In order to sell electronic/ Wireless products within the United States of America, products must be certified in reference to the relevant legislation under FCC, OSHA, CPSC, DoE and other Federal and States law requirements. Else, suppliers can be exposed to fines and blocking in the custom.
This article will touch base of the most common Federal & States law requirements:
- FCC – EMC – Electromagnetic compatibility Directive
- FCC – Radio Certification
- OSHA – Product Safety in reference to UL-Standards
- CPSC – Consumers commission
- Sustainability – Federal & states law general overview
Manufacturers and their supply chain carry a legal liability to follow the relevant legislations subjected to their product intend of use and technology.
The Federal Communications Commission (FCC) regulates all Electronicsand Wireless products in all 50 states and other USA territories. Any Electronic device must be in Compliance with FCC regulations and any Intentional radiators must have FCC ID.
Main FCC requirements are:
All electric devices or installations influence each other when interconnected or close to each other, e.g. interference between TV sets, GSM handsets, radios and nearby washing machine or electrical power lines. The purpose of electromagnetic compatibility (EMC) is to keep all those side effects under reasonable control. FCC EMC rules refers only to Radiated & Conducted emissions.
FCC radio certification is required for placing radio equipment on the market.
Any Intentional radiator should be tested and submitted for a TCB review ( the responsible party by the FCC to review the request and to submit the product under the FCC Website with his own FCC ID).
The process includes the following:
- Testing – In band and out of band Radio tests i.e. Bandedge, Mask , PSD, Peak gain, Spurious, etc.
- Grantee code and FRN under FCC in order to establish an account and issue FCC ID
- File submission – 20+ items for TCB review depends on the type of certification
- TCB review
SAR – Specific Absorption Rate
Whenever the radio device used as a portable device with a distance < 20cm from the user, than SAR tests need to be determined. In any other case SAR assessment will still be needed.
Whenever using already certified module, it’s the host manufacturer responsibility to verify that the integration in the final host device meets FCC Grantee limitation such as RF Exposure, Multi transmitters procedure and so on.
The host manufacturers should keep records and declare under the SDoC procedure that he in Compliance with all requirements.
The SDoC is a legal liability, and besides the company to be signed on, it should also include the company local representative details within the USA.
See explanation on SDoC procedure:
Product Safety – UL Standards
The Occupational Safety and Health Administration (OSHA) is an agency of the United States Department of Labor.
OSHA’s Nationally Recognized Testing Laboratory (NRTL) Program recognizes private sector organizations to perform certification for certain products to ensure that they meet the requirements of both the construction and general industry OSHA electrical standards. Each NRTL has a scope of test standards that they are recognized for, and each NRTL uses its own unique registered certification mark(s) to designate product conformance to the applicable product safety test standards. After certifying a product, the NRTL authorizes the manufacturer to apply a registered certification mark to the product. If the certification is done under the NRTL program, this mark signifies that the NRTL tested and certified the product, and that the product complies with the requirements of one or more appropriate product safety test standards. Current List of NRTLs >> Link
Most of OSHA standards are based on UL-Standards, therefore it’s important to distinguish between UL lab which is one entity among other NRTL’s, to UL-STD ( Standards).
UL-STD ensures that electrical equipment within certain voltage limits provides a high level of protection for the user.
Obtiaing the NRTL mark required first and quarterly factory inspections.
Sustainability , Environmental & Recycling Directives:
The Consumer Product Safety Commission (CPSC) is charged with protecting the public from unreasonable risks of injury or death associated with the use of the thousands of types of consumer products. CPSC’s work to ensure the safety of consumer products – such as toys, cribs, power tools, cigarette lighters, and household chemicals.
- California Proposition 65
Proposition 65 requires businesses to provide warnings to Californians about significant exposures to chemicals that cause cancer, birth defects or other reproductive harm. These chemicals can be in the products that Californians purchase, in their homes or workplaces, or that are released into the environment. By requiring that this information be provided, Proposition 65 enables Californians to make informed decisions about their exposures to these chemicals.
Proposition 65 requires California to publish a list of chemicals known to cause cancer, birth defects or other reproductive harm. This list, which must be updated at least once a year, has grown to include approximately 900 chemicals since it was first published in 1987.State law requires any person suing “in the public interest” to enforce Proposition 65, to notify the Attorney General of the lawsuit and outcome of the case.Link to Enforcement reporting >>
- There are also other State laws such as NJAC 13: 1E-99.94, which should be evaluated per State.
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