I read about halfway through the NAL, and I'm not suprised by this. A few things stick out:
Behringer also acknowledged that it had not verified compliance of any of the 66 models of
its digital devices with the applicable FCC technical standards, prior to importing and marketing such
devices in the United States. Rather, Behringer represented that “a range” of its digital devices had been
tested and passed “CE” directives, and expressed its belief that those devices will also comply with the
Commission’s technical standards given “the relationship between the applicable FCC and CE
electromagnetic compatibility regulations and the results of Behringer’s CE tested products to date.”
Mistake number one: they admit they didn't get the equipment type-accepted.
Mistake number two: they admit their equipment went for CE certification, but not FCC.
Having seen a number of Class A and Class B digital devices through compliance, I can tell you that
most labs are accredited to offer CE, UL, and FCC Class A and Class B certification, but
you get billed for what you get tested. If they sent their units in for CE cert and didn't follow through with the FCC cert, they very probably did so to pinch a few pennies per model and hoped they wouldn't get caught. As it was, they only sent a small percentage of the number of models they offer for CE certification.
Every time we release a new machine to the market, we get all the certification we need from one single outfit. One-stop certification. It's a difference of a few thousand dollars to get a device CE and UL listed without getting FCC listed. Cheaper than a million dollar NAL, for sure.
KL7OF asked:
I read thru the FCC legalspeak and I find myself wondering what is Behringer is gulity of /charged with? They seem to have been very cooperative with the FCC.. Are their devices interferring with someone/something?
They're charged with putting a digital device to market without receiveing FCC certification first. The regs clearly say you can't do that, and that's there to protect you and I from digital hash and tee-rash inundating the spectrum.
The fact that they've been cooperative with the FCC won't buy them anything. Compliance is expected from the start, suddenly coming
into compliance doesn't mitigate or negate a previous lack of compliance.
But they made it even worse for themselves when they responded to the first Letter Of Inquiry with a detailed statement of corrective action they would take to get all of their marketed products certified, and then appearently only gave lip service to that agreement. Not only does coming into compliance not negate anything, but
pretending to come into compliance without actually doing so makes things much, much worse.
That's a guaranteed way of pissing off Uncle Charlie, and "Charlie don't surf".
It's too bad, really. They're a good company that builds a good product, they just tried to cut a few legal corners and got caught. You dance the dance, you pay the piper.
--Thom
Kerolene Apparatus One Zooming Golf Cart
