I guess this is probably one for Zach, but is the Part 15 paperwork available somewhere. I looked in in the design area on GitHub and I could not see anywhere where it would obviously be (PDF’s would be the logical place).
In terms of EMC, it is not only the WiFi module that can be an issue, but also things like the CPU. Some jurisdictions require anything with an oscillator operating above 9 KHz to have analysis done for EMC.
Ideally what I would like would be some paperwork saying that the device in certain configurations meets US Part 15. I can then take that documentation and determine what further testing might be needed. It is my understanding under the Australian regulatory regime that if I take a design like the Spark Core that has already been tested and use it in my design, provide I do in depth analysis, that further testing is no longer needed.
If you have an FCC tested Spark Core with a linear regulator and some LED’s and Buttons then the analysis is easy. Add more CPU’s to the design and it becomes harder to justify lack of individual certification tests.
it’s my understanding that as soon as I connect any additional electronics (such as an LED strip) this is no longer the case. But this is not my area of expertise, so I could be mistaken.
Can anyone point to a reference that clarifies one way or another?
thanks in advance.
@matt_ri there are basically two types of certification that matter: intentional radiator (i.e. an RF transceiver) and unintentional radiator (i.e. something that might emit RF by accident rather than on purpose, such as a microcontroller). As far as certification goes, we’ve got you covered for the intentional radiator (the Wi-Fi chip), but if you add any unintentional radiators (high frequency electronics), you will require your own certification. That said, certification for unintentional radiators is much cheaper and simpler than those for intentional radiators, and if your product doesn’t add anything that would be considered an unintentional radiator, then you won’t need any further certification.
Got it! That’s what I thought. Thanks for clarifying.
Hope you don’t mind me digging this up, as searching in the docs yielded 4 generic results. I’d like to know the specifics of the FCC/CE/IC certification.
I’ve seen other players in the space I’m looking at entering list the following type of material in their docu:
The [product] Contains Transmitter Module FCC ID:Wxxxxx100-xxxx01 Radio regulation certification for United
States (FCC), Canada (IC), Europe (ETSI) and Japan (ARIB) 2.4 GHz, IEEE Std. 802.11b™, Wi-Fi® certified (WFA ID:
The Wi-Fi components in this product have been certified under Wi-Fi 802.11 withWPA2, WPA, and WEP System
Interoperability ASD Model Test Plan with Test Engine For IEEE 802.11a, b and g Devices (Version 1.0).
Is something along this lines handy to the team to provide (and potentially place in the docs?)
If its not too much trouble, I’d also like an American opinion on whether 12v sensor devices would likely require other certification?
@BDub and @mohit might be able to give more information.
Hi, bump @BDub @zach
This is pretty important for me, about to move into production.
Further information is it seems in Australia you require to be registered as a supplier with the ACMA. I’d really love someone from Particle who knows certification etc to a provide the FCC details as well as commentary on how Australian manufacturers would go about dealing with LIPD class registration. You don’t need recertification, but you do need to be able to refer to the international / other certification records.Perhaps a central page singularly highlighting compliance?
The crux of the matter, including what information should be supplied when registering:
Hey @mterrill - I’m bringing @will into the conversation because he’s the one who has done the certification on the Photon.
We have a stub of a section of our documentation dealing with certification:
Will, what’s the timeline for fleshing out this section of the docs?
Hey guys! I had just made a note in my to-do list to build out this section in the Guide before seeing Zach’s post. I’ll put more language together by the end of this week.
As far as your question about 12V sensor devices, the safe answer is that you probably need some sort of recertification, but that the process should be straightforward due to the certifications that Particle has already achieved.
The introduction of additional electrical devices means that you will probably have to take your product through FCC sub part 15b, which is the declaration of unintentional radiators. The FCC allows for self-declaration for unintentional radiators, so it is relatively painless.
The place where you can leverage Particle’s certification is with FCC sub part 15c which governs certifications of intentional radiators. You’ll be able to reuse our FCC Certification ID and number and expedite the approval process as compliance testing instead of a from-scratch certification.
Our FCC ID for the Photon is “2AEMI-PHOTON” and the model number is “PHOTONH”. I’ll add the testing documents to the Guide along with other information around certification compliance.
@mterrill here is that follow-up documentation I promised, by the way. Will continue building it out over the next week as we collect more documentation in a single place.
This is from memory, but I believe it’s still correct:
Australia/NZ follow the EU (CE/ETSI) standards, pretty much, and that means there is no such thing as modular approval. Devices have to be tested as a whole, and tested for the usual CE groups - unintentional emitter (including conducted if the device is AC powered, even through a brick), intentional emitter (the wireless testing) and susceptibility (which isn’t required for FCC - this is beaming RF at your poor hapless device and striking it with many kV of ESD). Note that CE intentional emitter standards are not the same as FCC, so you can’t use FCC reports to help get CE approval - the frequency range, max EIRP, and other details are different.
Note that FCC/IC modular approval only lets you skip the intentional emitter testing, as will notes. This does not guarantee you will pass unintentional emitter even if you just stick the module down with an LDO; the one thing you’ll learn by spending quality time in a $1k/day lab is that EVERYTHING radiates, whether you want it to or not. 4+ layer boards, good board layout, and the advice of the EMC gurus in the lab are all invaluable.
Some places allow self-certification (you say “it’s fine” and file some paperwork), but note that this doesn’t mean you should skip lab tests. If there are issues with the device in the field, or someone tests your stuff and finds it’s non-compliant & reports you, you’ll have to prove to the authorities that you did actually do your diligence and have the test reports to back it up - if you can’t do this then you could be liable for some huge fines and also you’ll have to recall all the products you’ve ever shipped in that market.
The labeling and registration rules vary country to country. Some require an in-country address, but many testing companies have proxies they can use for this to be legally compliant. We went through FCC/IC (modular & end product), CE/ETSI, C-Tick (test to spec, provide spec) and Taiwan modular approvals for our stuff, plus helped companies get approvals on end products in various markets including EU and Japan. As the rules change constantly you should contact a testing specialist and get them to advise you: we’ve used NWEMC and CKC labs locally, plus various ones in Asia.
Northwest EMC: http://www.nwemc.com/
CKC labs: http://www.ckc.com/
Thanks for that detailed response, its food for thought. This was originally a consideration, saw the early docu comments that the Photon certification could be used and then proceeded forward merrily. Now I see thats not the case at all, so potentially 2 months and 10k. I’ll have to find an Aussie test lab for confirmation and quotation.
The main thing to bear in mind is that the liability is yours, as the end product vendor, to comply with the rules & regulations. Speak to experts and take their advice. Most labs will walk you through what they believe you’ll need for free (they have to quote you for it, obviously!) and as sometimes there is room for interpretation, don’t be afraid to ask questions or get a second opinion from another lab. These guys help a lot of people through the process.
Often CM’s in China will have local labs who they work closely with who are very tolerant of multiple chamber visits to address issues without changing the budget. If you’re working with one already, ask them if they have a pretest chamber - often they will not be certified to run legally-acceptable reports, but it’s always best to walk into the expensive lab knowing you’re pretty much guaranteed a pass due to the pre-work you’ve done.
I thought I’d provide a quick update for the benefit of other Australian folk who stumble across this. There was an option for an Australian lab (EMC Bayswater) to review the Photon FCC report, so I paid $660 for that, the outcome being that extreme voltage and temperature testing needs to be performed (~2k) at minimum. It’s still not 110% clear if I still need to do EMI testing, will see how that goes.
@will, I must say I love the content in the building a product (certification) guide at https://docs.particle.io/guide/how-to-build-a-product/certification/. Not sure if its been recently filled out or added, but its great. If you’d like a copy of the Australian review report detailing the necessary extra tests then you’re welcome.
@mterrill thanks for the kind words! It hasn’t changed much since we’re still waiting on some of the final Electron certification numbers to come through, but it is definitely due for an update. I know very little about Australian certifications, and would love to learn more!
I’ll try to remember to post to this thread again once I’ve updated it for the Electron certifications that come through.
@will a few questions regarding certification of a product containing the P1.
- Has particle done any SAR (specific absorption rate) testing on the photon/P1? Our cert lab brought it up since our product may be in close proximity to
- Our product requires FCC co-location testing (we have a second BLE radio on board) which requires firmware for FCC test cases (blast signal on band X with [b/g/n] modulation) is that firmware available anywhere?
Feel free to email or PM.
Please, if the firmware could be put on github or the cloud libraries that would be most appreciated. I’ll need it within the next 10 days if that’s possible?
Ps, so much to organize, not having to write code and hope it’s right will be great.
Firstly thank you for the information about your results from EMC Bayswater, it’s generous of you to share this!
I’ve only just stumbled on this thread again after last viewing it months ago and I have to say that, like you I’d assumed that the FCC compliance would carry over (I’m based in NZ looking at NZ/AUS certification and possibly CE).
I’m finding it pretty overwhelming trying to understand different countries requirements. Do you have any updates on your progress with this extreme voltage & temperature testing? I assume that’s what you’re after the firmware for?