Upcoming Expansion of Electrical Devices for RF Lighting Products by New FCC Standards
RF lighting products utilize radio frequency energy to produce light and thus fall under the FCC rules, which regulate possible interference with radio communications services. RF lightning technology has existed for over 25 years and it functions by applying an RF signal to a gas inside a lamp. Products such as fluorescent fixtures and compact fluorescent bulbs use this technology and are thus covered by the RF emission limits of the FCC rules. Recent incidents where damaging interference was caused by such products have been recorded. The products in question were not compliant with the FCC emissions limits. The purpose of Draft KDB 640677 is to define how these existing FCC regulations apply to these products and to summarize the responsibilities of manufacturers in ensuring the control of RF interferences.
Part 18 Covers Technical Requirements for Lighting Products
Part 18 of the FCC rules covers AC power line conducted emissions limits below 30MHz and radiated emissions limits above 30MHz. Older RF lighting products operated at frequencies below 3MHz and hardly ever produced significant emissions. However, more recent RF ballasts have been observed to produce radiated emissions well above 30MHz, which is why the responsibility for compliance with emission limits falls to the manufacturers, who are required to perform routine radiated emissions measurements. The Draft clarifies that lighting devices are required to comply with the radiated emissions limits, and testing needs to be performed up to 1000 MHz in order to prove compliance.
The requirements that apply to such products are:
- AC Power Line Conducted Emission Limits: §18.307(c), for all equipment (i.e., consumer or non-consumer equipment).
- Radiated Emission Limits: §18.305(c). Radiated emission measurements are to be performed from 30 MHz to 1000 MHz.
- Equipment Authorization Procedure: The "Verification" equipment authorization procedure is used for non-consumer equipment; and the "Declaration of Conformity" (DoC) or "Certification" equipment authorization procedure is used for consumer equipment.
Technical Requirements Under Aspect of Lighting Devices Covered Under Part 15
Since LEDs do not apply an RF signal to the gas in a lamp and use a different technology, they fall under Part 15 of the FCC rules, which cover unintentional radiators. Interferences caused by LED lighting have also been recorded, especially with applications such as large advertising or video displays. It is also clarified that LED lighting products are also subject to testing up to 1000MHz in order to prove compliance.
Unintentional radiators can operate under the condition that no damaging interference is caused; and should harmful interference occur, manufacturers, importers and users are required to cease the operation of the product. Solid engineering design and construction methods are encouraged to assist in reducing the incidence of unwanted emissions.
The technical requirements that these products fall under are:
- AC Power Line Conducted Emission Limits: § 15.107(a) for Class B (residential) devices or § 15.107(b) for Class A (commercial) devices, as appropriate.
- Radiated Emission Limits: § 15.109(a) for Class B (residential) devices or § 15.109(b) for Class A (commercial), as appropriate. Radiated emission measurements are to be performed from 30 MHz to 1000 MHz.
- Equipment Authorization Procedure: The "Verification" equipment authorization procedure is used for both Class A and Class B devices.
The Commission is dedicated to actively enforce these testing rules and encourages manufacturers to avoid potential sanctions by resolving any possibility of harmful interferences.
(1) Draft Laboratory Division Publications Report
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