[HN Gopher] How to validate a market with development boards and...
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How to validate a market with development boards and SD cards
Author : zkirill
Score : 121 points
Date : 2024-07-09 19:47 UTC (1 days ago)
(HTM) web link (flyingcarcomputer.com)
(TXT) w3m dump (flyingcarcomputer.com)
| rererereferred wrote:
| Their FAQ here[0] explain some things about these devices they
| are building, except for the main question: what are they for? It
| says personal computers but no audio, video or games. So for
| reading?
|
| [0] https://flyingcarcomputer.com/posts/a-new-personal-computer/
| chrisldgk wrote:
| Reading this, it doesn't seem like they're really doing
| anything more than building a glorified raspberry pi with their
| own self-spun BSD distro preinstalled. Also the FAQ being
| mostly Q: ,,why not use X?", A: ,,I don't know X and thus it's
| bloated/I don't like it" doesn't inspire a lot of confidence.
|
| I admire their dedication and it seems like a fun project. I
| don't think it's something a lot of people will pay money for
| though.
| sgerenser wrote:
| Looks very weird. No LCD screen, but presumably it'll plug into
| a monitor? Seems like just pointing out expected use cases
| would go a long way.
| biosboiii wrote:
| The FAQ is hilarious.
|
| He is writing this entire article to save 3-5k conformity
| tests, but bases his entire software on FreeBSD because "it's
| more commercially friendly.
| buescher wrote:
| This new type of personal computer runs... xlib and twm. I
| like this person, but, uh, I'm not investing.
| Joel_Mckay wrote:
| You do know many devices like Raspberry CM have FCC/IC modular
| pre-compliance, and thus usually only require LAB EMI testing
| under the rules.
|
| The primary problem with mystery-parts is they tend to have
| issues with RoHS documentation, complex customs clearance
| requirements, and unknown specifications.
|
| DIY evaluation kits people assemble do fall under a sort of gray
| area, but if your hardware does splatter the RF spectrum it is a
| $1m fine in the US, and a $5k fine + up to 5 years in jail in
| Canada.
|
| Unshielded RAM, USB/PCI to Ethernet, and Video GPU chips will
| often just barely pass EMI testing under ideal circumstances.
| Cheap stuff from the mystery bins will usually just glean the FCC
| id off a refrigerator to get through customs.
|
| Have a nice day, =3
| practicemaths wrote:
| "The testing and certification industry is odd. In theory, it
| exists to serve the public good and uphold consumer protection
| laws. On the other hand, its customers are in the private sector.
| Normally, market forces would dictate that by now it would be
| straightforward, fast, and affordable to get your product tested
| as frequently as desired. However, in reality, the labs are "too
| busy" to respond or reply very late and generally sound less than
| eager to work with you. Not to mention, the fees that they quote
| are rarely palatable to a bootstrapping startup. And yet, working
| with them is generally required to get your product to market."
|
| Market forces naturally determined this outcome though. If you're
| big companies you naturally want to limit the threat of new
| competition. Making compliance more costly achieves this.
| eYrKEC2 wrote:
| a.k.a. "regulatory capture" -
| https://en.wikipedia.org/wiki/Regulatory_capture
| bildung wrote:
| Enforcing basic device safety is hardly regulatory capture. I
| was part of preparing devices for CE tests, the requirements
| are essentially: nobody gets killed if the hardware is
| plugged in, you haven't accidently created an rf transmitter,
| and if you want to advertise IP67 it should survive being
| placed under water.
| taneq wrote:
| Also, by definition, testing and certification companies have a
| captive market and will tend towards being lazy and
| exploitative. Any competition that springs up might temporarily
| improve things but then it too will get used to having a
| captive market and start sliding in the same direction.
| tootie wrote:
| I used to work at a place that did some custom hardware
| development. Usually one-off or very limited run. Any time we
| fabricated a case and plugged in off-the-shelf devices,
| certification was not necessary. If we did custom wiring we got
| ETL certified. I didn't run the process myself but I recall it
| being easy and not very costly (few thousand?) It's a barrier
| but a pretty low one. Our electronic work was like advanced
| amateur level and it still passed with minimal modifications.
| femto wrote:
| Big companies are often outside "the market", in that they have
| internal labs which are accredited to test their own products.
| Aurornis wrote:
| > Market forces naturally determined this outcome though. If
| you're big companies you naturally want to limit the threat of
| new competition. Making compliance more costly achieves this.
|
| Compliance for basic products isn't costly, though. It's a
| rounding error relative to the wages you have to pay engineers
| and the costs involved in manufacturing the product.
| bboygravity wrote:
| It is a high cost to certify when you're not paying yourself
| and you're the only person in your startup/hobby.
|
| Cost of DIY hardware design: 0 Cost of PCBA from China:
| rougly 100 to 2000 USD depending on complexity and nr of
| runs. Cost of DIY firmware and software: 0
|
| Cost of external certification/compliance tests: 5000 to
| 25000 USD depending on the amount of runs it take to make it
| pass and what needs to be checked and what the industry is
| (battery management safety, medical, aerospace, FCC and/or
| CE, RED and/or others, etc).
|
| So yeah, an RnD department wouldn't really care, but "guy in
| mom's basement" would.
| bildung wrote:
| If the project is actually just a hobby, then CE and
| probably FCC testing is not needed.
|
| If the project is a startup, then the cost of labor is not
| zero, at least not if people are not deluding themselves
| (i.e. at least opportunity costs should be considered).
|
| Personally, as a consumer, I'm pretty happy that I can buy
| e.g. a wireless mouse or a bluetooth speaker and can
| reasonably assume that they actually work and aren't
| accidently jammed by some "startup"'s hardware.
| crote wrote:
| > If the project is actually just a hobby, then CE and
| probably FCC testing is not needed.
|
| That's the entire problem: _According to the law, it is!_
| There are extremely few exception, and the exceptions
| that do exist are essentially useless for hobbyists.
| Everyone selling small-scale prototypes on websites like
| Tindie is just rolling the dice and hope they don 't get
| get a life-ruining fine.
|
| There are plenty of $5-$50 trinkets I'd like to design
| and sell as a hobby to fellow enthusiasts, due to their
| niche nature probably only a few dozen of each. But
| there's no way I can afford a $5000-$10.000 testing &
| certification fee on each one of those, and without that
| I'd be breaking the law.
| buescher wrote:
| You can sell kits, because companies do. Kits are only
| required to be authorized in very specific rules for
| specific types of kits. However, devices assembled from
| kits are not exempt from FCC authorization requirements.
| Home built devices not assembled from kits do get an
| exemption. You figure out the contradictions here - i.e.
| this is not advice.
|
| The FCC has fined people for assembling and selling
| uncertified radio transmitters from other's kits. Like
| this guy:
| https://docs.fcc.gov/public/attachments/DA-12-574A1.pdf
| Note that the company that sells the kit he was
| assembling is still selling the same kit that results in
| an uncertified AM-band transmitter when assembled.
| pjc50 wrote:
| This. The compliance requirements take out an entire tier
| of small companies and short run products. This eliminates
| a lot of potential startups at the first stage.
|
| You don't get quite so many big companies without going
| through the small company stage. You're limited to VCs and
| spinoffs of other megacorps.
|
| But I guess everyone is happy with the equilibrium that's
| actually emerged (buy your unregulated short run
| electronics from China).
| gizmo686 wrote:
| $10k is peanuts for starting a small business in many
| industries. It does not even buy you a truck. You don't
| need VC or a megacorp; this is well within the range of
| standard business loans.
| analog31 wrote:
| Is there such a thing as low-cost testing and certification
| services operating overseas?
| miki_tyler wrote:
| That's a TERRIFIC idea and a great business model.
| analog31 wrote:
| Actually, I'd use such a service myself.
| Aurornis wrote:
| There are labs in China that will _wink wink_ pass any product
| you send them for a flat fee.
|
| The problem is that having passing test results from a random
| lab doesn't help you if the FCC (or one of your competitors)
| discovers that your device is not actually compliant. So you
| have to be careful about what you're getting.
| jkestner wrote:
| Yes. The FCC has a list of accredited testing labs here:
| https://apps.fcc.gov/oetcf/eas/reports/TestFirmSearch.cfm Many
| are in China and have reasonable prices.
| liminalsunset wrote:
| There are plenty of products which ought to be certified but are
| not, and plenty of products that probably do not need to be that
| are.
|
| This is across large and small companies, so I'm going to take a
| guess and say that in the AliExpress and Temu age, simply mailing
| the device from China will solve all of your problems.
| Aurornis wrote:
| > so I'm going to take a guess and say that in the AliExpress
| and Temu age, simply mailing the device from China will solve
| all of your problems.
|
| Your guess would be wrong. The regulatory agencies aren't
| inept. They'll figure out where the headquarters is, not just
| where the products are being shipped from.
|
| So unless you're moving the entire company, and your bank
| accounts, to China and you have a backup plan for what happens
| when they start seizing your shipments at the border, this
| isn't a solution.
| liminalsunset wrote:
| Do you actually have an example of something like this
| actually happening? From what I can tell, at least in Canada,
| absolutely nothing from China I've bought has ever even been
| opened for inspection, and it's all tagged as a gift worth
| ten cents and a battery cover or something inane like that.
|
| Anything from half a kilowatt hours of laptop batteries to
| miscellaneous electronics has passed through, so I don't
| think there is any inspection going on at all.
|
| Anecdotally based on the number of things that I see without
| any FCC ID (tbf you can abuse the SDoC process which is self
| declared [this is why the CE certification is worthless btw]
| ), I'm just uncertain the FCC actually does any enforcement.
| And Amazon sellers are also an example of this not being an
| issue.
| HeyLaughingBoy wrote:
| Yep. Fluke, an electrical instrument manufacturer, has a
| copyright on the look and feel of its handheld digital
| voltmeters (DVMs). Anyone in the industry will immediately
| know a Fluke by what it looks like. And they are pretty
| much the gold standard of handheld DVMs.
|
| Some years ago, a containerload of cheap DVMs from China
| arrived with a similar appearance, but not made by Fluke.
| Customs seized the lot and informed them. I forget the
| details of what happened next, but they were not allowed to
| be sold in the US since they were in violation of the Fluke
| copyright.
| jvanderbot wrote:
| I never understood the nuance here. If I put a rasp pi in a box,
| does it need certification? What about with connections soldered
| on if all connections are already certified? How about the
| logical next step of a board with certified components?
| TheCleric wrote:
| I'm no expert but I think the problem is that once you start
| combining certified components in a new configuration that it's
| theoretically possible for the sum of the parts to be non-
| compliant. Perhaps a wire you added becomes, in essence, a
| transmission antenna of the noise in the circuit and thus could
| interfere with other devices.
| utensil4778 wrote:
| As far as I understand, modules like an ESP32 for example,
| carry their own FCC certification. If you include them in your
| product, you _do_ still need certification of the product
| overall, but you don 't have to worry about the radio
| certification, just unintentional radiators.
|
| For instance, if your widget includes an ESP32 and a switching
| power supply, you are (notionally) guaranteed to never fail
| certification due to bad behavior from the ESP, but if you
| botch your power supply design and are spewing out noise in the
| KHz to MHz range, you still fail certification.
|
| Even if every individual component in your device carry their
| own certification, you still have to certify the product as a
| whole. Poor PCB design can produce bad EMI. Maybe you're
| running SPI over a long wire or your traces are routed in a way
| that accidentally creates an antenna at your SPI clock
| frequency. Hell, even something as simple as toggling a GPIO
| pin once a second can emit high frequency EMI under the right
| conditions.
|
| There are a _lot_ of ways to unintentionally produce harmful
| EMI, and that 's exactly why FCC certification is required for
| everything. This stuff is _hard_ to get right and there are
| endless gotchas and exceptions and edge cases and you have to
| know about and account for all of them.
| jvanderbot wrote:
| This makes sense. Thanks for ELI5.
|
| Presumably EMI certification is easier than the FCC RF
| certification.
| petsfed wrote:
| > _This stuff is hard to get right and there are endless
| gotchas and exceptions and edge cases and you have to know
| about and account for all of them._
|
| And this is also a major source of the cost of the testing.
| You're not just paying $5k+ for a piece of paper that says
| "FAIL" on it, and "better luck next time". The test engineers
| want you to pass, ultimately (if for no other reason than
| because you can't get repeat business from a customer who
| goes out of business), so they're going to point out the
| common sources of harmful EMI they've seen in other designs.
| Animats wrote:
| > Market forces naturally determined this outcome though.
|
| Market forces alone didn't work. It's an externality, a cost paid
| by others not involved in the transaction. Market forces don't
| handle that. A 1970s Milton Bradley Big Trak and a Radio Shack
| TRS-80, both popular products in their day, will, if brought near
| to each other, both crash. Without fairly strict regulation of
| unwanted RF emissions, there would be many incompatible devices.
| There were before the FCC started requiring more testing in the
| 1970s. A world with a huge number of consumer devices emitting RF
| noise would have prevented low-power cellular phone and WiFi
| deployment.
|
| It's not that hard. This is an "unintentional emitter" (it's not
| trying to send a radio signal). The rules for that are not too
| bad. Testing costs about $3000 to $5000.
|
| You want to have some ability to pre-test. You might find
| something. Attaching a wire to something can give it an antenna
| and make it emit much more RF, so you do need to test. It's not
| too hard.[1] Actual FCC certification is $3000 to $5000, assuming
| you pre-tested and fixed any problems before getting a
| certification run.
|
| From the project's FAQ:
|
| _" Given that this will initially be a niche product, the price
| will be quite high. I was once taught to ask myself the following
| question: Who is your rich customer? The type of person whom I
| have in mind has a high discretionary budget for personal
| electronics and willingness to pay a premium for novel ideas."_
|
| [1] https://www.nutsvolts.com/magazine/article/low-cost-emi-
| pre-...
| bruce511 wrote:
| The first rule of knowing if a market exists is to define what
| you are making and then figure out who it's for. Then pitch to
| that person the benefits of your product.
|
| Alas the FAQ page lacks both of these questions. I'm left with
| no idea -why- I'd buy this thing. What utility does it have?
| What is it supposed to replace?
|
| I think you can stop worrying about the FCC issues with it. You
| won't sell any of these (at least not with this FAQ page). Your
| whole "discussion" is technical and doesn't mention utility
| once.
|
| It sounds to me like you're building this because it's fun to
| build and scratches an itch. But it's not a product, much less
| requires you to start building and designing new hardware. So
| well done on at least skipping that investment.
|
| If you want to make a hardware product then early about utility
| first. If it's useful then other things flow from that. Not the
| other way around.
| willsmith72 wrote:
| > The first rule of knowing if a market exists is to define
| what you are making and then figure out who it's for. Then
| pitch to that person the benefits of your product.
|
| I would switch that order. Figure out your customer before
| you define what you're making.
| bruce511 wrote:
| Yes, that's even better.
| olalonde wrote:
| Why is it so expensive though? Also, why not fine or ban
| products that cause problems rather than requiring
| certification. It seems that would be a lot more efficient.
| KolmogorovComp wrote:
| > Also, why not fine or ban products that cause problems
| rather than requiring certification
|
| Because people could get hurt or killed in the meantime. See
| the 737max for example.
|
| Now it is a dramatic example, but think about any device
| unwillingly emitting too much electromagnetic radiation
| potentially being harmful to kids or messing with people
| pacemakers.
| olalonde wrote:
| You could make similar arguments for basically any product,
| doesn't seem worth it to get every product certified
| though.
|
| Also, didn't the 737max pass certifications?
| pjc50 wrote:
| Almost every product _is_ certified in the EU (CE
| marking), although if you look closely it 's self-
| certification and it's not always clear _which_ sets of
| certification might be required for a product.
|
| (I'm on the fence about this; personally I think there
| need to be far more small company / small production run
| exemptions from these requirements, but on the other hand
| I don't want a loophole for recklessly dangerous
| products)
| wsc981 wrote:
| _> Almost every product is certified in the EU (CE
| marking), although if you look closely it 's self-
| certification and it's not always clear which sets of
| certification might be required for a product._
|
| Not to be confused with the Chinese Export marking:
| https://www.kimuagroup.com/news/differences-between-ce-
| and-c...
| okanat wrote:
| The amount of misinformation on the internet is
| worryingly high but not unexpected. No such thing as
| Chinese Export logo exist. It cannot officially exist in
| the EU since the CE sign is protected. Whatever this
| website is sharing is FUD and misinformation.
|
| It doesn't mean that nobody fraudulently puts those
| markings on devices without a testing certificate backing
| it. However anybody who puts CE mark on a product without
| complying is risking being punished by EU member states.
| As an importer and distributer of such goods you'll be
| punished as well. CE certification is indeed self
| disclosed but it doesn't mean that you would get away
| with noncompliance.
|
| Source: https://www.europarl.europa.eu/doceo/document/P-6
| -2007-5938-...
| pjc50 wrote:
| The "China Export" logo is extremely funny as it's
| basically a Chinese response to "you need a label? OK,
| fine, we'll give you a label" with none of the underlying
| bureaucracy.
|
| The "UKCA" one, on the other hand, is real but tragic.
| olivierduval wrote:
| Worst of all: if you package certified CE product... you
| need to certify the whole package too!!! Think about
| using some certified CE PC in a cabinet for example...
|
| On the other side: if you forget ventilation in the
| cabinet, the certified PC might burn... so packaging CE
| certified components doesn't mean that the whole is risk-
| free
| pjc50 wrote:
| > Worst of all: if you package certified CE product...
| you need to certify the whole package too!!!
|
| Yes. This is a significant difference from the US, where
| FCC compliance testing for modules is much more
| reasonable.
|
| The US also appears to contract out basic electrical
| safety to the insurance industry (Underwriter's
| Laboratories).
| buescher wrote:
| The NFPA writes the national electric code. They also
| came out of the insurance industry, and like UL and FM,
| predate adoption of their standards in regulation. FM is
| an actual insurance company but it is not OSHA. The
| history is similar to European organizations like the
| German TUeV, which came out of the boiler industry. All
| of them have their roots in disasters of the industrial
| revolution.
|
| Governments today generally don't operate test
| laboratories, standards organizations, or certification
| bodies. DIN, ISO, IEC, BSI etc are not government
| organizations.
|
| You're right, though, that there's more history of
| insurance industry involvement in developing safety
| standards and testing in the US.
| specialist wrote:
| Using fraud as a counter example, where the self
| certifying manufacturer admitted to the crime before
| Congress, kinda seems like missing the point.
|
| Ditto Dieselgate.
|
| Doesn't negate the need for testing. Rather, it shows the
| need for effective oversight.
| moooo99 wrote:
| > Also, why not fine or ban products that cause problems
| rather than requiring certification.
|
| Because certifying upfront is cheaper than trying to find
| products that cause problems in the field, do lots of testing
| and find somebody and recall all the other products that are
| in the field
| pjmorris wrote:
| It seems like fining or banning problems found problems 'in
| the wild' would require customer troubleshooting to find
| the cause, manufacturers would lose the product development
| cost for banned products, and the regulator(s) would have
| to staff for discovery in the field rather than in the lab.
| IMO, this seems like it could be more expensive than
| finding potential problems early.
| buescher wrote:
| It's not expensive. What does a week of a good hardware
| engineer's time cost?
|
| It's not even necessarily that expensive: $3K-$5K is a good
| budgetary range if you don't have any pre-compliance test and
| engineering capability because you might need 2-3 trips to a
| certified test lab to pass. If you have experience in your
| product space and good pre-compliance testing, you can
| definitely be one-and-done for less than that.
| delfinom wrote:
| Certification requires testing in a specialized lab that has
| a special anechoic chamber along with equipment that runs
| tens of thousands to hundreds of thousands of dollars. You
| also need an engineer or highly trained technician to run the
| test and/or interpret the results. You also have to wire up
| and instrument every device that comes in and they do vary a
| little. That's why the cost is in the thousands of dollars.
| There is a profit margin for the labs but it's also not a
| cheap service.
|
| It is not efficient policing bad devices after the fact. You
| can have a bad device interfere with RF communications for
| miles. It then requires dispatching a team of humans with RF
| probing equipment and escalating to the Feds if the person
| refuses to comply. It does happen but it is time consuming.
|
| Leaky RF can cause mass events such as
| https://www.cbc.ca/news/canada/calgary/carstairs-westview-
| co...
|
| Here's a IEEE Video on the process of interference hunting:
| https://www.youtube.com/watch?v=elUDfDmIHLs
|
| A short article on how some equipment on a tug boat was
| interfering with a town:
| https://www.verizon.com/about/news/verizon-test-force-
| braves...
|
| And this is the interference hunting that has to happen now
| with devices certified. It would be an absolute hell if
| devices could just be introduced willynilly.
| rsynnott wrote:
| "We've just bought 50,000 new whatevers for our worldwide
| chain of stores... Oh, oops, they cause EM interference,
| throw them away I guess."
|
| (More realistically, you'd just see extremely slow adoption
| in any important use-case.)
| joezydeco wrote:
| _Now, how to get the SD card in the hands of the customer? Mail
| it to them!_
|
| I worked on a equipment project for a large restaurant chain
| about a decade ago. The core application and related
| assets/recipes/files were all on an SD card. When it was time to
| upgrade the app or release new seasonal recipes, every store got
| a new SD card in the mail with instructions to wait for a certain
| date, power down, swap cards, power back on, dispose of the old
| card.
|
| It was _way_ cheaper to send updates that way than bother with
| encryption, networking, corrupted disks, etc. A bricked machine
| lost a hundred dollars or more per hour. If the new card failed,
| the operator could continue with the old one until a replacement
| could be sent.
|
| One major problem was suppliers always trying to swap to lower
| cost SD cards, even counterfeit ones (c.f. Bunnie), and things
| would go south really fast. The Linux system and hardware were
| both pretty old and had MMC stack issues when the cards showed
| shaky margins on the timing. Or, capacity wasn't what was
| advertised (c.f Bunnie). We had to spend a cycle or two
| qualifying each mailing release to make sure a shitty batch of
| cards didn't make its way into the stream.
|
| SD has its uses, although I still prefer a read-only eMMC
| partition to hold the bootloader and O/S. I don't get why RPi
| users put themselves through such misery to save $20 on their
| SBC.
| negative_zero wrote:
| EEE here with 16 years experience and having to deal with
| compliance from day 1 of my career. I now consult on product
| compliance. Author you are welcome to contact me.
|
| Disclaimer: Nothing below is meant as legally relevant compliance
| advice. This is just my opinion on the matter.
|
| Going to snark:
|
| _" The testing and certification industry is odd"_
|
| Except, outside the software world, the real world, where there
| are real consequences, it's not really.
|
| _" The line about CES, in particular, made my hair stand up."_
|
| Why? Absolutely the unauthorised device at CES is should NOT be
| allowed. What if said device caused too much interference on cell
| phone frequencies and suddenly nobody at CES can dial the local
| emergency number?
|
| If that made "your hair stand up", here's one from personal
| experience that will freeze your blood:
|
| I worked as a teen for a certain electronics chain. Said chain
| was selling a wireless weather station imported from China. A
| government department that monitored the country for Earthquakes
| noticed that this device impinged on their frequencies. After the
| spectrum regulator confirmed the finding, a nice gentleman from
| them visited us a told us the following:
|
| 1) As of this moment this device can no longer be sold. Move it
| off the floor immediately (he stayed and made sure we did exactly
| that).
|
| 2) That we will immediately issue a recall of said device at your
| own cost and issue full refunds to the customers.
|
| 3) He will return when we decide on further enforcement action
| which may include punitive fines and recommendations for further
| remedial action you will need to undertake.
|
| _" In theory, it exists to serve the public good and uphold
| consumer protection laws."_
|
| Well here's a (very simplistic) tidbit for the author: In the US,
| part of the gestation and formation of standards bodies and
| testing was "market forces", not for the public good. It was to
| help protect companies from litigation. If you followed the
| standards, tested and certed to them, paid the fees etc you then
| had the standards entity bat for you in court (UL is short for
| _Underwriters_ Laboratory. That name was not chosen for funsies).
|
| _" However, in reality, the labs are "too busy" to respond or
| reply very late and generally sound less than eager to work with
| you."_
|
| Well you don't sound like a serious customer. AND the Labs are
| not there to give you advice. They're there to do INDEPENDENT
| testing.
|
| _" Variations of the FCC exist in pretty much every developed
| economy. Putting a poorly tested hardware product on the market
| immediately puts a target on your back. Maybe you'll get lucky,
| but chances are that someone somewhere will report you. And,
| unless you are operating entirely out of China, it will hurt. A
| lot. Both your company and maybe even you, personally."_
|
| As it should. The electromagnetic spectrum is a very precious and
| very limited commodity and IMO, the best regulated "commons" in
| human civilisation (though still not perfect). So no, you are not
| welcome to just urinate in it willy nilly with your hustler start
| up product.
|
| _" I did not want to spend so much money on testing before I
| validated the market or gathered a community of believers."_
|
| And there it is.
|
| _" This way, the electronic device liability will fall on the
| manufacturer, and the magic of friendship EULA should afford me
| enough protection to make this a pure software play."_
|
| No. That's not how this works.
|
| 1) I assume the author is from the US (as they speak about the
| FCC). I had a 30 second look at these dev boards and their
| instructions. There is no FCC conformity declarations or
| markings, so US customers can't use it.
|
| 2) It has CE and UKCA though, so customers from EU+UK (and some
| other countries) can buy them but the certs only cover the dev
| boards AS SOLD. (i.e without the authors software)
|
| 3) Author is modifying the product behavior with their software.
| So yes author. You are still liable. Technically, your customers
| are first in the line of fire. But the likely sequence of steps
| is: Friendly Spectrum Representative will visit them first, have
| a chat, ask them to stop using the device, then leave them a lone
| and then come for YOU.
|
| 4) What the author has _actually_ done is "buy down" their risk.
| It is simply less likely that the product will become non-
| compliant when their software is loaded. But it is still
| possible. At second glance, those dev boards don't come with a
| power supply. What is your recommended power supply to use
| Author? Have you tested your setup with said power supply and
| have test reports at the ready for when Friendly Spectrum Person
| comes knocking?
|
| 5) Sure it seems clever but Friendly Spectrum Agencies actually
| have quite far reaching and scary powers. Don't think that your
| little sleight of hand here is clever and protects you.
| Fundamentally: You are repackaging + modifying an existing
| product. The steps you are taking in between to "launder" your
| liability are irrelevant.
|
| Frankly, it's shit like this, that makes it harder for everyone
| else playing by the rules. It did actually used to be easier.
| There used to be exemptions for "low volume" products. But all of
| those were seen as loopholes and HEAVILY abused. Now these toys
| have been taken away, with more to follow.
| ThrowawayTestr wrote:
| Absolutely amazing response. I love it when a real engineer
| comes and explains the real world to software "engineers".
| liminalsunset wrote:
| I think that both sides (SW and HW) can learn to coexist
| better, and tbh, there is really a necessity for them to.
|
| The reality is that the reason software is currently the top
| industry/value creator when it comes to revenue is an
| artifact of an open ecosystem where the barriers to entry are
| low, and where there is space for many to experiment.
|
| Traditionally, the engineering world doesn't see things the
| same way. Part of this is culture, and that's hard to change
| - engineers see what they do as an art, and this is fine,and
| it's a good thing as some engineering systems do have a
| disproportionate impact, but I think the tone of the response
| also does reflect an attitude of perfectionism and "this at
| any cost" that I think holds the field back.
|
| I think the solution is not rather to "just let people run
| amok" (though as it happens, this is the strategy China is
| testing for us and it appears to not have broken too much yet
| - the land of trillions of SOIC-8 Bluetooth MCUs with no
| shielding and a 5-line BOM) but rather for the engineering
| world to embrace the software developers and provide a happy
| path to compliance.
|
| If you want North America to compete with China on having
| ubiquitous technologies everywhere (this is the only way to
| build out the supply chain), we have to come up with a way to
| fix certification and part of the attitude has to be "we're
| going to teach you how to cheaply get your product to market
| in a way that respects the spectrum", and not "it's
| expensive, deal with it". This one is tough for people to
| accept but we cannot ever go back to stuff being expensive,
| as the floodgates have already been opened.
|
| This is something that the government has to do, probably -
| provide funding to run (at least, cut down versions of the
| labs for precompliance) cheaply, put out good resources.
| Encourage or fund the creation of low-cost and easy to
| understand paths to compliance. As anyone knows, if you try
| to hold your nose to stop a nosebleed, the blood just goes
| down your throat. Same with all of the stuff from China. If
| you want to meaningfully improve device compliance, making
| the process hard and painful will just increase the number of
| random Amazon/Temu Bluetooth nonsense with a total lack of
| attention to design at all. If we made the process more
| accessible, it's possible that this would drive the industry
| to create solutions that might not even cost more, but are
| more compliant - which would be a win overall.
| Palomides wrote:
| hard agree, it sucks immensely that I can design a cool 4
| layer PCB with multicore processor in an afternoon, throw
| on a standard bluetooth module, and have it manufactured
| and shipped to me in a week for like $100, but heaven
| forbid I want to sell five of them to fellow nerds on a
| niche forum without breaking multiple laws, and the path to
| compliance is, uh, find a consultant with EMI testing
| experience and industry connections and/or spend $5000?
|
| and then amazon is full of absolutely noncompliant untested
| stuff with no consequences
| buescher wrote:
| Amazon absolutely requires sellers to supply FCC
| certification and Suppliers' Declaration of Conformity
| documentation for FCC regulated devices. You can report
| any noncompliant products to them and they do remove
| them.
|
| Just wait till you learn about say, product liability,
| CPSC regulations, "voluntary" safety standards, and so on
| crote wrote:
| Don't forget having to spend $X000 for the privilege of
| being allowed to read the standards you're required to
| follow, and needing a consultant to tell you _which_
| standards you have to follow in the first place.
| negative_zero wrote:
| EMC compliance rules are needed so that all our electronic
| devices (running software mind you) can continue to
| function. Part of the rules are about squeezing as much
| "performance" as possible out of the "thing" that is the
| electromagnetic spectrum. It's simple physics.
|
| The other part of the rules are for human safety. Devices
| can directly hurt people (like a microwave) or indirectly
| (like a crappy device that prevented ambulance phone calls
| going through).
|
| It's as simple as that (and not perfectionism or being mean
| to the poor software people).
|
| _" "we're going to teach you how to cheaply get your
| product to market in a way that respects the spectrum"_ I'm
| available to do exactly that for you at my hourly rate :D
| peteforde wrote:
| Thank you for this. It's possible that you've saved me and
| others a lot of pain by heading off ignorant mistakes.
|
| I'm currently building a product that makes use of an ESP32
| module with a built-in antenna. I've been operating under the
| naive assumption that since the modules are certified, the
| product I build with the module is certified (perhaps pending
| an EMF certification or something equally trivial). You've
| certainly put this issue on my radar.
|
| That said, while I actually enjoyed the snark in your reply,
| there are those of us who actually do want to get this right
| and do the right thing, despite lacking years of experience and
| an infinite budget.
|
| If you have any go-to resources to share that might qualify as
| accessible and perhaps written to an indie maker audience, I'll
| diligently consume anything you recommend.
| buescher wrote:
| The go-to resources are the FCC regulations and guidance
| documents. Be very careful with anything written to an indie
| maker audience. FCC regulations have the force of law and you
| are ultimately responsible for compliance: not the guy you
| read on the internet, not even your test laboratory.
|
| https://www.fcc.gov/oet/ea/rfdevice
| https://www.fcc.gov/general/equipment-authorization-
| procedur... https://apps.fcc.gov/eas/comments/GetPublishedDoc
| ument.html?...
|
| There are a number of things you could conceivably be doing
| that would complicate your compliance situation beyond simply
| using the module's certification, getting test data from a
| certified lab for unintentional radiation for the Supplier's
| Declaration of Conformance procedure, appropriate labeling,
| and so on. (You're right that's a reasonable assumption about
| your situation but it may not always be true). They include
| but are not limited to, say, using more than one pre-
| certified transmitter in your device.
| negative_zero wrote:
| No problems. You are very welcome :)
|
| It sounds like you are actually doing some things right :)
| FCC, for example, have scope for "modular approval". Order a
| radio module (with modular approval), do _exactly_ as the
| datasheet tells you and you can "piggy back" off the radio
| modules radio certs. But you will still need to test and cert
| for things like your own "unintentional emissions", maybe ESD
| and other things (NOT actual compliance advice btw, this is
| just to give a rough picture).
|
| _" That said, while I actually enjoyed the snark in your
| reply, there are those of us who actually do want to get this
| right and do the right thing, despite lacking years of
| experience and an infinite budget."_
|
| Oh I absolutely know you people are out there :) (I've
| consulted for them. I've also consulted for the ones who are
| learning the hard way...)
|
| I don't intend to be mean with posts like this on HN, but
| some reality on these posts is just needed IMO. Especially
| given how much software dominates product development these
| days and people just don't know.
|
| I think it's difficult for new comers, but I don't know how
| you fix that other than asking a consultant. The earlier the
| better. You can certainly make early feature and design
| choices to make your certs simpler (and cheaper) down the
| road.
|
| That said, I think a good place to start for anyone is the
| following:
|
| 1) Find a product that is broadly similar to yours. Is it
| like a small computer? Is it a wired network device like a
| router? Maybe it's like a bluetooth dongle or smartwatch?
| Find one from a large reputable company and search said
| company's website for their "EU Declaration of Conformity".
| On these docs (even though it is not required) many companies
| list the standards that the device is compliant with. They
| have names like: EN 55022, EN 60950, IEC 61000-3-3.
|
| NOTE - This is for EU only, but they have massive regulatory
| reach. Also many FCC and EU standards are very similar or
| even the same. Over time they have been converging more and
| more.
|
| 2) Do this for a few different devices of the same or similar
| category and you will notice many which are _always_ there
| and some that are sometimes there. Now you have a starting
| template of standards that you might need.
|
| 3) With this starting template, you can now look up the
| standards names and often download the first few pages free
| to get an idea for what they are for.
|
| 4) Get a quote from a lab. They often do a lot of testing for
| product importers (as onus is also on said importers), so
| they can have "non-engineer friendly" forms that you can fill
| in. This will give you a price but also some information on
| what they think you need (they have to be careful though
| because they have to maintain their independence). Tell them
| you want CE (Europe) and FCC (North America). This covers
| much of the world for you. Many countries, even those with
| their own standards, also simply accept CE and FCC (again
| this is all in very very broad strokes). Many standards are
| also just copy and pasted between different regulatory
| domains but they change the name. So the original standards
| body will have their name for it. When the EU recognises it,
| it'll get an "EN" number for it's name (for example).
|
| 4b) Consider a hiring consultant for a short chat to
| "downsize" the standards you need and maybe they can point
| out any you might be missing. Good ones can also advise you
| on things you can do to avoid standards (and this is not in
| an illegal way). If you understand the rules well, you can
| sometimes make small changes and avoid whole sets of rules
| and testing (classic one IMO is a radio device. In VERY
| GENERAL TERMS, if it's going to be used more than 40cm from a
| human, then you don't need to test for human absorption of RF
| energy. My Chromecast, for example, has a disclaimer on it so
| that they can claim exactly this (IMO of course) ). How to
| find a good consultant? Well that's hard and I don't have a
| sure fire way sorry. Some labs have business cards of small
| local consultants.
|
| 5) Source copies of the standards and read them (Yes it'll
| likely be heavy reading). Most standards sellers (including
| the national ones) are crooks. Don't use them. Instead go to
| the Estonian Centre for Standardisation and Accreditation:
| https://www.evs.ee/en . They are the cheapest source I know
| of for standards in English (and only English matters).
| Further details in an old comment of mine here:
| https://news.ycombinator.com/item?id=36452660
|
| These above steps are the same steps that I myself use.
|
| Sources to read ... sadly I've not found many good ones. I
| think the best one that I would recommend is
| https://incompliancemag.com/ It's dry and does what it says
| on the tin. But their archives have some great articles by
| experts. They cover new standards, certing particular
| devices, testing technology etc. Even the ads can be kind of
| informative I think. It's good for learning the general
| layout of the field. Not a shallow learning curve but not
| steep either IMO (It's also free in digital form).
| buescher wrote:
| This is all good information. I'd only add:
|
| You left out Canada. IC certs are kind of a pain because
| some of their rules are very slightly different plus you
| need a representative in Canada.
|
| UL standards can be read (but not downloaded) for free on
| UL's standard store. These don't include IEC standards
| adopted by UL, but do include national differences for
| those standards for the US.
|
| The specific procedures your test lab will use in the US
| for typical part 15 devices include procedures covered by
| ANSI C63.4 (unintentional radiators) and C63.10
| (intentional radiators). These you can't get from the
| Estonians. You probably won't need them but they can be
| helpful if you get serious about pre-compliance testing or
| if you are puzzled by what the lab is doing. IEC CISPR
| standards overlap here. There is a list of measurement
| procedures on the FCC web site:
| https://www.fcc.gov/general/equipment-authorization-
| measurem...
|
| You should have an engineer or "directly responsible
| individual" on site at the test lab during testing for all
| kinds of reasons, from building capability and
| understanding of the process to having someone there to
| clear up any misunderstandings. If you have a consultant do
| this for you, you or someone from your company should be
| there also.
|
| For transmitters (intentional radiators) you can look up
| test reports and submittal information for competing
| products on the FCC's web site. That's one way to get an
| idea of what your test requirements and setups will look
| like. For unintentional radiators, you can find some test
| reports with a web search - companies are not required to
| make these public.
| HeyLaughingBoy wrote:
| The certification testers will give a definitive answer, but
| most manufacturers will pre-test their products before
| sending them out for testing to improve the chances of
| passing the first time. You can rent some of the testing
| tools if necessary.
|
| This might be helpful to learn more:
| https://compliancetesting.com/how-to-measure-emi-
| electromagn...
| someonenice wrote:
| >> 3) Author is modifying the product behavior with their
| software. So yes author. You are still liable. Technically,
| your customers are first in the line of fire. But the likely
| sequence of steps is: Friendly Spectrum Representative will
| visit them first, have a chat, ask them to stop using the
| device, then leave them a lone and then come for YOU.
|
| Few questions related to this. - Does this meant that
| recertification is required every time we load a different
| version of the software ? - How does this work for Computers
| and mobile phones ? The hardware is certified but you are
| loading different software daily.
| pjc50 wrote:
| The "software" in these cases is localized to the
| drivers/firmware. This is why you basically can't get a RF
| peripheral for Linux with truly open firmware and they all
| use binary blobs: to prevent you modifying it.
| negative_zero wrote:
| In the purest theoretical sense yes, in practice no. So that
| you don't have to recert everytime, you
|
| 1) test and exercise your product to extremes so that you can
| say with high certainty that: no matter what the customer
| loads, it won't breach the rules.
|
| 2) As pjc50 mentioned: Lock down the parts which the user
| could potentially cause the most damage with. i.e lock down
| that radio firmware (why is why none of it is open source).
|
| If you do (1) and (2) and a few other things, you buy down
| your risk sufficiently that you can confidently demonstrate
| that re-certs are not needed.
|
| The Author of the parent article IMO is doing the exact
| opposite.
|
| There are also half-way houses: Just doing "pre-compliance
| testing". So not a formal cert, your just doing a quick test
| in an anaechoic chamber or even on a table top scanner. Of
| course this only applies to things you can self-certify. Some
| things, like radios (WiFi, Bluetooth etc.), you cannot self-
| certify. That's why almost everyone buys the radio as a
| module (To buy down their risk). By consequence: That's why
| those radio module manufacturers have the firmware locked
| down hard and engineer and cert the radios to have big
| margins.
|
| There are a lot of rules yes, but there is actually a lot of
| flexibility and common sense in the system too (but it is
| still imperfect, absolutely). But that flexibility does not
| allow for horsing around. If you can demonstrate to Friendly
| Spectrum Agency all this due diligence, you are going to have
| a MUCH better time.
| buescher wrote:
| It's complicated!
|
| If it's not a transmitter, then it's not _certified_ (this
| has a meaning), you just need to have acceptable data on hand
| for your Supplier 's Declaration of Conformity (SDoC). Then
| if you make any changes to your product after test, it is a
| judgement call whether you need to retest. Ultimately you are
| responsible for compliance, so this is not a free pass. In
| principle your computer or cell phone manufacturer could get
| fined if it is possible to operate their device with new user
| software in a way that emits RF above allowable levels.
|
| If it is a transmitter and you-the-manufacturer make changes
| to software that operates the transmitter, the FCC has
| specific rules. Look at the KDBs for permissive changes and
| for Software Defined Radio Applications. Note that the FCC
| has a somewhat unique idea of what constitutes an SDR. Some
| software changes to radio firmware will require
| recertification but some just will require a permissive
| change. Some permissive changes are handled in a way similar
| to SDoCs, where you just get yourself a report with
| acceptable data, some require filing that data with the FCC.
| _flux wrote:
| In practice the guy was planning to sell piece of software, on
| an SD card, that is compatible with a piece of hardware, and
| it's up to the customer to actually combine those two. The plan
| is exactly _not_ to sell the hardware at all--granted they SD
| cards are piece of hardware, but what if that too was just an
| image to download off a site?
|
| If the customer cannot legally use that SD with their boards,
| which SD can they use?
|
| Is this not exactly equivalent how I might buy a Raspberry Pi
| and install a non-Raspberry-authorized OS on it? Or equivalent
| on how I might buy a PC and install Linux on it? Or Android and
| LineageOS? Are those devices certified not only as SOLD but
| also as modified by the end-user with software, making them
| somehow different?
| negative_zero wrote:
| That was not my read on it. My interpretation was that they
| wanted to sell a product, but didn't want to pay for an
| engineer who understands all this, labs for testing and doing
| all the paper work that it entails. So the plan became:
| "Customer buy this software, buy that hardware and put it
| together" => not liable => profit.
|
| _" Is this not exactly equivalent how I might buy a
| Raspberry Pi and install a non-Raspberry-authorized OS on it?
| Or equivalent on how I might buy a PC and install Linux on
| it? Or Android and LineageOS? Are those devices certified not
| only as SOLD but also as modified by the end-user with
| software, making them somehow different?"_
|
| Yes and no :) Very very succinctly: When you test and cert,
| it is best practice to create the worst case scenario for
| your product and pass like with healthy margins. Especially
| for something like a smartphone or PC, when it's in the test
| chamber (for something like radiated emissions), you run it
| at "full noise" (even if it's not a realistic use case). So
| all your clocks: maximum (don't use all of the clocks? Turn
| them all on anyway); Power draw: Maximum or more; Play
| seizure inducing video to exercise that screen; Connect
| peripherals that are likely to be used to make sure those
| don't screw you etc. PCs and phones, especially, are tested
| at these extremes so that the manufacturer can be confident
| that _despite_ what software the end-user loads, the device
| will remain compliant (this is also why the radio firmware is
| kept locked down hard).
|
| Now in the case of this article, sure, the dev boards have
| CE, but what does that mean? How did they test it? Where all
| the peripherals running? What did the physical test setup
| look like? Under CE they are required to keep a compliance
| folder and to provide the information on request.
|
| My experience with, dev boards that are "compliant". They
| just powered it up and maybe ran a simple program. Low
| effort, low noise, easy pass, because the reality is that
| they don't need it and time is money.
|
| So now you a third party integrator takes that dev board, and
| runs something that wasn't exercised or puts it into a state
| that is non compliant. That's on you. Just like it's on the
| Author of this article.
|
| I might be wrong in this case. Maybe the dev boards have
| excellent test setups. I might look at the test docs and
| think: "oh we should be fine". And just do a pre-compliance
| test and self-certify. You have to evaluate the risk each
| time and make a call.
|
| If Microsoft released a patch tomorrow that somehow caused a
| sizable percentage of PCs to start stepping on the cell phone
| bands they would VERY quickly be told (I emphasise _told_ NOT
| asked) to fix it. Just like any software this Author could
| load. They have not sidestepped any responsibility.
| _flux wrote:
| I was actually under the impression that PC motherboards
| have the spread spectrum clock available exactly for
| compliance reasons, and indeed it's the default as well.
| But you can turn it off.
|
| Maybe they do indeed test without it, and it's only for the
| benefit of integrators to make use of (and perhaps disable
| other options altogether), if they find their complete
| system emissions somehow exceed limits.
|
| Now that I'm in position to ask ;), I've wondered about the
| glass/plastic window PC cases.. Surely a PC case itself
| would not be required to have any emission tests done on
| it, or would it? On the other hand, might the PC
| motherboard emissions be certified with the assumption that
| it will be placed inside a case?
|
| And then finally comes a consumer (or even a small
| integrator) and sticks in a PC motherboard inside a
| windowed case--but in this case the case might not be doing
| much on the RF side. Or maybe the cases provide better RF
| protection than they look like or the MBs don't need a case
| for that reason in the first place :).
| negative_zero wrote:
| You are correct on the spread spectrum clocks. Outside of
| military, they really soley exist for compliance
| (specifically unintended electromagnetic emissions) and
| are increasingly everywhere out of necessity. If an
| integrator needs spread spectrum locked on, there is no
| doubt a BIOS available that does just that.
|
| _" Now that I'm in position to ask ;)"_
|
| Ask away :) This is boring for 99.99999% of the
| population so I don't get to talk about it often :)
|
| _" I've wondered about the glass/plastic window PC
| cases.. Surely a PC case itself would not be required to
| have any emission tests done on it, or would it?"_
|
| You're right, a PC case itself does not need EMC
| compliance, but a PC case that's sold with a power supply
| does. So does one with built in fans and lights or
| anything electronic. IMO and very much off the cuff,
| certing the case + lights and fans without a whole
| computer inside is probably reasonable. But I would
| personally try cert with a whole PC (defence in depth).
|
| _" On the other hand, might the PC motherboard emissions
| be certified with the assumption that it will be placed
| inside a case?"_
|
| Yes it can be certed that way. Generally if it is, the
| details have to be in the manual.
|
| But also, legally, you don't really need to cert a
| motherboard because it will always be integrated into
| another thing. However the reality of the PC architecture
| is that it is extremely modular and reach module is
| extremely complex. It's simply not at all practical for
| any systems integrator to try to modify those modules to
| try and make a whole PC compliant so that they can sell
| it. Even sticking the whole thing in a metal case might
| not be enough because the case has cables attached to and
| unwanted emissions and get out via those.
|
| So for practical purposes manufacturers of motherboards,
| graphics cards, PSUs, hard drives etc vigorously test and
| cert their products with decent margins so that no matter
| what cards are used or how a PC is put together, the sum
| will be compliant. And this rule holds pretty well in
| general at all scales, from the individual parts and
| submodules that come together to make a product up to
| several products wired together in your house with power
| and network cables.
|
| And system integrators can demand these requirements
| because it's necessary for the industry to function. I
| found a few years ago on Dell's website their manual for
| part suppliers. It listed every standard they required,
| made stricter and even had additions of their own so that
| they could sell with your module everywhere in the world,
| because they sell everywhere. It basically a thick manual
| on making a computer "world compatible".
|
| _" And then finally comes a consumer (or even a small
| integrator) and sticks in a PC motherboard inside a
| windowed case--but in this case the case might not be
| doing much on the RF side. Or maybe the cases provide
| better RF protection than they look like or the MBs don't
| need a case for that reason in the first place :)."_
|
| And the consumer benefits from everything I explained
| earlier. They can buy parts and assemble a computer that
| will be compliant. It's also why computer shops can build
| you a PC and sell without a cert and it'll be fine. Just
| the sheer effort of all these manufacturers so that they
| have a market to sell into means that the problem is
| solved for small players in the traditional PC world. The
| traditional PC industry is quite unique in that way
| actually.
| HeyLaughingBoy wrote:
| That bit about PCs and phones was surprising, but I guess
| not unexpected. I have built many "EMI test versions" of
| code so various products can be taken to the test house. We
| don't go to those extremes: typically, we'll run as close
| to worst case as we can get, but nothing unrealistic. Then
| again, no one but us is loading code onto our devices, so
| it's not like a PC where you have no control over what it's
| running.
| pjc50 wrote:
| > I assume the author is from the US (as they speak about the
| FCC). I had a 30 second look at these dev boards and their
| instructions. There is no FCC conformity declarations or
| markings, so US customers can't use it.
|
| Just order it off Aliexpress.
|
| It's fine to have a really expensive compliance regime, so long
| as you understand how that drives the small end of the business
| offshore.
| negative_zero wrote:
| Then it's on you as the importer. This is part of why lots of
| stuff on AliExpress and dodgy Amazon 3rd party supplies is
| cheap. It's non compliant stuff that is not even sold in
| China. It's export only, and for the wrong reasons.
| analogwzrd wrote:
| "Author is modifying the product behavior with their software."
|
| I would say that the end user is modifying the behavior of the
| hardware, that they own and are fully in control of, by
| choosing to run software that they purchased. But I'm fully
| aware that regulatory agencies probably have their own way of
| thinking about that.
|
| Point taken about how we need some regulations, but isn't
| everyone sitting in an MBA program right now being trained to
| identify this exact kind of workaround?
|
| As for displaying a device that isn't certified yet, who's the
| victim? What's wrong with saying "We can't take orders on this
| yet, but we're working on getting _cool new product_ certified
| as fast as possible "? The article said _displaying_ a device,
| not turning it on.
|
| From your post, it seems like you're painting this guy as a
| malicious bad actor who going to destroy society when, to me,
| he seems like someone who's trying to find an efficient way to
| sell a solution to people who might find it valuable.
| warkdarrior wrote:
| > we need some regulations, but isn't everyone sitting in an
| MBA program right now being trained to identify this exact
| kind of workaround?
|
| Just because there are some bad actors out there, it does not
| mean that you should behave the same way.
| leptons wrote:
| >"Author is modifying the product behavior with their
| software."
|
| If this were a real concern, then every programmer everywhere
| would need FCC certification for any program they ever write.
| But that isn't the case so far as I know.
| negative_zero wrote:
| See my response to a similar question here:
| https://news.ycombinator.com/item?id=40926103
| Aurornis wrote:
| > Normally, market forces would dictate that by now it would be
| straightforward, fast, and affordable to get your product tested
| as frequently as desired. However, in reality, the labs are "too
| busy" to respond or reply very late and generally sound less than
| eager to work with you. Not to mention, the fees that they quote
| are rarely palatable to a bootstrapping startup.
|
| The various test labs I've worked with haven't been "too busy" to
| respond. However, they are generally hesitant to work with people
| who don't really know what they're doing.
|
| If you are an engineer with knowledge about the process and who
| needs a lab to partner with, it's not hard to get in somewhere.
|
| However, if you don't have the knowledge or experience, the lab
| might sense that you're looking for someone to hold your hand
| heavily through the process. They may be less than enthusiastic
| to take on a one-off customer who might require an abnormally
| high amount of communication and hand-holding when they can fill
| that same spot with a repeat customer who needs nothing more than
| to book the time at the lab and can show up prepared and ready to
| go.
|
| I suggest teaming up with a local consultant for your first
| round. Not only will they help you through the process, they'll
| have connections and reputation to get you into the labs.
|
| The lab fees aren't extraordinary high for a hardware startup,
| really. It's not free, but it's not much relative to the up front
| costs of building hardware inventory.
| fellerts wrote:
| In my limited experience, it was the other way around. I had to
| hold the technician's hand through most of the testing and
| onboard several technicians due to a staggering amount of
| employee churn in the test house. What should take an afternoon
| would take months of intermittent testing at very inconvenient
| times (night slots). Next time I might just show up outside
| their door with a sleeping bag and refuse to leave until the
| tests are completed.
|
| Maybe we were the problem and our documentation was
| insufficient, but we never had a chance to do a "post-mortem"
| with the test house and learn how we could do better next time.
| Rovoska wrote:
| I would be embarrassed to publish this. It is a stunning display
| of ego and ignorance of how this part of the world works that
| boils down to the author being too cheap to put in the work and
| too lazy to understand why regulations exist.
| AnarchismIsCool wrote:
| It's _wild_ to me that everyone here is taking this seriously.
| This is high school science fair level stuff.
| WhereIsTheTruth wrote:
| > I don't need to sell the development boards. I just have to
| tell my customers which boards to buy and how to set them up.
| This way, the electronic device liability will fall on the
| manufacturer, and the magic of ~friendship~ EULA should afford me
| enough protection to make this a pure software play.
|
| Parasite of the economy, right there
| fxtentacle wrote:
| I wonder how much research this person did. At least in Germany,
| cheap DIY kits are everywhere !!!
|
| https://www.pollin.de/p/bausatz-led-wechselblinker-810051
|
| German company selling a German-made electronics kits in Germany
| without CE certification. And they have lots of them:
|
| https://www.pollin.de/bauelemente/bausaetze-module/bausaetze...
|
| As long as you don't connect to mains power and you don't ship a
| finished product, you're exempt from CE certification. So use an
| USB plug as your power supply and sell it as DIY kit to be
| assembled by the customer and you're good to go.
| pjc50 wrote:
| The US and EU regulatory systems are quite different.
| okanat wrote:
| This exact blog also complained about EU regulation and
| selling stuff in EU. I think they basically don't know what
| they are doing.
| pjc50 wrote:
| https://flyingcarcomputer.com/posts/strategy-for-eu-
| bootstra... ?
|
| I agree about the ambiguity of CE marking. It's pretty
| impenetrable as a non-expert. I wonder if he's referring to
| Fabius the Delayer.
|
| > It even made me suspect that it is easier for a non-EU
| country to sell to customers in the EU than it is for an EU
| company to do the same. An advantage that Chinese
| businesses surely enjoy.
|
| 100% correct. There's way too many small parcels for
| customs to check them; the major nuisance is the recipient
| having to pay the tax themselves.
|
| > If one were to incorporate in Estonia but not sell to
| anyone in Estonia, or any member of the European Union for
| that matter, that company would theoretically be exempt
| from a whole cluster of legal and tax headaches.
|
| .. but why would you do that? This guy appears to be a US
| national, he should just register in Delaware like everyone
| else. The Estonian company and "E-Estonia" system is
| primarily useful if you _do_ want to do business in the EU
| and have a presence there.
|
| If you're not in the EU and want a flag of convenience
| company registration, the usual places like Grand Cayman
| offer their services.
| buescher wrote:
| What an odd person. I can't figure the Estonia thing out
| either. I _think_ the idea is to provide plausible
| deniability that the company is operating in the EU??? By
| incorporating in the EU but doing nothing else there? I
| can 't imagine what specific legal and tax headaches one
| would escape that way.
|
| The CE marking is super simple in principle, right? Just
| self-certify that you meet all applicable European
| regulations, and that's when the fun starts. It would be
| impenetrable to do from scratch but as "negative zero"
| points out, you can bootstrap from looking at competing
| products' declarations of conformity.
| ctrlw wrote:
| DIY/parts are a fuzzy area and might not need the
| certification, but the board at your first link does have a
| huge CE print near the LEDs.
|
| Edit: I found this Make article (paywalled and in German) a
| good overview for makers wanting to sell hardware in the EU:
| https://www.heise.de/select/make/2017/6/1513996282631753
| buescher wrote:
| You can find statements and notices and citations and such on the
| FCC web site to see what happens if you get caught out. If you're
| interested in that kind of thing, they're interesting reading.
|
| Here is a pretty bad scenario for apparently willful
| unintentional radiator violations, where an ultrasonic foot bath
| company was at best unorganized and slow to comply with testing
| and labeling requirements:
| https://docs.fcc.gov/public/attachments/FCC-18-67A1.pdf
|
| Here is a better scenario, where an LED sign manufacturer was a
| bit more on the ball:
| https://docs.fcc.gov/public/attachments/DA-22-1136A1.pdf
|
| Note in both cases there is no mention that these devices emitted
| RF above allowed limits for unintentional radiators. These
| companies simply didn't test and didn't label their devices
| appropriately.
|
| Here's one for Asus, where they got WiFi products certified, and
| then changed something, probably firmware, that allowed those
| devices to transmit more power than allowed:
| https://docs.fcc.gov/public/attachments/FCC-24-69A1.pdf
| cwoolfe wrote:
| Yes! And don't forget to somehow encrypt the data on your SD
| cards, or do a check-in with the cloud to activate, otherwise
| your customers can make copies and give away all your software
| for free!
| zkirill wrote:
| I hate DRM and would never do that.
| RecycledEle wrote:
| I have rarely seen someone this happy to add friction that
| prevents his customers from buying his product.
| AnarchismIsCool wrote:
| Ok so as someone working on something vaguely similar (portable
| computer, slightly different market, more RF focus) I assure you
| this person is just rambling on a blog.
|
| Basically everything on their blog/faq ranges from inept to
| dangerously misleading.
| mschuster91 wrote:
| > Variations of the FCC exist in pretty much every developed
| economy. Putting a poorly tested hardware product on the market
| immediately puts a target on your back. Maybe you'll get lucky,
| but chances are that someone somewhere will report you. And,
| unless you are operating entirely out of China, it will hurt. A
| lot. Both your company and maybe even you, personally.
|
| And that for good reason. _Any_ bad actor on the RF spectrum can
| be an actual, significant and _direct_ threat to people 's lives
| - particularly the EMS bands as well as the rail, marine and
| flight safety/coordination channels are absolutely vital. Up next
| is stuff like GPS, radio and television where disturbances affect
| a lot of people, and then there's local stuff like wifi,
| Bluetooth, Zigbee, door openers and whatnot that only affects
| very few people.
|
| Unfortunately it is very, very easy to be a bad actor on the
| airwaves. Powerline/PLC is hated by radio amateurs for a reason,
| and that one is actually even licensed. The other stuff is much,
| much worse.
| iamleppert wrote:
| Is it possible to couple compliance testing with an LLM? I smell
| a new business model.
| andrewstuart wrote:
| This was a missed marketing opportunity to say what the product
| is.
| zkirill wrote:
| Subscribe to the mailing list and you'll be the first one to
| find out! Seriously, though, HN is not my target market. I just
| needed a sounding board. Getting to the front page did grow the
| subscriber count from 7 to 48 people in 24 hours.
| dublin wrote:
| Regulatory certification is a shakedown racket that makes the
| Ticketmaster monopoly discussed a few items down look like a
| friendly environment.
|
| Do you wonder why all of your new electronics are made in China?
| One big reason is that China has its own regulatory labs (which
| may or may not do testing - who knows?) that are literally at
| least an order of magnitude cheaper than getting certification
| done in the US or Europe.
|
| I'm working on two client products now that I and the clients
| would prefer to have made here in the US, but both will be made
| in China because the companies literally cannot afford the
| rapacious cost of getting them certified here. (And China mfg is
| way cheaper, too - partly because of parts distribution models:
| It's literally cheaper to buy a finished product from China than
| to buy the components here to assemble the same product!)
| pedalpete wrote:
| We've been developing a wearable, which is classified as a
| medical device, so we've been looking at the FCC/CE/etc
| regulations for a while.
|
| We're using ESP32s, and are currently going through ethics
| approval, which, from what I understand, means we can use the
| device prior to sale, but maybe we've got that wrong. I can't
| imagine having to have each hardware iteration certified by the
| FCC.
|
| What struck me more about this article is the subject of
| marketing.
|
| For companies that are doing pre-sales, and are still in
| development, and likely haven't been certified yet. Isn't that
| considered marketing? How are other companies handling this?
| We're looking to run a marketing trial in a few months, and
| marketing is part of the recruitment process for a trial.
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