[peteforde]

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]

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/GetPublishedDocument.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.

[HeyLaughingBoy]

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...

[negative_zero]

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]

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.

[negative_zero]

Excellent additions. Sadly for Canada, some companies I worked with didn't bother because of these differences. "US market is big enough for launching. Maybe we'll come back to Canada later." They rarely did.