QUESTION: We have designed a 40 KHz switching power supply to power only an LED lamp for lighting purposes. Is such a lamp/switching power supply considered RF lighting under FCC Part 18?
ANSWER: The device you describe is a Part 15B device.
Lighting devices that use a switching power supply operating over 9000 cycles per second to convert 60 Hz AC to DC, or that contain digital logic (as defined in Section 15.3), are regulated under Part 15. Verification would be the appropriate equipment authorization procedure. With RF, pulsing or non-rectified RF signals are applied within the device directly to non-gas lighting components (LED-incandescent), resulting in a Part 15 unintentional device.
Part 18 RF lighting devices use RF frequency to excite a gas to cause the light by applying RF inside the device, locally to electrodes or locally inductively coupled to resonant gas cavities. Part 18 requires that consumer equipment of this type is subject to either Declaration of Conformity or Certification, and industrial (non-consumer) equipment requires Verification.
On the other hand, if this were an RF lighting device under the rule FCC Part 18.203(a), the device would have to be authorized as consumer ISM equipment unless otherwise specified under either the Declaration of Conformity or Certification procedure prior to use or marketing.
Note that you as the manufacturer, and/or your test lab may choose which authorization procedure to use (DoC or Certification) for consumer RF lighting devices. Each route requires different labeling, but you the manufacturer may decide the route to compliance.
Note that if the device only requires Verification, the specific labeling requirements for this must be followed; the DoC or Certification requirements will not apply.
Radiated tests may be omitted when the operational frequencies of the RF lighting device are less than 1.705 MHz, based on the table in FCC Section 18.309. This is because RF lighting devices only require radiated measurements greater than 30 MHz, and the table in FCC Section 18.309 does not require measurements of radiated emissions if the frequencies are less than 1.705 MHz. |
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