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I'm familiar with Part 15 FCC testing for intentional radiators (3 meter limits of certain power, must be filed with FCC, requires accredited lab), but I'm a little unclear on the Class B unintentional radiators?

I know from another product we received a Declaration of Conformity for the Class B limits, and that nothing was filed with the FCC. As the "responsible" party we make the certification the product conforms to Part 15 Class B.

Are we required to use an accredited lab for the Class B unintentional measurements? We have a LISN and 30MHz to 1000MHz EMI antenna in house. Ultimately, my company's you know what, is on the line as the certifying party. So why can't we take the readings, and certify?

The only place I read that the Class B DoCs must come from accredited labs, are from the websites of accredited labs!

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It depends on what it is, look at what your device is in the table:

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Verification

Verification is the easiest and quickest authorization route. Verification just involves you sending your product and any required auxiliary equipment and cables to a test lab. The lab spends approximately 1-2 days measuring the radiated and conducted (if required) emissions coming from your product. If all is well, they generate a test report and send it to you. That’s all there is to it. You’re now at liberty to label, market and sell your product.

Of the 1000 or so FCC test labs around the world, you can select any of them to do this job. From the FCC’s perspective, there are “2.948 listed” test labs and “accredited and FCC recognized” test labs. The difference is that trusted independent 3rd party companies are used to inspect accredited labs to verify a certain level of competence and that procedures are implemented and being followed properly. For non-accredited, registered test labs, no such 3rd party inspection take place. Approximately 2/3 of FCC test labs around the world are not accredited.

Declaration of Conformity (DoC)

Not to be confused with the Declaration of Conformity for Europe, which is completely non-related, the DoC method for the FCC covers certain types of electronic equipment.

If your device is in a category that allows the DoC authorization route, the key here is that you need to select an FCC accredited test lab. Test labs that are only ‘2.948 listed’ with the FCC and are not accredited, are not allowed to test devices using the declaration of conformity authorization route.

Before these new rules, “Listed” (or non-accredited) test labs could get around this requirement by instead undertaking ‘certification’ testing on your device. But that option will no longer be available to you or to the test lab when the rules come into full effect. So, products subject to the ‘DoC’ authorization route will only be able to be tested at an accredited lab.

Certification

Certification testing requires an application package of test results plus other documentation be sent to a special test lab called a Telecommunication Certification Body (TCB). Both accredited and non-accredited test labs could previously do the testing for certifications. After these rules come into effect, only accredited labs will be able to perform the testing. It’s worth noting that TCBs can also perform the testing themselves as well as issue the certifications.

Source: EMC fastpass


Are we required to use an accredited lab for the Class B unintentional measurements? Ultimately, my company's you know what, is on the line as the certifying party. So why can't we take the readings, and certify?

If the product being tested only needs verification, then you could test at a lab that has been registered with the FCC. If you need a DOC, then you'll need to go to an accredited lab.

Of course, you can always test in your lab before you send the product out for testing to make sure the testing goes smoothly and you don't have to do a second round.

The only place I read that the Class B DoCs must come from accredited labs, are from the websites of accredited labs!

No, the FCC also tells you that you need DOC's from an accredited lab:

Q: I don’t have the expertise in house at my organization. Who can provide FCC equipment authorization?

A: Unless you are fortunate enough to have an accredited in-house FCC laboratory in your company, the best choice is to involve a third-party FCC lab at the design stage and then follow through with testing of your product at the lab.

Q: Is one lab as good as another?
A: There are many EMC labs around the world. In accordance with 47 CFR 2.948, the FCC list labs that the FCC has on file for FCC Verification equipment authorization. For any FCC work, your lab should be on this list.

Furthermore, if the device requires Declaration of Conformity equipment authorization, the lab must be ISO/IEC 17025 Accredited. An accredited lab has been audited by a third party such as the American Association for Laboratory Accreditation to the international standard for good laboratory practice ISO/IEC 17025.

The following website: http://www.fcc.gov/oet/ can be used to find an FCC lab that is listed under 2.948 or Accredited for FCC work. Search under “Test Firms”. Then search by the level of accreditation needed.

Source: FCC FAQ's

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  • \$\begingroup\$ I actually emailed the FCC. Verification has been removed in the most recent rules. It is now supplier declaration of conformity, SDoC. SDoC does not require an accredited lab... Also has less labeling requirements. I am waiting to get more guidance and will post something when i hear back. \$\endgroup\$ – Leroy105 Nov 21 '17 at 4:49
  • \$\begingroup\$ Also what is interesting is that there are no 2.948 Listed labs in that tool. Because the FCC appears to have really moved to accredited labs, but now is moving back...? I get the sense that the 2.948 listing requirement would eliminate self-testing (that is unless you want to go through the 2.948 process), but hopefully the FCC will weigh in on this. Also, for SDoC there are not real clear statement requirements in manuals floating out in the public. \$\endgroup\$ – Leroy105 Nov 21 '17 at 15:52

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