How would you like your customers to receive a citation letter from the Federal Communications Commission (FCC) like this one:
“This CITATION AND ORDER (Citation) notifies Thomas Edward Rogers (Mr. Rogers) of his obligation to stop operating devices that are causing interference to licensed radio operations and to comply with federal rules and regulations related to radio frequency devices. This includes consumer and industrial devices such as lighting ballasts that utilize radio frequencies in their operation. […] Failure to take action to resolve the interference may result in severe penalties, including fines of up to $16,000 per dayi.”
For many years, the lighting industry did not have to worry about FCC rules and regulations. But with the introduction of fluorescent lamps and fixtures, and the explosion in popularity of LED technology, the FCC and Industry Canada have become relevant regulators. Like it or not, lamp manufacturers are now immersed in the world of Radio Frequency Spectrums, and find themselves under the governance of regulatory bodies around the world. And for designers who are incorporating wireless technologies into their lamps, the rules are even more complex. How can lighting manufacturers ensure that they are compliant and avoid unnecessary headaches for their customers?
Understanding the Authorization Scheme
The FCC has two rule parts that apply directly to lighting devices. Part 18 applies to fluorescent lighting and Part 15 applies to LED lamps. Generally speaking, all aspects of non-incandescent lighting are governed by these two rule parts:
Lighting devices such as fluorescent lamps, compact fluorescent lamps (CFLs), and fixtures are governed by the Industrial, Scientific and Medical (ISM) regulations contained in FCC Rule Part 18. Non-consumer ISM equipment is authorized under the Verification procedure, while consumer ISM equipment requires either a Declaration of Conformity or a Certification to meet the conditions of authorization.
Unlike fluorescent fixtures, LED lamps are solid-state devices that radiate radio frequency energy unintentionally, so they fall into FCC Rule Part 15. Since the switching-power circuitry driving LEDs operates at high frequencies, when it is not properly filtered, electromagnetic interference can result. This interference has become a significant concern to the FCC and the EPA (in the scope of its ENERGY STAR® program). Depending on the nature of the device, LED lamps falling into Part 15 are authorized through a Verification, Declaration of Conformity, or Certification.
The Complexities of Incorporating Wireless Technology
LED lighting manufacturers must now resolve radiation issues for both their lighting fixtures and any wireless technology that controls the fixtures. It is well known that wireless devices must be tested and certified to be marketed in the United States. Because LED lamp designers integrate their radio chips onto internal circuit boards, certification of the lamp as a wireless device becomes necessary.
Depending on the specific radio technology and frequency range, the product can fall into different rule parts. For example, a ZigBee and 2.4GHz Wi-Fi radio almost always fall into FCC Rule Part 15.247. Generally, Bluetooth technology falls into Part 15.249, and the 5GHz Wi-Fi radios fall under Part 15.407. Devices with multiple radios can fall into multiple rule parts simultaneously. And each of these has different rules for compliance. Authorization tends to rise in complexity on a geometric scale as the product increases in complexity on a linear scale.
Get in touch for more information on how ACS can help you enter the FCC world.
So What’s a Compliance Manager To Do?
There are a number of ways to work with the FCC/Industry Canada and avoid complications and potential fines from unintended and harmful LED radiators:
- Learn the FCC/Industry Canada’s mandatory LED testing and certification requirements
- Partner with a capable test lab that provides wireless testing and certification services
- Discuss your compliance questions with the test lab experts:
- What standards apply?
- What are your responsibilities?
- What are the labeling requirements?
For lighting manufacturers, understanding and complying with FCC regulations is a necessary hurdle. It is worth the effort to research and adapt, rather than to incur the penalties.
iFederal Communications Commission. (2014). Incidental Radiator Causing Harmful Interference (FCC Citation No. C201432980003). Washington, DC.