We are planning to use the PLUTO to complement our system (through programming the PLUTO and adding an additional RF stage at TX and at the RX).
I am digging into the CE and FCC marking, to develop it further, demonstrate, and later place it into the market. We don't want to venture out in our work, away from either EU or US rules. In putting it all together, we need to understand how the parts and the whole thing are made to conform.
In previous PLUTO versions, we understood that the CE and FCC markings were indicated as crossed, showing clearly that it did not conform. That would be OK for us, since we were interpreting the PLUTO as for: - the EU: to be used in R&D, not for RF testing (but to be tested itself), as a prototype (not a finished product), so that it could be commercialised in the EU without the CE marking. We would then add an additional module in a similar way. OK
- the US: to be interpreted as a sub-assembly (again not as a finished product, as for the EU) and as a test equipment "intended primarily for purposes of performing measurements or scientific investigations", so that it could be commercialised in the US without the need for FCC marking. We would then add an additional module in a similar way. OK
But, ironically, now that the PLUTO has the CE and FCC marking, we may now need to change the way that our module will be seen, by itself and altogether, in the EU and US perspectives.
Could anyone shed some light on this?How is the PLUTO now seen as compliant for the EU? Not anymore as a prototype, for R&D, etc? Or with the sent antennas, for a specific band and use? And for the US, as a "digital device", an "unintentional radiator" (if so, not with the antennas)? Or again, for a specific band, with the sent antennas?
I know that, for us, we need to deal with our own marking or non-marking. But we also need to understand the whole and all parts in it.
I did read AD's https://wiki.analog.com/resources/eval/user-guides/ad-fmcomms2-ebz/certification, about the FMCOMS and ADI Boards“Certification
Both CE and FCC are necessary for system level products. Because ADI boards are custom built evaluation kits destined for professionals (you) to be used solely at research and development facilities for such purposes, they are considered exempt from the EU product directives and normally are not tested for CE or FCC compliance.
If you choose to use your board to transmit using an antenna, it is your responsibility to make sure that you are in compliance with all laws for the country, frequency, and power levels in which the device is used. Additionally, some countries regulate reception in certain frequency bands. Again, it is the responsibility of the user to maintain compliance with all local laws and regulations."
There are some answers at:
Did you see that? If it doesn’t describe things - I will try to add some more.
Thank you, Robin!I did yes, and also your https://wiki.analog.com/resources/eval/user-guides/ad-fmcomms2-ebz/certification, about the FMCOMS and ADI Boards.I did acknowledge that the PLUTO is not FCC-Certified, but that it now has a SDOC (Self-/Suppliers Declaration of Conformity, for the FCC marking). Similarly for the EU, with a SDOC (for the CE marking).
Should I then understand that, though not obliged to follow the EU (RED/EMC/Low Voltage/ROHS) or US/FCC rules 15, "just" (not the right word, which is a lot!) stating "Operation is subject to the following two conditions: (1) these devices may not cause harmful interference, and (2) these devices must accept any interference received, including interference that may cause undesired operation. " can be a reason to consider that it does comply with the EU/CE standards and US/FCC rules - "just" the necessary ones, these fundamental ones?
Am I explaining this well enough?João
OK. Maybe I wasn't too clear, above. Sorry.But I get the gist: for the FCC, even being excluded from most of the rules, there are certain rules that still apply (some rules in part 15 and part 2 of Chapter, for the marking); since the rules include the consideration of exclusions, being an exclusion means following the rules in the minimum required; the same, probably, for the EU and CE marking.
Thank you for your help.
I added the Declaration of Conformity, so you can see what things we tested/passed.