I do appreciate the stickers with the model numbers and mac addresses that come with the RBs. It would be useful for the US market to have the FCC ID printed on the sticker as well.
Radio cards I buy such as the CM9 come with a sticker showing the FCC ID number, and I put that sticker on the RB case when one is used in the case.
the mikrotik products that are FCC certified have such stickers, but AFAIK for product sets and installations with antenna you need a separate certificate, and re-sticking the wireless card sticker isn’t going to fool anyone
Lets ignore the complexity of a wireless system for a moment. Let’s say I bought and deploy a rb433 as an ethernet router and put it in a black aluminum indoor case like would be commonly sold with the mikrotiks. The 433 has the FCC logo printed on the circuit board, implying some sort of approval. Basically all the electronics I can find (even the minimalist ipod) have some sort of FCC writing or logo on it’s exterior. I’m not a lawyer, but conspicuous probably means on the exterior rather than on the circuit board. You already include a sticker with the 433 to go on the case showing that it’s a 433 and has some mac addresses. This sticker would be a good place to put the FCC label as well.
I’m not trying to be anal, because sometimes I forget to put the product sticker on too, even though it is helpful. It would lend additional credibility to the Mikrotik brand make it easy to play by the rules. The underdog and affordable networking equipment companies (and especially so with wireless), have a bit of a tarnished image among higher-budget equipment buyers for haphazard certification or end users not following FCC rules.
The stickers are not there for a reason. Board itself is not FCC certified, it’s only FCC certified as a kit with a certain antenna. Contact your distributor for details.
Can’t speak for the US, but in the EU the wireless card itself is obviously required to be certified to the relevant EU standards because it is a transmitter. If it is found to be compliant to ALL the relevant standards for that type of device, can the CE mark and if necessary the ! mark be applied. There are also regulations that state how large the symbols must be. (There are also regulations that state what can be done if the device is too small to show such a large label)
The ! (alert mark) is required in the case of the Mikrotik R52 as it is capable of transmitting outside of a ‘harmonised band’.
So, the CE and ! alert mark applied on the label of the R52 only applies to the card “as certified”. (There a number of different ways a device can be certified). Therefore as it was clearly tested without any antenna connected, the CE compliance mark can only apply to the wireless card itself. The label cannot be included as a loose label in the bag to be stuck on the outside of your box as the test they did does not apply to your setup, only to their card.
If you now install the wireless card onto a Routerboard and put it into a Routerboard case and connect an aerial you are now a manufacturer of a completely brand new piece of equipment. You have now to ensure that your new system is compliant. Only when you can prove that it complies with all the relevant EU standards, may you place a NEW sticker of your own on the outside of the ‘system’.
Placing a CE label on the outside of the enclosure, without traceable proof that your ‘system’ complies with all the relevant standards is an offence under EU legislation. I.e. just as bad as not putting a label on it at all. This stops people just sticking CE and ! marks onto the outside, when they clearly haven’t any proof that it actually complies.
EU R&TTE Legislation can be a legal minefield, for a start the above information is only the ‘tip of an iceberg’, I am sure the FCC is no different!
An $11,000 fine for Proxim in February 2009 for placing non-compliant Wireless Access Points on the market. (For those who don’t want to read the pdf - they were APs which operated on 5250-5350 MHz and did not have DFS. They were also fined for not using correct labelling on one of the APs)
This is very interesting info you are giving here.
So, I buy MT routerboards, with MT radio cards, put them in a box and connect a quality antenna (one of the mayor vendors thus also certified as far as applicable) and set power output and channel frequencies with DFS according the national/European regulations.
How do I now prove that I apply to regulations and can I now design my own sticker to attach?
Since the 5Ghz band I use is license free I am on this moment not even registered with the national regulative body. Do I have to actively search for approval or is it enough to have documents ready in case of…
This is not a straight forward subject. That is why I offer consultancy services on this subject matter as each case is different and there a number of different routes to enable your product to become ‘legal’ depending on what you are trying to do with the final product and what technical standards your company is able to show compliance with. However, very simply, if you have manufactured a new product then it requires certification for it to be offered for sale in the EU or for it to be imported into the EU, regardless of where you obtained the internal parts from and regardless of what certificates they have as individual parts.
This is only sensible as when you combine different parts, how can you say that they will not inter-react? Each individual part may be compliant, but all the parts, when placed together into a new final product that you have created may no longer be compliant. Therefore the responsibility lies with the supplier and installer to ensure that the entire finished product is compliant.
Well, I am not a reseller. I build the units together to have them as my production units working for me in the field. Ownership stays in my hands.
By having all the certificates of the individual parts at hand and showing the proper settings within local regulations I should have my ass covered?
I haven’t seen any approval/calibration body checking out the equipment Europe’s biggest telcon provider put on the roof of my house after the technicians build it together from parts out of several boxes straight from the manufacturer. And this provider goes the legal way in all situations!
Doesn’t matter if you are a reseller or not. By building the device from a kit of OEM parts and using it in the EU, you have now manufactured a device that requires compliance with the R&TTE Directive. Whether you obtain certification to prove compliance is your choice.
Someone else allegedly failing to obtain compliance certification for a device on your roof does not make your equipment obtain the required certification. We have an expression here in the UK. ‘Two wrongs do not make a right’. But if it makes you sleep better at night, that is OK by me.