Speaker 1: Hi, thanks for joining us today at Compliance Testing. This is our second podcast of the year, and today we'll be covering the FCC approval process and regulatory test labs. Joining me today is Matt, who is our Director of Emerging Markets. Matt, do you want to tell us a little bit about what you do here at CT or Compliance Testing?

Speaker 2: Sure, I mean, it's pretty easy. My role is to make sure that the clients are seeing a seamless, efficient experience when they come in with a product that is almost ready to go to market, but has to tackle those remaining hurdles, the regulatory hurdles, before they're ready to get started marketing the product. So everything I do is based on making sure the product gets through quickly and efficiently.

Speaker 1: Great, well, thanks for joining us today, Matt. We at CT are an ISO 17025 and ISO 17065 test measurement and certification lab. We're based out in Phoenix, Arizona, which is exploding in emerging tech, manufacturing, a lot of activity here, so it's a fun time to be in the Valley. And we do testing for the FCC, Canada, EU, and many organizations. So our objectives today, we're going to cover what type of devices need the FCC approval, how does the FCC approval process work, what products or devices require FCC certification, what does the approval process entail, how can a trusted regulatory test lab like CT help, and what to look for in a regulatory test lab as well. So who this content is for, I won't go over the list, but electronic device manufacturers, that's a broad scope, IOT, IIOT, wearables, and many different industries with sensors, medical devices, biotech, renewable energy devices, you name it if it has an antenna. So Matt, let's start off, what needs the FCC approval?

Speaker 2: Well, this is another easy one. So anybody who has an electronic product that they're hoping to sell or manufacture in the United States has to make sure that they're getting this testing done. So it will apply to everybody who falls under that very broad bucket. There's a specific set of guidelines regarding electronic goods sold or produced in the United States. You can find them on the FCC website, but you can't necessarily figure them out. So that's why we're here, that's why we're doing the podcast, and that's why you always wanna reach out to your friendly neighborhood compliance lab.

Speaker 1: Great, yeah, I always hear in the industry, even people who have been in it, we have an engineer that's been in this industry for 42 years and people with that tenure still don't understand compliance fully. It's definitely tricky, so always helpful to get some support. Now, let's go over the overview of FCC guidelines. Can you talk a little bit about that?

Speaker 2: Sure, so talking about RF devices, so like you said, anything with a radio in it, those are required to be authorized under 47 CFR part two. Don't worry about all the numbers. Again, you can find that stuff on the FCC website, but basically there's a chapter that's for devices with radios, which are considered... So there are unintentional and intentional radiators. We're talking about intentional radiators. So essentially the program is one of the principal ways that the commission, the OET, ensures that RF devices are used in the United States and are operated effectively without causing harmful interference and otherwise comply with the commission's rules. Again, we help you figure those out. Any equipment that contains an RF device must be authorized in accordance with the appropriate procedures specified in 47 CFR part two. These requirements not only minimize the potential for harmful interference, but also ensure that the equipment complies with the rules that address other policy objectives, such as human RF exposure, which we are still learning more about, and hearing aid compatibility with wireless handsets. So essentially what you're trying to do is make sure that your device is not interfering with all the other electronic devices out there because of the signals and radiation that it's emitting.

Speaker 1: Now, what does that mean to me if I'm an electronic or wireless device manufacturer? Because sometimes we run into these newly funded startups, they're excited for accelerated growth, and then they kind of find out about compliance along the way, and they say, okay, well, what happens if I do it? What happens if I don't do it? So how does it impact a manufacturer like that?

Speaker 2: Sure, so like I said, this is a regulatory thing. So you have to do it, or else you run the risk of fines, having your product pulled, things like that. So essentially, you're right, that there are startups and smaller companies that they think the development cycle is the end all and be all. And when they get to the end of that, they think, great, I'm ready to sell the product. I have these retailers set up and resellers and technology partners, not realizing that there is this regulatory step that comes next. And like I said, that is to ensure that you meet these standards to make sure that your product doesn't interfere with somebody else's. So whether it's other consumer products, industrial products, whether it's interfering with government operations, the whole point is to make sure that your product doesn't necessarily turn anybody else's off or interfere with its use. So you can play around with it in your lab all you want, and you might think it's going really well, but the point is you have to bring it in and have it tested to the proper standards, which again, a compliance lab can help you do.

Speaker 1: That's great. Now that's helpful info. And we work with clients all the way from that newly funded startup to mid-market to enterprise. Do you see any different needs or a different type of client journey depending on the size and where a manufacturer is?

Speaker 2: Absolutely. So if you're a large brand name company that many of us have heard of, then odds are you have a compliance team, right? There's probably a compliance officer and compliance engineers, and they've been doing this for a long time. So they understand what all the requirements mean sometimes just as well as the test labs themselves because they're constantly doing this. When you're more of a startup or a smaller company, you may not have anybody who's trained in this. It might just fall into your lap. You're a design engineer. You're a BDM. You're just somebody who works in the company and maybe you worked with the FDA or somebody in the past. And so they say, okay, this is going into your lab. You now have to deal with this. And it really is kind of a strange world out there full of acronyms and numbers and rule parts that you may not understand. So I think whereas the larger companies are more worried about things like the bottom dollar and the bottom line, the smaller companies really do need a lot of handholding to figure out what do the rule parts mean? What do they apply to? Where does my product fit in? And what is the process gonna look like? How much time is it gonna take me to get this done? If my marketing team wants to get the product out in two months, can that be done? So that's sort of the difference in the different kinds of companies that we come into contact with at CT and other compliance labs.

Speaker 1: Now that's helpful. So it's more of a true partnership, especially as that company grows. And then in mid-market, it's more I think about efficiency relationship and turning things around and coordinating those schedules. That's good. So let's move on to the next topic. How does the FCC approval work?

Speaker 2: Sure. Well, okay. So it has these different limits. All these different rule parts are based on the type of radio frequency that a product emits. So one, it's based on the technology, right? You could have a Wi-Fi in a certain band, Bluetooth, maybe some RFID or maybe some ultra high band stuff. Once the type of radio frequency is identified, the FCC begins testing the electronic device or in this case, FCC approved labs to ensure that it's in line with the standards. I don't know if you've talked about radio frequency in the past on another podcast, but it's a really interesting subject, how these frequencies work, how they're doled out, the auctioning that happens. So that would be an interesting topic in the future. Oh, absolutely. Essentially your product is going to be using a certain signal band, a certain frequency band and the different standards are gonna depend on which bands you're using. Any electronic device that's manufactured, sold or distributed in the US, again, requires approval from the FCC. To receive this coveted seal of approval, I like this verbiage, your product must pass FCC testing and stay within radio frequency limits imposed by the FCC. So again, the FCC has asked a number of different labs to do this testing and apply for the certifications on their behalf. They decided some years ago, they didn't necessarily wanna be in the game of compliance. Better to farm it out to other labs and let us do the dirty work on their behalf.

Speaker 1: Absolutely. And it's funny you mentioned the auction and the bands. I find that so interesting too. I follow it on social media. I've seen a lot going on with the FCC and Twitter and repurposing different bands and all of that. So that's a great idea. That's definitely gonna be added to the list for our next topic. Thanks for that. And then what do you see as far as clients coming to us? Do they usually have the correct standards identified to test and measure to or no?

Speaker 2: No, often what they have is they know what technology they're using. And that's about as far as it goes, right? They know they're using a chip set that has both Bluetooth and Wi-Fi on it, whether it's BLE or the most up-to-date Bluetooth standard. They'll know that much information, but then it's up to us usually to let them know then what standards are going to apply, what the testing is gonna look like, including the entire process with our lab, not just what the FCC requires. Turnaround time, quoting, everything like that. So they don't necessarily have standards identified. Usually they do know at least what the technology is contained within the product. And that's enough for us to figure out the rest.

Speaker 1: Okay, good. That's helpful. When I first entered this industry, that was a question I always was curious of. So thanks for answering that one. Let's move on now. What products require FCC certification?

Speaker 2: Yeah, so sort of like you said in the beginning, not only does it apply to a broad range of verticals and industries, but product types as well, right? So like we said, anything with a radio, that's an easy one. If you're gonna be broadcasting wirelessly, then that's how you're gonna have to come in. So that could be power adapters, anything that's a Bluetooth device, remote control transmitters, a lot of IT equipment these days. For example, I'm just gonna look at my desk here. I've got a laser printer that communicates wirelessly with my laptop. I've got two laptops actually and a monitor. I've got Bluetooth mouse and keyboard. I've got a number of headsets and earbuds that are Bluetooth. So all you have to do is kind of look around and you'll figure out that almost everything on your desk, in your home, especially with all the smart home stuff these days is going to apply. Very few things these days are made that don't apply to these basic standards. So like you said, almost everything.

Speaker 1: And that's so cool. I know our engineers love seeing cutting edge technology come into the lab and it just expands our scope about what really does fall into these categories. It is pretty broad. I see so many wearables, biotech, medtech, medical devices. Just such a wide variety of products is interesting. It's always very cool and insightful when the engineers run back in the office or send pictures of some of the devices they test.

Speaker 2: Right. And this is just so, this is the consumer environment, right? Where I'm sitting right now. But like you said, it could be industrial. It could be medical. Almost everything's connected in some way these days. So again, it applies to so many different things and technology that we haven't heard of yet, right? New innovative technology that we can't even necessarily name is being developed right now. And they're gonna need to go through these standards and develop new standards for those technologies as well.

Speaker 1: Yeah, smart cities, smart appliances, and industrial, you mentioned that. I know we see some oil and gas sensors, smart agricultural devices. It's very eyeopening when you think of the application of these. And then the data, everything's producing too from all these connected devices. It's mind blowing. Okay, what does the approval process entail with the FCC?

Speaker 2: Sure. So before submitting your product for approval, you first need to ensure that it's radio frequency emissions don't surpass FCC limits. Next, it's usually a good idea to run pre-compliance tests just to make sure that the product is operating well in your lab or in a lab of your choice before you bring it in for your certification. What you don't wanna do is have a failure and delays and you're talking to your marketing team and your boss and trying to get everything worked out when you could have upfront figured out that there was an issue. So we always offer pre-compliance scanning, design reviews, things like that, to make sure that ahead of time, you're understanding what the issues might be with your product.

Speaker 1: What's that timeline look like? When should these manufacturers engage somebody like us? When should they start thinking about pre-compliance so they don't delay their production cycles and market access times?

Speaker 2: So there are a couple of things that we can do for a client. One is we can base it on specs and diagrams, right? So if you don't have a working prototype yet, but you have an idea of what the design's gonna look like, the technology involved, we can do a design review based on that and say, okay, if you're not gonna make any changes based on these diagrams, these are the standards that are gonna apply. These are the risks associated. And that way you have an idea ahead of time of what the whole process is gonna look like. If you are already at the prototype stage, it's definitely a good idea to get that into a lab, see how it operates in a real environment against FCC standards, because you may think that you have everything worked out in the lab, in your design lab, but once you get it into a compliance lab, you might find that the equipment that you used isn't necessarily in tune. There could be all kinds of issues in terms of figuring out whether it's compliant. So we can do that for you as well. So we can do design reviews, we can do pre-scans, and that way you have that level of comfortability when you're ready to actually get started with the approval process.

Speaker 1: So the sooner the better, probably around the time of prototype, maybe even beforehand might be a safe call. Does that sound right?

Speaker 2: Absolutely, because if you're gonna go for the full certification process, if you're gonna bring it in, do pre-scans, do the actual certification testing, and then have us file on your behalf with the FCC, I like to prepare clients, it could take six to eight weeks. We could do it faster, it's possible, but there are certain delays built in in terms of writing reports, submitting, waiting for the FCC. You definitely don't wanna wait until you are almost at launch, right? You wanna make sure that you're giving yourself enough time to get everything done in proper order. Easier said than done, talk to any of the clients that I work with on a day-to-day basis, they're being pushed in a million different directions. Things are changing on their end, technology's changing. So always difficult, but yes, the soonest you can possibly bring it in, if you have an idea of what that product's gonna look like, the better off you'll be.

Speaker 1: Great advice. All right, I just wanna talk through this little step-by-step process to kind of consolidate and give people a summarized visual of what you just mentioned and went over so well. So the process, kind of the first step would be determining the FCC rules that apply to your product, like we discussed. Then once we do that, we would determine which equipment authorization procedures are required for that product. We'd perform the compliance testing at an authorized testing laboratory, like ourselves, compliance testing, or a trusted one in your part of the country, region, or world.

Speaker 2: I was gonna say, I know a good one.

Speaker 1: Yeah, me too. Me too, I've heard of one. And then the next step there is once you test with a lab, like compliance testing, we would then obtain the required approval to get you market access. We'd label that product with the required information and include compliance information in the user manual for that device. And we'd also maintain compliance information records going forward too. One thing that's often overlooked is that document management and as a ISO certified and accredited lab, that's something that we have to do. Next, we would ready the manufacturer, which would be you, our target audience listening today, and then import and market your product. And then as you go forward, we would have to support and review modifications to approve products as well. Do you wanna talk a little bit about that, Matt?

Speaker 2: Yeah, so obviously you've designed a product, you've gone through the initial testing, you're marketing it, it's going great. You wanna introduce a new model with a few tweaks. That's something that you're able to bring into us as well. Sometimes these things are able to be certified as families. It sort of depends on what technology is being changed. So we can always modify the products if you need to do any permissive changes with the FCC is something that's kind of a scary word that you might hear every once in a while. Oh no, which permissive change is it gonna be? That's something that we can guide you on as well. And I should also mention that we're a TCB, we're a technical certification body as well. Any services relating to that we're able to handle at CT. But labeling, you mentioned, very important. That's something that even large corporations that are used to doing a lot of compliance work often need a lot of guidance on. It's never really exactly clear what's gonna be required and where it's gonna be required either on the packaging or the user manuals or the product itself. So that's definitely something that people often need a lot of help with.

Speaker 1: Okay, that's very helpful. And we do so much work with so many manufacturers too that market access is so important and that's the process to get there. So how can a trusted regulatory test lab like compliance testing help? What's the big value add there?

Speaker 2: Sure, so like we talked about, you're a startup, you just sort of started to find out about the regulatory procedures that you're gonna have to follow to get your product to market. We're gonna be able to kind of hold your hand through that process and make sure that, like I said in the beginning, we wanna give you the most efficient path possible. Whether that means cutting down on time, cutting down on cost, cutting down on retesting, those are the things that we're gonna be trying our best to do. And as long as we're communicating correctly between ourselves and the client, we feel confident that that's something we can provide every time. Like you mentioned earlier, we're ISO certified, audited, we're accredited agents on behalf of agencies like the FCC, the IC in Canada, European Union, UK, and we're able to provide certification services for the rest of the world as well through partners. So we're able to get you to market anywhere you need to be as fast as humanly possible.

Speaker 1: Yeah, so I think one of the things that I enjoy seeing the team do is what I hear feedback on sometimes, and there's some great labs and we partner with several of them. A lot of our team members have been lucky enough to grow in their career through several of them. But I also hear sometimes that some labs may be top heavy on the sales side or top heavy on the engineer tech side. The one thing I think we pride ourselves on and just the great team we've built is I feel we're really strong on both. Great client experience, great client journey, small mid-market enterprise all the way up. So it's really, it sounds like for a lab like ours or another high-performing lab, it's trust, it's partnership, it's setting expectations, communication, and things like that.

Speaker 2: 100%, yeah. I mean, I think just talking about what to look for in a certification lab, the complaints I hear most often about my clients with their current lab relationships are just the feeling that they're not partners, that they're not treated like partners, that they're not treated like their work is important, probably because there's some other bigger company who's either taking up lab time or engineering headspace or whatever it is. And they've kind of been relegated to the side. And that's something that you only have to put yourself in your client's shoes for a few seconds to understand how that would feel. So that's probably the number one complaint that I received from clients about their current lab relationships and why they've come to CT in particular to ask us about what we can do for them. But there's a number of different things that you should be looking for if you're gonna choose a certification lab. So obviously capacity is an issue with some of these larger labs, right? There's seasonal capacity. You wanna make sure that your product can get in when you need it to be done and that your lab's able to accommodate projects on the pace and the schedule that you're looking for. You definitely wanna make sure like we talked about that this is an accredited lab, either with ANAB or A2LA. Definitely go through a scoping process with your lab for a project. Figure out whether or not they're giving you information quickly, whether they're having to change the information over and over again, whether you're having to go back and forth with a lot of questions and follow-up, because you wanna make sure that you feel comfortable that these people know what they're doing, that they're providing you with the correct information upfront about what the product test strategy is gonna be for your product. Definitely you want support during test failures. They happen, right? You bring in your product. It looks good in your lab. It fails the first round of testing. It's good to know why that might be happening. We can't provide design advice, but we can definitely tell you why the product isn't necessarily hitting the standards that it needs to, which will help you to go back to your lab and figure that problem out quickly. Hopefully you don't have to do too many retests. And then, like we said, a strong relationship with the entire team. So not just your salesperson, somebody in my position, but also with a project manager, you're able to reach the engineers when you need to and get advice from them. Just being able to work with the entire team and have kind of a cohesive project process is very important as well.

Speaker 1: Yes. And it takes people to do that. And again, so grateful that we have a great culture. We live the values we have and very much client-focused. And I know everybody says that, but I'm happy that we're living it as well. And a lot of other labs around there do as well. So it's very important to all of you. Make sure you do your due diligence. Look for a credible lab. It's about relationships. It's about true partnership. It's about picking up a phone and being able to get ahold of somebody and getting a transparent, accurate snapshot of how we get through this process together.

Speaker 2: Yeah, this is an important step in your product journey. You wanna make sure that you're with people who are gonna be able to do a good job. So I always encourage you, do a trial project, go through the process in real time and figure out whether it's something that works for you, whether the team works for you, whether the lab works for you. And hopefully you find the right one.

Speaker 1: So thank you for taking the time to join us today. Matt, thank you for joining us and taking your time on the podcast. We really appreciate you listening to this content. We hope it was helpful for you. Again, it's very important to find a true partnership, a relationship when finding a high-performing, credible test lab. You wanna be able to pick up the phone, get somebody on the other end, quick responses, transparent and accurate information with solutions and paths forward. We wish you the best of luck on your product life cycle journey. Thanks for joining us today. Matt, any closing comments? No, good luck everybody. It's a difficult world, but we're here to help. Well said. Thanks everyone. Take care, we'll see you next time.