Brian

     > I can't find the legal language in Part 15 that spells this out;  does 
anyone know?

It’s not in part 15 😊

Part 2.1043<https://www.ecfr.gov/current/title-47/section-2.1043> and FCC KDB 
178919


Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: Brian Gregory <[email protected]>
Sent: Tuesday, August 29, 2023 11:13 PM
To: [email protected]
Subject: [PSES] Fw: FCC/ISED file change update


Good afternoon,

I'll repeat my earlier story and give the group an update.

We have made some small changes to our product (prominently to Y-caps, and some 
beads) which unfortunately did not increase our margin vs EMC limits, but the 
product still passes FCC and ISED.  Engineering wanted to use the 
self-declaration process to document these changes, including passing test 
results w/o going through the TCB and re-file process.  The changes do appear 
to classify for what CFR 47, Part 15 § 2.1043  call a class II permissive 
change, but it's just as certain that the original FCC and ISED ID's are still 
valid as the product is roughly the same, still passes emission limits and made 
no changes to the WiFi system (same chip, location, antenna, and firmware).

I've been told - by (a) an engineer from a well-known EMC/TCB, and (b) an 
engineer at a local EMC test lab -  that Class II permissive change only 
applies to intentional radiators.   I can't find the legal language in Part 15 
that spells this out;  does anyone know?

Does anyone want to confirm Engineering's assertion that SDoC will suffice?

Thanks,

Colorado Brian


Please note: forwarded message attached

From: David Schaefer 
<[email protected]<mailto:[email protected]>>
To: Brian Gregory 
<[email protected]<mailto:[email protected]>>, 
"[email protected]<mailto:[email protected]>" 
<[email protected]<mailto:[email protected]>>
Subject: RE: [PSES] Necessary Lab accreditations, class 2 permissible change
Date: Thu, 10 Aug 2023 15:42:24 +0000
________________________________

This message is from the IEEE Product Safety Engineering Society emc-pstc 
discussion list. To post a message to the list, send your e-mail to All 
emc-pstc postings are archived and searchable on the web at:
https://www.mail-archive.com/[email protected]/<https://www.mail-archive.com/[email protected]/%20>

Website: https://ewh.ieee.org/soc/pses/
Instructions: https://ewh.ieee.org/soc/pses/list.html (including how to 
unsubscribe)<https://ewh.ieee.org/soc/pses/list.html>
List rules: https://ewh.ieee.org/soc/pses/listrules.html

For help, send mail to the list administrators:
Mike Sherman at: [email protected]<mailto:[email protected]>
Rick Linford at: [email protected]<mailto:[email protected]>

For policy questions, send mail to:
Jim Bacher at: [email protected]<mailto:[email protected]>

________________________________

To unsubscribe from the EMC-PSTC list, click the following link: 
https://listserv.ieee.org/cgi-bin/wa?SUBED1=EMC-PSTC&A=1

-
----------------------------------------------------------------
This message is from the IEEE Product Safety Engineering Society emc-pstc 
discussion list. To post a message to the list, send your e-mail to 
<[email protected]>

All emc-pstc postings are archived and searchable on the web at:
https://www.mail-archive.com/[email protected]/

Website:  https://ewh.ieee.org/soc/pses/
Instructions:  https://ewh.ieee.org/soc/pses/list.html (including how to 
unsubscribe)
List rules: https://ewh.ieee.org/soc/pses/listrules.html

For help, send mail to the list administrators:
Mike Sherman at: [email protected]
Rick Linford at: [email protected]

For policy questions, send mail to:
Jim Bacher:  <[email protected]>
_________________________________________________
To unsubscribe from the EMC-PSTC list, click the following link: 
https://listserv.ieee.org/cgi-bin/wa?SUBED1=EMC-PSTC&A=1

Reply via email to