Is it easy to get FCC certification for a device using the Spark Core?

Got it! That’s what I thought. Thanks for clarifying.

Hi,
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:
WFA7150)
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?

General description:
http://acma.gov.au/Citizen/Consumer-info/My-connected-home/Wireless-local-area-networks/wireless-lans-in-the-24-ghz-band-faqs

The crux of the matter, including what information should be supplied when registering:
http://www.acma.gov.au/sitecore/content/Home/Industry/Suppliers/A-Type-of-equipment/Transmitters-and-mobile-phones/compliance-and-labelling-requirements-of-low-powered-radiocommunications-transmitters

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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:

https://docs.particle.io/guide/how-to-build-a-product/manufacturing/#6-product-certification-em-coming-soon-em-

Will, what’s the timeline for fleshing out this section of the docs?

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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.

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@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.

https://docs.particle.io/guide/how-to-build-a-product/certification/

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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/

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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.

Good luck!

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Hi,
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.

Mark

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@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.

  1. 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 meatbags humans.
  2. 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.
Thanks.

Hey @jakeypoo

  1. We haven’t yet done SAR testing, so you’d have to to do that one separately.

  2. I can work on getting the test firmware to you from the manufacturer of the P1, USI. We have worked with them in the past on verification of certification of products with the P1 on board.

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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?

Mark

Ps, so much to organize, not having to write code and hope it’s right will be great.

@mterrill

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?

Furthermore @mterrill, have you found that you are going to be able to reuse some of the ETSI reports in terms of intentional radiators?
My understanding from @hfiennes comment was that any product going for CE would require all of the intentional radiator tests to be redone - since CE does not accept modular approval, however from your comment regarding just doing the extra extreme voltage and temperature testing, I’m a little confused…

On SAR:

If your device is intended to be hand-held or body-worn, with a output power of >50mW (16.9dBm EIRP), you generally need to do SAR testing. There are different rules for different parts of the body - in particular hand-held is less stringent than body worn (think: walkie talkies).

As I remember, you can completely skip SAR if your EIRP is <50mW (this includes “worst case” (ie maximum) antenna gain). Depending on your product, you may be able to turn down the maximum transmit power - sacrificing range - to avoid the need to do SAR at all.

We did SAR testing on the first imp, and kept our ~80mW EIRP (+17dBm output power in CCK modes, +2.5dB antenna gain) - we passed device independent testing - which has a lower maximum absorption limit) at 20mm separation as I remember. SAR testing is quite cool (they use a robot arm and a tub full of “human body simulator” goo!) but also not cheap (~$10k).

On CE: CE is self certified. There is no such thing as CE modular approval, but modules can be tested to CE specs - that just doesn’t guarantee your product will pass, it only guarantees that on a test board, the module passed product level specs. There are plenty of modules with CE marks which are obviously lying about it - eg the ESP8266 ones which note a +25dBm output power and then also say CE, which is not possible as this is 5dBm over the legal CE power levels…

People DO ship stuff with modules in it without doing intentional emitter testing, but you should speak to a lab and determine whether you think this is a good path. If you CE mark your product and can’t produce any backup that shows that you tested it to CE specs, then you may end up in a bad place. See my post back in July’15.

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Obligatory picture of SAR testing setup. The unit being tested is located under the tub of goo - the robot moves a field probe around in the liquid, mapping out the strength at specific points.

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