What a Kit Is

A quick look at FCC Part 15.23 which refers to "home-built devices" leaves one scratching their head as to the question of kits:

"§ 15.23 Home-built devices.  

(a) Equipment authorization is not required for devices that are not marketed, are not constructed from a kit, and are built in quantities of five or less for personal use."  

So it doesn't define what a kit is and doesn't say a kit is illegal, only that a kit must must have an FCC authorization which one can only assume is needed to market the kit.

Part §15.25 addresses "kits" but only referring to "A TV interface device".  Huhhh?  That doesn't really apply to our situation.

So if you are going to buy and build a Part 15 transmitter "kit", make sure it has an FCC authorization if you are going to use it.

If you're just buying parts and information which are not packaged and represented as a Part 15 transmitter, that should meet the "home-built device" criteria which also is not defined.

Also look at FCC Part15.3 DEFINITIONS (P) KIT. Any number of electronic parts, usually provided with a schematic diagram or printed circuit board , which, when assembled in accordance with instructions, results in a device subject to the regulations in this part, even if additional parts of any type are required to complete assembly.

It is here that part 15 transmitter kits are expressly enabled via description.

Nowhere in the rules does any language overturn this definition.

15.23, cited above by MRAM, differentiates kits from home built devices so as to indicate that kit builders are not limited to a quantity of five or less.

Kit builders are allowed to assemble any number of part 15 kit devices.

Otherwise, my logic in post #1 remains evident on its face and indisputable.

"So if you are going to buy and build a Part 15 transmitter "kit", make sure it has an FCC authorization if you are going to use it."

Going with this advice, that would mean all the "kits" we use....SStran, Ramsey etc., AM or FM can't really be used because they are not FCC or Industry Canada approved, with number.

And technically in Canada if you read the fine print ANY transmitter can't be used unless it's certified.

Has to be some middle ground here....A kit means it's a hobby and it would make sense that if it can be adjusted to comply with regulations it would be OK.

Mark

but I recall that at one time there was "type acceptance" and "certification". Certification meant that the manufacturer or kit supplier certified that their product met the FCC standards. This was the case with my KnightKit broadcaster where "Allied Radio certifies..." Type acceptance meant that representative samples of the product were submitted to the FCC for lab testing.

Be that as it may, it seems that now only assembled devices can be FCC certified so kits cannot be since they are not assembled. I possess three txs. assembled by me from kits and others which are "home brew" and I am not going to sit here and obsess about this.

Neil

When anti-part 15 trolls post their hate-speech on other websites always directed toward besmirching SSTran in particular and kits in general, it is important for a more reasoned voice to speak up and dismiss the false noise.

The wonderful part 15 transmitter kits are a major part of what makes this hobby worthwhile, and if we tolerate an attack on their existence we risk losing them.

The certification requirement for pre-built transmitters is a financial impediment to both the users and the manufacturers, and is out of proportion to the small signal produced by such transmitters.

To continue enjoying this hobby we are wise to defend it from its detractors.

Despite the fragmented and somewhat conflicting references to kits in the FCC Part 15 rules, transmitter kits have continually been marketed and used without opposing actions by the FCC.

Almost ten years ago, the manufacturer of a well known certified transmitter posed the question of legality of kits to the FCC. On April 7, 2005, he graciously posted the FCC response on the Radio-Info.com Community Radio forum. Following is an exact copy of the response posted.

FCC RESPONSE:

There has been quite a bit of confusion regarding the legality of kits of Part 15 transmitters. I've been coordinating with other staff members and believe that I can clarify our existing policy.

In 1987, the Commission proposed to rewrite its Part 15 regulations. One proposal was to require that all transmitter kits be specifically included under our certification equipment authorization procedure. However, the text that was eventually adopted in 1989 did not contain this language. Rather, it was silent regarding transmitter kits. Further, while Section 15.23 was added to permit home-built devices, kits were specifically excluded from that section.

Section 15.1(b) states that the operation of a transmitter must be in compliance with the Part 15 regulations or the operator must be licensed by the Commission. Section 15.1(c) states that a transmitter must comply with the Part 15 rules, including any requirement for an equipment authorization, in order to be legally operated or marketed. Section 15.201(b) states that a transmitter, other than a home built device (which excludes kits) or certain products detailed in 15.201(a), must be certified prior to marketing. Part 15 also provides a definition of kits under Section 15.3(p).

These regulations, on their face, appear to require that kits be certified by the Commission as a prerequisite to legal marketing and use. However, the fact is that except for kits of TV interface devices and external RF power amplifiers, as described in Sections 2.815, 15.25 and 97.315(b), the Commission has not required kits to be certified as a condition of marketing or operation. This does not mean that the kits are necessarily legitimate. Any assembled kit must comply with the appropriate standards and the marketing of any non-compliant kit would be a violation of our regulations. In addition, we have issued many citations and fines to operators of broadcast frequency transmitters that were assembled from what were supposedly Part 15 compliant kits.
I agree that the regulations themselves could be clearer. Hopefully, we will be able to resolve these discrepancies in our forthcoming clean up of the Part 15 rules.

I'm sorry about the earlier misunderstanding on these issues and hope that the above clarifies matters.

i have seen the posting(s) from a certain individual(s) on another forum that i'm sure prompted this topic.

not very knowledgable or understanding of the rules imho for someone who claims to be the one stop shop legal reference of all things part 15.

i have known about the above fcc interperetation @Phill B posted since it was first posted at the old radio-info site. also the well known manufacturer who posted that fcc reply now has changed his tune on the previous interpetation since the recent well know part 15 am kit that is on the market has been eating into this well known manufacturers already small sales.

Funny that hey mention RF Power Amplifiers.  Heathkit comes to mind.

Remember CB Kits? from i believe either Allied or heathkit?