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LED Ticker Displays and FCC Certification

FCC Certificiations

Buyers of LED stock ticker displays need to be aware upfront of issues that may impact them, regulatory issues, performance and serviceability, and total cost of ownership. Unlike going into a big box store and buying a consumer-grade flat panel display, there are layers of proper due diligence that must be addressed to make the best direct view LED decision for your application.

The LED display market is growing exponentially in both outdoor and (most significantly), indoor applications. As LED display pricing is moderating and becoming more understood, sales are becoming more pervasive but also more complex. Historically, end users buying large outdoor displays would work directly with manufacturers. With the expansion into fine pitch indoor products, we are increasingly seeing direct view LED provided through resellers and systems integrators to an expanded end user community with unique needs.

Pursuant to the measurable increase in demand, we see a literal wave of direct view LED manufacturers and suppliers attempting to fill this newly created void. This rush to market by a plethora of unknown providers is a key factor in the complexity and confusion we are seeing. It is a fact that most direct view LED products are produced in Asia. This is true for the LED diodes as the core component, as well as the assemblies and modules that make up the RGB displays. According to Made-in there are over 2,000 manufacturers and over 6,000 products that fall under the heading of LED displays. It is not difficult to see where the confusion might lie, in terms of selecting a product for your applications. There are huge differences in the discrete LED diode itself, and even more so with the end products from the manufacturers that fall into this category.

Manufacturers range in size from truly tiny operations with a few people all the way up to full factories with manufacturing, testing, and quality control such as Sunrise Systems. What further complicates the manufacturer selection process is that one product may look like another on the surface, with the “apparent” difference being dot pitch. Suffice it to say that appearances can be deceiving.

We have mentioned the numerous sizes of companies that consider themselves LED display manufacturers. Sorting out one from another is difficult, but a good place to start is in qualifying as part of a manufacturing management standard. A quality management system (QMS) is a set of policies, processes and procedures required for planning and execution (production/development/service) in the core business area of an organization. (i.e. areas that can impact the organization’s ability to meet customer requirements.) ISO 9001 is an example of a Quality Management System. It is an internationally recognized Quality Management System and is the only ISO standard that requires certification.

A second sorting out of vendors is to look for those that exceed the ISO 9001 standards. Beyond meeting the minimum standards are those that go above and beyond in terms of quality. For those select few, this directly relates to overall design, increased mean time between failure (MTBF), redundancy, and serviceability.

The design of the display is about much more than pixel pitch. Design also refers to the panel configuration, power supplies and electrical connections. This also speaks to serviceability. To the first order, this establishes how serviceable the design is and how easy is it to access replaceable components, and finally how much time is required to conduct maintenance. One major part of the service issue is whether full service to the component level is available in country with authorized service centers and a full complement of spare parts. It is also critical to understand what the typical turn-around time is. This falls under mean time to repair or MTTR.

One potential “deal breaker” in the list of items to consider, is a product meeting applicable regulations and standards. This is often assumed as being in order and that some regulatory agency has checked to make sure that all is in order. Products being brought into the USA must meet certain standards, and many are done in the factory at the manufacturing and testing levels with quality control. Here is a list of standards that are met by quality manufacturers such as Sunrise Systems.

  • CE Mark – CE-marking is a mandatory conformity mark required for a wide variety of products sold in the EU. CE-marking indicates that your products comply with stringent EU product safety directives.
  • UL Compliance – UL Standards are used to assess products; test components, materials, systems and performance; UL is accredited by the American National Standards Institute (ANSI) as an audited designator.  Two significant standards for the LED ticker industry are UL- 1950 and UL60950 which addresses construction and performance criteria with the intent of reducing the risk of fire, personal injury, and electric shock.
  • ETL Mark – The ETL Mark is proof of product compliance to North American safety standards. It is OSHA Recognized NRTL in the U.S.
  • FCC – Code of Federal Regulations, Title 47, Part 15 Class A. It regulates everything from spurious emissions to unlicensed low-power broadcasting. Nearly every electronics device sold inside the United States radiates unintentional emissions and must be reviewed to comply with Part 15 before it can be advertised or sold in the US market.

Much of the testing and compliance of all the above regulations is conducted by the manufacturers at their respective facilities, often with their party testing verification. When done within the scope of work of each regulation, they are intended as a guarantee that a product is safe and that it adheres to the dictates and limitations of a given standard. While each standard has their own degree of complexity, it is the elusive nature and lack of proven compliance of the FCC standard that prompts his article and prompts the admonition, let the buyer beware. We will work from the top down and build the case for this concern.

The Federal Communications Commission (FCC) is an agency of the U.S. Federal Government structured under Chapter I Telecommunication 47 Code of Federal Regulations. The FCC oversees the management of the radio spectrum in the US. One of the mandates of the agency is to protect against “radio and broadcast pollution” and regulating electromagnetic interference (noise) sources.

Electromagnetic interference (or EMI) is the disruption of operation of an electronic device when it is near an electromagnetic field in the radio frequency (RF) spectrum that is caused by another electronic device. The concern and propensity for noise is when RF signals are in the vicinity of one another. One intrudes on the other. Going back to the laws of physics we know that as electric current moves around inside an electrical product, the current will produce electromagnetic field waves that will travel through space. All electric and electronic systems and equipment generate signals that could potentially interfere with the normal operation of another nearby piece of equipment. Also, EMI can degrade the performance of equipment, introduce errors or operational faults, or cause complete failure.
Specific FCC regulations apply to any electrical and electronic products that do or may produce radio frequency pollution or EMI. There are two main product categories that are covered: “Intentional Radiators” and “Unintentional Radiators”.

As the term suggests, an intentional radiator is a device that is intended to emit radio energy. This includes, among many other products, Cell phones, Tablet PCs, Wi-Fi routers, Walkie talkies and Bluetooth headsets – essentially any item whose operation depends on transmitting radio waves. Compliance with FCC regulations is mandatory when importing products classified as intentional radiators and must therefore undergo an equipment authorization procedure.

Unintentional radiators are a bit more complex and not as obvious to the casual observer. An unintentional radiator is, as defined in 47 CFR 15.3, any electrical device “operating at over 9000 pulses per second (9 kHz) and using digital techniques”. This definition includes most electronics containing a chip, even if the device is not equipped with a Wi-Fi or Bluetooth transmitter. Unintentional radiators are also electronic digital or radio devices that produce radio signals that are not central to their intended use. For our purposes, this section includes LED or digital signage.
The FCC requires that any electronic product covered by their regulations undergo an “equipment authorization procedure”. It is important to note that it is illegal to import, sell, or lease equipment FCC regulated equipment that has not undergone the required equipment authorization procedure. The penalties are not insignificant. The stakes are high when importing electronics to the United States. So, what could happen if you are caught importing non-compliant electronics? Below is a summary of non-compliance penalties:

  1. If the FCC finds that you have willfully or repeatedly violated the Communications Act or the FCC Rules, you may have to pay as much as $10,000 for each violation, up to a total of $75,000. (See section 503(b) of the Communications Act.)
  2. If the FCC finds that you have violated any section of the Communications Act or the FCC Rules, you may be ordered to stop whatever action caused the violation. (See section 312(b) of the Communications Act.)
  3. If a Federal court finds that you have willfully and knowingly violated any FCC Rule, you may be fined up to $500 for each day you committed the violation. (See section 502 of the Communications Act.)
  4. If a Federal court finds that you have willfully and knowingly violated any provision of the Communications Act, you may be fined up to $10,000 or you may be imprisoned for one year, or both. (See section 501 of the Communications Act.)

Keep in mind that it’s always the company importing the items that is responsible to ensure compliance with all applicable regulations.

Per the FCC regulations on unintended radiators of EMI, manufacturers must comply with the radio pollution limits and equipment authorization procedures. Herein lies the problem. There is no FCC verified compliance certificate before a product is brought into the country. As one observer pointed out, it is an “honor system with teeth after the fact” if a product is found to not comply. This self-directed testing program mandates that digital signage must be independently tested and verified according to FCC standards to be compliant. The manufacturer is responsible to archive the test procedures and results and are asked to produce this if non-compliance comes into question.

This now falls under what is called the FCC Declaration of Conformity. The FCC Declaration of Conformity or the FCC label or mark is a certification mark employed on electronic products manufactured or sold in the United States which certifies that the electromagnetic interference (EMI) from the device is under the maximum limits approved by the Federal Communications Commission. The Federal Communications Commission established the regulations on electromagnetic interference under Part 15 of the FCC rules in 1975 and they were reconstituted as the Declaration of Conformity and Certification procedures in 1998. By the regulation, the FCC certification mark is mandatory for devices classified under part 15 including LED displays. The certification mark for part 15 is a stand-alone logo along with other pertinent data, the trade name of the product, the model number, and information whether the device was tested after assembling, or assembled from tested components.

There are currently 280 accredited testing firms worldwide, who are qualified to issue the declaration of conformity certificate. Once verified, the FCC’s Part 15 requires that a sticker, also known as a Two-Part Warning, be displayed. The label should state, “This device complies with part 15 of the FCC Rules. Operation is subject to the following two conditions: (1) This device may not cause harmful interference, and (2) this device must accept any interference received, including interference that may cause undesired operation.” Manufacturers who fraudulently place stickers on unverified products face harsh fines and penalties from the FCC as noted above.

Since the FCC program is self-directed and there are no upfront checks and balances directly overseen by the FCC to ensure compliance, there are serious issues to take into consideration. For example, a manufacturer is not required to use one of the 280 testing centers. As a result, there are many substantiated occurrences of inferior testing that was not done properly or not done at all. There are other cases where the Declaration of Conformity logos and labels are being counterfeited. Overall, the LED sign industry has a spotty record of compliance.

In some cases, this lack of testing and conformity may appear after a sign installation is completed and EMI is discovered causing serious issues with interference in proximity to the sign. At this point, investigations will ensue, testing done, and if violations are found, serious penalties will come into play. As we move forward in our wireless world, EMI pollution will become more apparent and regulations stricter. Violations will become more apparent.
If you are already employing a direct view LED sign, depending upon the origin, you are most likely emitting illegal levels of EMI. As noted above, there can be significant fines and in extreme cases, the sign totally shut down or even confiscated. If a manufacturer’s product is found to be out of compliance, the product may be held in customs or refused entirely, leaving the buyer in the lurch with no recourse.

In short, failing to comply with FCC Part 15 testing and regulations is illegal. Some questionable or unscrupulous manufacturers conduct “partial compliance” which is inadequate to say the least, and illegal. Others are guilty of counterfeiting the labels and marks, all with the objective to save short term dollars on their end. There are no instances of being somewhat legal in these cases. Of course, this puts into question the integrity of the manufacturer and their business practices, but also the quality of all the components in the product. Keep in mind the penalties and that sign owners and end users are at risk for severe FCC enforcement.

Of course, this begs the question of how you can protect yourself and your investment. Here are a few guidelines that should be considered:

  1. First, work with a trusted source. We are referring to a company with a proven track record of successful installations in the USA. We have 20+ years of experience in the USA and hundreds of installations.
  2. Check to verify what certifications and standards that a specific product has attained. Always ask for proof especially in terms of FCC Title 47 Part 15.
  3. Check into local codes for rules and regulations that may affect the installation of an LED sign.
  4. Does the manufacturer have service centers in the USA and what is the turnaround time on parts replacement?
  5. Is there are USA based team to support the sales and application engineering effort?

It does boil down to let the buyer beware. In this burgeoning market, it is difficult to sift through fact and fantasy. One adage holds especially true; “The sweetness of low price is long forgotten when the first problem arises”. You do not need a direct view LED vendor, rather a partner that assumes part of the responsibility for the success of project along with you. It is not the original price but the overall total cost of ownership (TCO) that will determine the profitability of the project. Do not accept the risks we have outlined that are easy to avoid with clear thinking and some effort up front.

this article contributed by Alan Brawn