# Is FCC-accredited testing required again if circuit board is placed in a different package?

I am considering enhancing a commercially-available device so that it can be installed outdoors. The enhancement would be to seal the product inside a resin case to make it weather-resistant. The result will be something that looks like a brick with wires sticking out for 12v DC power and Ethernet data. Once inside the sealed case, the product, along with its FCC sticker, would be invisible. The resin case would have my branding on it and not that of the sealed device. Can I just remove the FCC sticker on the original device, before encasing it, and apply it to the exterior of the new sealed case, or do I need to go through the FCC conformance testing as if it were a new totally different product? The sticker would have the branding of the sealed-device manufacturer on it. The device is an unintentional radiator.

I have the option of either sealing the entire device, as it is sold, or removing it's circuit board from it's original enclosure, only sealing that, and discarding it's original plastic non-shielded enclosure. Would it make any difference between any of these two scenarios, from the point of view of FCC conformance testing requirements?

• What certification? Part 15? Which class? Which subpart(s) are applicable? – Mark Jul 31 '11 at 18:27
• This answer says you don't even have to get it tested to begin with (since it is an unintentional radiator): electronics.stackexchange.com/questions/16935/… – Kellenjb Aug 1 '11 at 0:20
• "What would I know, I'm in New Zealand, but I've heard much over time" answer: I'd guestimate that sealing it unaltered in a box would retain FCC compliance, but that taking off the external box may invalidate the compliance. (If it was UL then both may invalidate compliance). – Russell McMahon Aug 1 '11 at 5:09
• The device is an unintentional radiator that connects to a computer, so it falls under 15.101 subpart d. It doesn't require certification but it does require a Declaration of Conformance, (DoC), which can only be issued if the product has passed the tests done by an FCC-accredited lab. It's an honor-system type thing where you declare that the device conforms, but you're only allowed to do that if you had your product tested and it passed. You then have to put the sticker on with the FCC logo and language. – Jim M. Aug 2 '11 at 20:08
• What Russell said makes sense, however, I'm concerned that because the product that was sealed, now has permanent cables attached to it, that it didn't before, it may now be considered a different product. If one is not careful, those cables can actually become radiating antennas. I'm inclined to think that I can't get away with just reusing the original sticker, but I was hoping that someone in the forum would have more insight into this type of issue. – Jim M. Aug 2 '11 at 20:14

I am going through this too, and likely late for the original question, but thought I'd share. FCC requirements are for anything marketed or sold that emits electromagnetic radiation. If it's a computer or gear that isn't supposed to transmit then it is, as mentioned, an "unintentional radiator"--so it's now in that ballpark of rules. If the device is for commercial use, not in homes, then it falls under the Class A rules (less stringent). If it is for residential use you have to follow the rules for Class B. If you are encasing the whole product inside something else then you don't have to go through FCC validation and can use the existing approval. If it is a Class B device with an FCC statement on its label then you can put that same info on the outside of your box. If you don't want to use the full product and put parts in your own resin case then you have to go through the FCC processes. If you market and sell and then get caught you could end up with severe penalties, along with being stopped from marketing your product.

Start at: http://transition.fcc.gov/oet/ea Note the "Application Information" and "Equipment Authorization Procedures," including:

Verification
Declaration of Conformity (DOC)
Certification


To get an idea of testing go to this page: http://transition.fcc.gov/oet/ea/fccid/ and plug in the FCC ID from any product you have handy that has an FCC ID (or you search the Web for one) and then you can see the report that was generated--including a description of the lab setup, the tests, and the report data.

We will work with a lab for the testing but also work on our own testing ability so that we can do at least part of it on our own (so that we don't go to a lab with something that won't pass).

Good luck.

If you are only putting something in a box and not re-selling it, there is, in my understanding, no requirement to do any further testing or make any further declarations. The problem will be if you indend to re-sell the device, as it will now not be the same as originally tested. If all you are doing it putting it in a box, it is highly unlikely that the emissions characteristics will change. However, you can no longer use the original FCC sticker as that only applies to the original device that you put in the box. You will need a new sticker that identifies you as the responsible organization. You don't necessarily have to re-test, you can self declare if you can make the case that the emissions will not have changed.

• Though your point about the additional cables is a good one. I would be inclinded to get a lab to do a quick pre-scan and see how much margin there is and then self declare if it's OK – Gareth Aug 24 '11 at 13:57

If this is a unintentional radiator and you are using it completely within its specified limits, then I think you're OK. Permanently keeping the cables plugged in shouldn't matter because the device was originally tested with cables hanging off. If the device is specified for maximum cable lengths, make sure you don't exceed them.

Unless putting this device in a box is outside its intended use, I don't expect any problems.

If you open it, then you're on your own.

See Olin's answer. Everything electronic must be within the conducted and unintentional radiator limits. There isn't a certification for this: you must comply. Many people pay a lab to do this testing to make sure their device is ok. Unless your box somehow acts as a waveguide and focus some low level emissions, you should be ok.

Devices with an FCC ID are intentional radiators and have further testing and must be certified (that's when they get the FCCID). You can get a "modular" approval for an intentional radiator and include this is a device. Then on the label you say "Contains FCC ID: foo". Modules have additional rules to me such as they must have a shield.

You can't take a device with an FCC ID that doesn't have a modular approval and stick it in something and use "Contains FCC ID: foo". If you ship something without a module (e.g. an embedded board with a WiFi USB stick) the WiFi stick has to be visible from the outside and user serviceable.