Could Your Cheap Android Digital Signage Box Send You To Jail?

fcc-part-15There are many reasons not to use a cheap Android set-top box or stick from Shenzhen, China to power your digital signage network, like shaky reliability and zero support, but I wasn’t aware of the one that could result in a massive fine and even jail time.

I was talking recently to Jonathan White, the deeply experienced CTO of Capital Networks Limited, which has been doing broadcast servers and digital signage players for 20+ years. White casually mentioned something about the FCC (US Federal Communications Commission) and how most of the boxes being used as Android signage players were not FCC-approved, or approved by its Canadian counterpart, Industry Canada.

Here’s the deal, says White:

All devices that utilize radios, such as WiFi and Bluetooth, must go through a battery of emission tests by a certified testing laboratory.  These passing grade test results must then be submitted to the FCC and Industry Canada (separately ) with an application for certification as Intentional Radiators.

The FCC and Industry Canada will then issue a certification number for the specific device.  This certification number MUST be printed on the outside of the device. Failure to do so carries heavy penalties for infringers, with fines up to $1,000,000 and up to one year in prison.  This applies not only to manufacturers, but also to whoever imports the device into the U.S. or Canada, and even the end-user.

There are devices from China’s technology hub Shenzhen coming over with FCC stamped on them. That’s the mark for self-declaration of conformity for “unintentional radiators” – devices that use microprocessors, but don’t have radios. 

For those, White says you do not have to apply to the FCC or Industry Canada for a certificate. However, a solutions provider/reseller/etc  is responsible for having the unit tested by the same type of certified testing laboratory as used for Intentional Radiators.  

“Even Chinese sites that ‘claim’ to have this type of certification, when I’ve dug deeper, I’ve found that they’ve only tested a single model, where it is required that EACH model variant … even if the variation is only cosmetic … must have its own test report from the accredited lab,” says White.

Here’s a rundown from the FCC on these radio transmitters and what all is involved.

Here’s why the FCC suggests you comply:

The FCC requires that any product that is covered by FCC regulations undergo “equipment authorization procedure”. It is illegal to import, sell, or lease covered equipment that has not undergone the required equipment authorization procedure. Additionally, operators must cease to use equipment that causes interference upon notification by the FCC. The FCC does have the ability to levy fines, impose seizures, and even jail offenders. The FCC frequently targets end-users with fines to bring pressure to bear on retailers.

In North America, testing labs generally charge between $10,000 – $15,000 to test an unintentional radiator.  Tests for an Intentional radiator are $20,000 and up.  This is provided that the device passes the tests the first time.  If it doesn’t, then you have to pay to have the device re-tested.

Capital is among many companies that started out using devices sourced from Shenzhen, testing and discarding sample units that were not up to the task of 24/7 signage. Like other companies, they settled on one they felt could be trusted to stay working in the field. “Part of my selection process was to find a manufacturer that would be willing to have the device certified as an intentional radiator (on our dime, but testing labs are less expensive in China). Our Gen 1 player failed the test the first time, as I expect most devices from China would.  Our manufacturer had to modify the design to add additional shielding and emission-reducing components, in order to obtain a pass on the second test.”

So … does this actually happen? Does the FCC go after companies and even individuals?

Not that often, but, Yup … they do.

Is your low-cost Android device certified?

Dave Haynes

Dave Haynes

Editor/Founder at Sixteen:Nine
Dave Haynes is the founder and editor of Sixteen:Nine, an online publication that has followed the digital signage industry for more than a decade. Dave does strategic advisory consulting work for many end-users and vendors, and also writes for many of them. He's based near Toronto.
Dave Haynes

@sixteennine

Decade-old blog about digital signage and related tech, written by industry consultant and shit-disturber Dave Haynes.
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