CE Marking & USA FCC 740

Question posted by Kevin Barkey, on behalf of KPG Products Ltd in BN3

Hi we have been selling to the Us for 10 yrs but I am now asked to submit a FCC 740, is this required if our product is CE marked & EMC tested?

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John Showell, on behalf of Product Approvals Ltd in TF2.

Hi

As you've been asked to fill in an FCC 740 form, I assume your product is - or contains - some kind of intentional radio frequency transmitter?

We assisted a customer in South America that developed a product containing a short range RF transmitter circuit and I advised them to fill in an FCC 740 form.

Also advised them that they needed to get the appropriate FCC testing done as it was an intentional RF transmitter. I recently helped review test lab quotes for EU & FCC RF testing. EU CE mark and EMC testing does not cover the FCC requirement.

I think the FCC / US customs are policing this more and more. My advice would be to get the appropriate FCC testing done and fill out an FCC 740 form to avoid problems.

Hope this helps.

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Kevin Barkey, on behalf of KPG Products Ltd in BN3.

Hi John
Much appreciated, the product is a laboratory cell counter/calculator & has 2 versions M+ has Memory & data output via RS232 cable. It was tested: EMC Emissions / Interference & Safety. So what part would not be covered under FCC?

Note have been shipping this to US for 4-5yrs with no problems

Many thanks

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John Showell, on behalf of Product Approvals Ltd in TF2.

Hi Kevin,

You're welcome.

Normally the FCC testing is related to EMC emissions (rather than immunity) and there is some harmonisation with EU EMC emissions. If the lab cell counter/calculator has no wireless transmitter i.e. radio transmitter function, and data is outputted purely by RS232 cable then the FCC form 740 may not be needed. However FCC compliance still applies but it may be possible to self-declare to the relevant FCC part and utilise your EU EMC test data.

I think US customs officials are becoming more aware of FCC approvals requirements. You may well have no issues at all for the foreseeable future. However you could get a US customs/FCC inquiry about your product at some time, in which case it would be advisable to address the issue in the not too distant future and be prepared for that. The requirement may just be solved by a statement in the product instructions and possible an FCC related statement on the packaging.
Regards,
John

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