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FCC regulations apply to unintentional radiator devices, but provide exceptions for subassemblies, including this one:

CPU boards, as defined in §15.3(bb), other than those used in personal computers, that are marketed without an enclosure or power supply

Would a PCB business card qualify since it has no enclosure? Do batteries qualify as a power supply? The rest of the page references power supplies in relation to personal computers, but the definitions page does not define power supply. I would be giving these away instead of "marketing" them, but I'm not sure that makes a difference. Also, new rules came out in 2017 about testing, which may be relevant here.

The board I would like to build would have a small screen, tactile buttons, and a microcontroller and use 1-2 coin cell batteries. It would run at over 1.7MHz and use more than 6nW, so I don't think it qualifies for any exemptions.

Here are a few similar projects I have found that seem comparable:

PCB Business card

Tiny Tetris on a business card

Business card game console

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  • \$\begingroup\$ The way I read it is: CPU boards...that are marketed without an enclosure or CPU boards...that are marketed without an (sic)...power supply. Therefore, if you had both an enclosure and power supply then you're no longer exempt. \$\endgroup\$ – calcium3000 Aug 23 '18 at 21:41
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I can understand your frustration, testing is expensive:

Request quotes from a few test facilities as well as timelines for when they can get your product into their facility for testing. They will generally handle the filing after you fill out a few forms. Quotes for an intentional transmitter may contain sections for the following (rough ballpark numbers. your results may vary):

  • CFR 47 Part 15 Section 247 – testing for intentional radiated emissions ~$5k
  • CFR 47 Part 15 Section 109 – testing for unintentional radiated emissions ~$1k
  • Test report documents ~$1k
  • FCC Form 731 and some other filing paperwork ~$2k
  • IC paperwork – $2k

Source: https://hackaday.com/2016/09/19/preparing-your-product-for-the-fcc/

An unintentional radiator (defined in Section 15.3 (z)) is a device that by design uses digital logic, or electrical signals operating at radio frequencies for use within the product, or sends radio frequency signals by conduction to associated equipment via connecting wiring, but is not intended to emit RF energy wirelessly by radiation or induction.

Today the majority of electronic-electrical products use digital logic, operating between 9 kHz to 3000 GHz and are regulated under 47 CFR Part 15 Subpart B.

Examples include: coffee pots, wrist watches, cash registers, personal computers, printers, telephones, garage door receivers, wireless temperature probe receiver, RF universal remote control and thousands of other types of common electronic-electrical equipment that rely on digital technology. This also includes many traditional products that were once classified as incidental radiators – like motors and basic electrical power tools that now use digital logic.

Products that only contain digital logic may also be specifically exempted from an equipment authorization under Section 15.103.

Source: https://www.fcc.gov/oet/ea/rfdevice

The only devices that receive exemptions are these:

Except as otherwise exempted in §§15.23, 15.103, and 15.113, unintentional radiators shall be authorized prior to the initiation of marketing, pursuant to the procedures for certification or Supplier's Declaration of Conformity (SDoC) given in subpart J of part 2 of this chapter...

Source: FCC CFR 15.101

As stated in the question, your device would not fit in the unintentional radiators exemptions category (15.103) your device is definitely not at 15.113 (Power line carrier system)

It could fit into 15.23 and more on that later:

§15.23 Home-built devices.

(a) Equipment authorization is not required for devices that are not marketed, are not constructed from a kit, and are built in quantities of five or less for personal use.

(b) It is recognized that the individual builder of home-built equipment may not possess the means to perform the measurements for determining compliance with the regulations. In this case, the builder is expected to employ good engineering practices to meet the specified technical standards to the greatest extent practicable. The provisions of §15.5 apply to this equipment.

Source: FCC CFR 15.23

Your device is an unintentional radiator but not one under section 15.102 (CPU boards and power supplies used in personal computers.) Because these are related to PC's and their components, these components usually are designed for operating inside of a metal enclosure, they also have their own standards that need to be tested.

If your device is not exempted, then you'll need in the least verification because you have a CPU in your product (and it above 1.7MHz check the Frequency allocation list\chart). If your device starts messing around with radio device or knocks someones cell out, someone might complain. It's when people complain (if your radiating on their band) that you get into trouble and become the "responsible party" and if your found to be above the limits, then the producer of the product gets a fine. And rightly so, it can take a significant amount of resources to find an offending device.

RESPONSIBLE PARTIES The FCC has very specific rules as to who is responsible for regulatory compliance regarding various types of RF devices. Different rules apply for RF devices subject to various types of authorization. The responsible party is the exclusive party that is required to ensure that RF devices under its custody comply with FCC rules. This includes all identical devices marketed after authorization. Because the responsible party is liable for noncompliant RF devices and related matters, that party will be subject to FCC enforcement actions in the event potential rule violations are discovered (see 47 C.F.R. § 2.909).

Source Are Your Company’s Consumer Electronics Exempt from FCC Marketing Regulations?

If it's a prototype then you don't have to worry about testing, but you still have to worry if your device is an unintentional radiator

What does this mean for a hobbyist?
Very little, actually, depending on what you’re doing. The FCC allows a hobbyist to build up to five devices of a single design for personal use with no testing whatsoever. If you are contacted by the FCC (or anyone else) about a matter of spectrum interference, immediately stop using the device, don't use it again, and you should be okay. Stick to the ISM bands (13.56MHz, 27.12MHz, 40.68MHz, 915MHz, 2.45GHz, and 5.8GHz, +/- a bit for each) for added comfort

Source: https://www.sparkfun.com/tutorials/398

So stick in an unlicenced band for extra comfort and design around that.

Edit -Subassembiles

How do some companies get away without certifying their devices?

You may be asking yourself how companies such as Sparkfun, a business based on selling electronics kits and wireless development kit companies continue to sell large numbers of non FCC authorized kits, with seeming impunity. For Sparkfun, the rules that apply in most cases relate to “subassemblies”. This just means that Sparkfun’s customers will most likely use the products to build larger products containing a number of subassemblies. For example, that may include an Arduino™ processor board along with several sensors or peripherals and an LCD. The user may even put all of these parts into an enclosure. If the user sells this product containing multiple subassembly parts in an enclosure, for all intents and purposes they are now a “manufacturer” and their equipment is subject to the normal FCC authorization procedures.

Where is the FCC’s line in the sand for when home built equipment becomes subject to their rules? That is defined in Part 15.23.

“Equipment authorization is not required for devices that are not marketed, are not constructed from a kit and are built in quantities of five or less for personal use.”

That’s probably easier to understand if I say it in the opposite way; If you are marketing your product (are you putting out ads, or offering your product for sale?) or it is not intended for personal use (i.e. it’s for someone else) or if you make more than 5 of them, then you need to have your device tested according to FCC rules. If you do any of these things, the FCC views you as a manufacturer.

Source: http://www.emcfastpass.com/fcc-rules-kits-subassemblies/

So if you want to go the sub assemblies route, then sell them as sub assemblies for use in another product, and don't do any marketing.

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  • \$\begingroup\$ I see that it is not under section 15.102 but I am asking about 15.101 on subassemblies: CPU boards, as defined in §15.3(bb), other than those used in personal computers, that are marketed without an enclosure or power supply \$\endgroup\$ – user19271 Aug 23 '18 at 23:10
  • \$\begingroup\$ Yes, the device you describe would most likely be defined as a CPU board, other than those used in a personal computer. Anything with a CPU or a frequency generation device is an unintentional radiator and is regulated as such. In all of the products I design, I also have to list the frequency so the ETL that does our FCC testing can make sure that frequency does not exceed the unintentional radiator limits \$\endgroup\$ – laptop2d Aug 23 '18 at 23:24
  • \$\begingroup\$ in that case, it would a subassembly, which does not seem to need regulation according to the exceptions in 15.102 referring to unintentional regulators, right? \$\endgroup\$ – user19271 Aug 24 '18 at 0:36
  • \$\begingroup\$ Sorry, I forgot about subassemblies I'll edit the question. \$\endgroup\$ – laptop2d Aug 24 '18 at 2:51

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