliant equipment o $100,000/$200,000 criminal penalty for an individual/organization o a criminal fine totalling twice the gross gain obtained from sales of the non-compliant equipment o an administrative fine totalling $10,000/day per violation
Additionally CISPR 22 certification may be needed if you are selling in Europe.
I hope olkb and massdrop are not putting themselves at risk.
...why bring it up? Are you concerned about emissions?
I bring it up because of my curiosity about electrical engineering and the challenges of brining a product to market.
Also, the pcb is probably the only item that would fall under fcc jurisdiction and it probably qualifies as a sub assembly so it would be exempt. Now if he was selling a fully assembled board that might be a different scenario.
Pertaining to subassemblies: 15.101(e)Subassemblies to digital devices are not subject to the technical standards in this part unless they are marketed as part of a system in which case the resulting system must comply with the applicable regulations.
From the explainer document: (Note, however, that circuit boards or cards that are connected to external devices or increase the operating or processing speed of a digital device are considered peripherals.)
From these descriptions it looks like this keyboard/kit/peripheral/subassembly would fit under the description of Class A digital devices and their peripherals which means it would be subject to FCC verification.
HAHAHAHAHAHAHAHA!!
Don't shoot the messenger.