# EHX fined $450,000!



## bzrkrage (Mar 20, 2011)

http://www.fcc.gov/document/new-sensor-pays-450k-settle-equipment-marketing-investigation

Opps!

That's a big hit for EHX.

Here is where I found out about it.

http://www.effectsbay.com/2014/05/fcc-regulations-for-pedals/

Thoughts on "boutique builders"?


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## Adcandour (Apr 21, 2013)

My pedal prices have just gone up, since they're pre-fcc.


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## bluzfish (Mar 12, 2011)

I have to be suspicious of other agendas being involved in strict regulations that are newly invented that walk all over standard established norms. Since the regulations were implemented in 2013, what problem precipitated such strict regulations, and more importantly, the parameters?

It's like the regulations for maximum 100 ml bottles of shampoo, etc. by airline security regulators when a quick look at typical standard sizes on store shelves for sample and travel products are all 120 ml to 150 ml. - is 100 ml of smuggled volatile liquid really safer than the established standard 150 ml size used for common off the shelf products?

Obviously radio frequencies must be controlled to avoid anarchy and chaos in the airwaves. But while an upper limit of 9 khz might seem reasonable to someone ignorant of the established parameters of digital audio frequencies, anyone who can read a "Dummies" book would see that this is a problem to comply with in the audio industry. Would a 20 khz or even 50 khz upper limit be a problem in low powered audio equipment?

So are the regulators just ignorant or is there some party with a vested interest and something to gain pulling the puppets' strings?


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## dodgechargerfan (Mar 22, 2006)

It sounds like it's more of a labelling and/or documentation issue than anything else.

Fill out a few forms and send them in.
Add a label to the pedals and/or a warning or disclaimer in the product manual, train your production staff to know about all of these rules, and it's covered.

It doesn't really order them to fix or change anything with the products.

At least, that's how I read it.

But, yeah. How did this come to the attention of the FCC? Hmmmmm...


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## keto (May 23, 2006)

dodgechargerfan said:


> It sounds like it's more of a labelling and/or documentation issue than anything else.
> 
> Fill out a few forms and send them in.
> Add a label to the pedals and/or a warning or disclaimer in the product manual, train your production staff to know about all of these rules, and it's covered.
> ...


This is how I read it too...some customs inspector came across a box of IC's that have the potential to emit. EH hadn't done the proper import documentation and/or labeling on the pedal box/manual. This is not a particularly hefty fine by USA corporate/government standards, it appears that EH just got their paperwork in order and a settlement was made.


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## mhammer (Nov 30, 2007)

A large chunk of what regulatory/enforcement agencies do is essentially confirm that something passes muster. Unfortunately, making everyone pass through the same gate is the only way to stumble onto that which does NOT pass muster. The only way the traffic bylaw enforcer is going to find out *you* haven't paid for your parking spot is to check *everybody's* meter, or dashboard for the receipt. So it would seem that EHX's crime was to not seek FCC clearance on their various digital products.

Kinda makes me wonder about all those bucket-brigade pedals - analog delays, flangers, chorus - do they count as analog or digital, given that they have a high-frequency clock?


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## Guest (May 6, 2014)

It's a little more than documentation and labelling. They have to pass interference and emission tests as well. It's not hard, but if you have a product that's been on the market for a long time and you suddenly have to pass an EMF emissions test and...it fails. Well, redesigns are a bitch let's just say that. Not the end of the world. I'm sure EHX will recover.


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## mhammer (Nov 30, 2007)

This has made me curious about all those pedals that are pretty much all analog, with the exception of a PT2399 digital delay chip. More recently, we've also seen the introduction of tap-tempo chips in otherwise all-analog pedals. These are PIC/Atmel devices - microcontrollers with a high frequency clock.


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## bolero (Oct 11, 2006)

unintentional transmitters?

what exactly is happening? it is transmitting radio interference? or is it a health issue?


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## mhammer (Nov 30, 2007)

The FCC, just like the CRTC here, is tasked with managing the broadcast spectrum. That means assuring that ANY sort of "transmission" doesn't deliberately or inadvertently interfere with any other sort of transmission. So, my garage door remote should not interfere with your cellphone, local soft-rock radio station, aircraft communication, police band, or home network router, and none of those things should interfere with each other. If I look closely, I suspect the wireless doorbell I just installed at home a few weeks ago probably had to go through similar sort of compliance evaluation.

The bigger question, as it pertain to us (and to EHX), is what counts as a "transmission"? That the device is not _intended_ to transmit is entirely separate from whether it _does_ transmit over any sort of appreciable distance. My wireless doorbell in designed to have about 20-25ft reach, so it easily passes muster. And I imagine Holy Grail pedals do too. But the FCC has to verify that. When you have national regulations, you can't just accept the manufacturer's word, because they could be underinformed, or devious. Somebody accepted the business-owner's word on the contents of what the train that exploded in Lac Megantic was carrying. Inspection may be a royal pain in the arse, but if you want safe, you have to accept the nuisance of inspection.


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## Guest (May 6, 2014)

mhammer said:


> This has made me curious about all those pedals that are pretty much all analog, with the exception of a PT2399 digital delay chip. More recently, we've also seen the introduction of tap-tempo chips in otherwise all-analog pedals. These are PIC/Atmel devices - microcontrollers with a high frequency clock.


They do indeed have to pass FCC emissions regulations to be sold in the US. For inside-the-US manufacturers you can kind of fly under the radar (like EHX) and hope it doesn't catch up with you. For non-US manufacturers you have to show a compliance certificate to be able to export your pedals to the US.

- - - Updated - - -



bolero said:


> unintentional transmitters?
> 
> what exactly is happening? it is transmitting radio interference? or is it a health issue?


There are a bunch of ways this can bite you in the ass. Normally it happens because the EMF around the unit, produced by the electronics inside the box, extends further from the box than FCC regulations allow.


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## mhammer (Nov 30, 2007)

We're having a good, and very informative, discussion about this over on the diystompbox forum: http://www.diystompboxes.com/smfforum/index.php?topic=107145.0

One of the puzzlers is why the FCC set 9khz as its boundary/threshold for what it considers as a transmitting device. That's certainly much lower than what any of us might consider to be a transmitting device. But since, as I noted earlier, part of the purpose of these forced compliance measures is to keep different sorts of transmission from stepping all over each other, I'm wondering if there aren't any recent biomedical devices that receive transmission in that range, and need to receive something higher than a certain amplitude. In other words, the boundary hasn't been moved down from 100khz to 9khz for reasons having to do with what we'd consider to be the normal content of transmissions (voice, text, business data, etc.).

Anyone have any technical insight into this?


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