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A word about UL and FCC certification

Monday, May 25th, 2015 by Mike Ficco

The UL (Underwriters Laboratories) and the FCC (Federal Communications Commission) are two American organizations concerned with the safe and proper operation of electronic equipment and associated power supplies. These organizations, and others like CE, CCC, KCC, etc. do much more than worry about power supplies and electronic equipment but that is my focus today.

I think everyone will agree that we can’t have our electromagnetic spectrum splattered and destroyed by noisy electronics. We can also agree that burning down your house with a poorly made power supply would be really, really bad. The problem is the cost of testing and certification – especially as related to cheap, low volume, products.

The testing itself involves some magic. In one instance, years ago, we took a new¬†product through FCC part 15 certification. The product¬†connected to the PC printer port and transmitted and received digital data. We took a name-brand PC and cables with us for the test. Our device failed and we were very disappointed. The helpful technician running the test looked at our disappointment and asked if he could disconnect our device. He did and observed that the PC itself was splattering the environment with emissions. The very helpful technician removed our name-brand PC and grabbed a well-tested one he had in the lab. We loaded our software on his PC and our device passed. We were awarded the magical FCC certificate. He then shared some inside information with us. “Keep these modules safe”, he said of our devices that had just passed. “Normal production variation means that many, if not all, of your production modules will fail future emission tests.”

I also remember my childhood. My father was involved in ham radio – back in the days where you built your own equipment using ARRL books, Popular Electronics, Radio Electronics, and other references. This equipment was often made from war-surplus equipment and nearly all of it was made by hobbyist, not engineers. My dad had a tower in the back yard and regularly talked to other hams in Europe and South America – and occasionally neighbors when the broadband TV receivers of the day couldn’t reject 500 watts from down the street.

Electronic splatter can be worse than annoying. It can be dangerous if it interferes with equipment operation or critical communications. So the goal is righteous but compliance and certification testing may cost many thousands of dollars – perhaps $10,000 to $15,000 for only FCC part 15. It also requires some very specific technical knowledge. All this can be a huge impediment to the development and sale of cheap, low volume products. If an entrepreneur spent $15,000 on government testing and sold 100 of her product this would add $150 to the cost of each product sold – not very cost effective…

If this imaginary entrepreneur sold 1,000 products, she would be very, very happy but the testing still would add $15 to each and every product.

I have a personal interest in this as I’ve been playing with a small Arduino based product idea and it has reached the point to start worrying about certification prior to sale. I’ve been through FCC certification several times in the past and frankly I’m looking for ways around this expense.

I’m climbing on my soapbox now and calling for a government change. The goals of the testing and certification are righteous and good but the implementation has gone astray. Many of the authorized testing labs make millions of dollars per year and the costs are simply out of reach of most people armed only with a cool idea and ambition. The government agencies, testing organizations, and such need to provide a low cost alternative to this expensive testing.

Cheap low volume products could be assigned to a specific category eligible for free or subsidized testing. Perhaps testing labs could perform some amount of pro bono testing; perhaps the government could encourage this with a tax deduction for this public service. I don’t know the right answer but this is a real problem that must be addressed. The alternative to some sort of free or low cost testing is what we see today – false certification labels applied to some imported products with cavalier disregard for any testing. Worse, we see good ideas withheld from the market due to fear of the government regulations.

Like I said in my book (p. 33), “The most explosive growth of technology occurs in the Wild West mode before the sheriff and laws move in to protect intellectual property and ensure orderly progress.”

Unfortunately, our electromagnetic spectrum is too valuable to allow its corruption and wanton destruction. Simply giving a free pass to low volume products or turning a blind eye to the problem really does risk the sanctity of a finite resource. Somebody, or some foundation, should solve this.

One Response to “A word about UL and FCC certification”

  1. ‘CE’ is not an organization. It is a mark that indicates the manufacturer has published a declaration of conformity with a basis for the presumption of conformity with marking directives that are scoped for the product. Unless accompanied with a test lab’s mark, there is no formal certification associated with a CE mark.
    The FCC has no associated administrative law that addresses “safe and proper operation”. 47 CFR part 15 establishes limits for unintentional radiators, but these limits have no enforcement value unless there is a complaint.
    ‘CCC’ is not an organization; it is the China Compulsory Certificate mark that indicates one or more mandatory Guobiao standard certifications.
    Sample requirements and recommendations for Type Tests are clearly specified in the EU EMC Directive guide, Canada ICES, etc.

    There is no veracity for radiated emissions data for component power supplies, and most EMC standards or directives disallow formal reports for a component where end-use equipment is not part or the report; which then becomes a condition of acceptability for use.

    EMC and safety test labs require a huge investment in facility and equipment and personnel. Pro-bono work by these test labs is essentially corporate suicide.

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