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How to validate a market with development boards and SD cards

129 points| zkirill | 1 year ago |flyingcarcomputer.com | reply

115 comments

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[+] Animats|1 year ago|reply
> Market forces naturally determined this outcome though.

Market forces alone didn't work. It's an externality, a cost paid by others not involved in the transaction. Market forces don't handle that. A 1970s Milton Bradley Big Trak and a Radio Shack TRS-80, both popular products in their day, will, if brought near to each other, both crash. Without fairly strict regulation of unwanted RF emissions, there would be many incompatible devices. There were before the FCC started requiring more testing in the 1970s. A world with a huge number of consumer devices emitting RF noise would have prevented low-power cellular phone and WiFi deployment.

It's not that hard. This is an "unintentional emitter" (it's not trying to send a radio signal). The rules for that are not too bad. Testing costs about $3000 to $5000.

You want to have some ability to pre-test. You might find something. Attaching a wire to something can give it an antenna and make it emit much more RF, so you do need to test. It's not too hard.[1] Actual FCC certification is $3000 to $5000, assuming you pre-tested and fixed any problems before getting a certification run.

From the project's FAQ:

"Given that this will initially be a niche product, the price will be quite high. I was once taught to ask myself the following question: Who is your rich customer? The type of person whom I have in mind has a high discretionary budget for personal electronics and willingness to pay a premium for novel ideas."

[1] https://www.nutsvolts.com/magazine/article/low-cost-emi-pre-...

[+] bruce511|1 year ago|reply
The first rule of knowing if a market exists is to define what you are making and then figure out who it's for. Then pitch to that person the benefits of your product.

Alas the FAQ page lacks both of these questions. I'm left with no idea -why- I'd buy this thing. What utility does it have? What is it supposed to replace?

I think you can stop worrying about the FCC issues with it. You won't sell any of these (at least not with this FAQ page). Your whole "discussion" is technical and doesn't mention utility once.

It sounds to me like you're building this because it's fun to build and scratches an itch. But it's not a product, much less requires you to start building and designing new hardware. So well done on at least skipping that investment.

If you want to make a hardware product then early about utility first. If it's useful then other things flow from that. Not the other way around.

[+] olalonde|1 year ago|reply
Why is it so expensive though? Also, why not fine or ban products that cause problems rather than requiring certification. It seems that would be a lot more efficient.
[+] debugnik|1 year ago|reply
Agreed, but I can't find that quote in TFA so I can't entirely tell which point you're rebutting. Did the author remove it?

EDIT: Oh, I see you meant to reply to some top-level comment further down.

[+] joezydeco|1 year ago|reply
Now, how to get the SD card in the hands of the customer? Mail it to them!

I worked on a equipment project for a large restaurant chain about a decade ago. The core application and related assets/recipes/files were all on an SD card. When it was time to upgrade the app or release new seasonal recipes, every store got a new SD card in the mail with instructions to wait for a certain date, power down, swap cards, power back on, dispose of the old card.

It was way cheaper to send updates that way than bother with encryption, networking, corrupted disks, etc. A bricked machine lost a hundred dollars or more per hour. If the new card failed, the operator could continue with the old one until a replacement could be sent.

One major problem was suppliers always trying to swap to lower cost SD cards, even counterfeit ones (c.f. Bunnie), and things would go south really fast. The Linux system and hardware were both pretty old and had MMC stack issues when the cards showed shaky margins on the timing. Or, capacity wasn't what was advertised (c.f Bunnie). We had to spend a cycle or two qualifying each mailing release to make sure a shitty batch of cards didn't make its way into the stream.

SD has its uses, although I still prefer a read-only eMMC partition to hold the bootloader and O/S. I don't get why RPi users put themselves through such misery to save $20 on their SBC.

[+] zkirill|1 year ago|reply
Glad to hear that this passed muster in the food industry. Do you by any chance remember how the SD card was packaged or protected from damage while in transport?
[+] Aurornis|1 year ago|reply
> Normally, market forces would dictate that by now it would be straightforward, fast, and affordable to get your product tested as frequently as desired. However, in reality, the labs are “too busy” to respond or reply very late and generally sound less than eager to work with you. Not to mention, the fees that they quote are rarely palatable to a bootstrapping startup.

The various test labs I’ve worked with haven’t been “too busy” to respond. However, they are generally hesitant to work with people who don’t really know what they’re doing.

If you are an engineer with knowledge about the process and who needs a lab to partner with, it’s not hard to get in somewhere.

However, if you don’t have the knowledge or experience, the lab might sense that you’re looking for someone to hold your hand heavily through the process. They may be less than enthusiastic to take on a one-off customer who might require an abnormally high amount of communication and hand-holding when they can fill that same spot with a repeat customer who needs nothing more than to book the time at the lab and can show up prepared and ready to go.

I suggest teaming up with a local consultant for your first round. Not only will they help you through the process, they’ll have connections and reputation to get you into the labs.

The lab fees aren’t extraordinary high for a hardware startup, really. It’s not free, but it’s not much relative to the up front costs of building hardware inventory.

[+] fellerts|1 year ago|reply
In my limited experience, it was the other way around. I had to hold the technician's hand through most of the testing and onboard several technicians due to a staggering amount of employee churn in the test house. What should take an afternoon would take months of intermittent testing at very inconvenient times (night slots). Next time I might just show up outside their door with a sleeping bag and refuse to leave until the tests are completed.

Maybe we were the problem and our documentation was insufficient, but we never had a chance to do a "post-mortem" with the test house and learn how we could do better next time.

[+] Rovoska|1 year ago|reply
I would be embarrassed to publish this. It is a stunning display of ego and ignorance of how this part of the world works that boils down to the author being too cheap to put in the work and too lazy to understand why regulations exist.
[+] AnarchismIsCool|1 year ago|reply
It's wild to me that everyone here is taking this seriously. This is high school science fair level stuff.
[+] buescher|1 year ago|reply
You can find statements and notices and citations and such on the FCC web site to see what happens if you get caught out. If you're interested in that kind of thing, they're interesting reading.

Here is a pretty bad scenario for apparently willful unintentional radiator violations, where an ultrasonic foot bath company was at best unorganized and slow to comply with testing and labeling requirements: https://docs.fcc.gov/public/attachments/FCC-18-67A1.pdf

Here is a better scenario, where an LED sign manufacturer was a bit more on the ball: https://docs.fcc.gov/public/attachments/DA-22-1136A1.pdf

Note in both cases there is no mention that these devices emitted RF above allowed limits for unintentional radiators. These companies simply didn't test and didn't label their devices appropriately.

Here's one for Asus, where they got WiFi products certified, and then changed something, probably firmware, that allowed those devices to transmit more power than allowed: https://docs.fcc.gov/public/attachments/FCC-24-69A1.pdf

[+] rererereferred|1 year ago|reply
Their FAQ here[0] explain some things about these devices they are building, except for the main question: what are they for? It says personal computers but no audio, video or games. So for reading?

[0] https://flyingcarcomputer.com/posts/a-new-personal-computer/

[+] chrisldgk|1 year ago|reply
Reading this, it doesn’t seem like they’re really doing anything more than building a glorified raspberry pi with their own self-spun BSD distro preinstalled. Also the FAQ being mostly Q: „why not use X?“, A: „I don’t know X and thus it’s bloated/I don’t like it“ doesn’t inspire a lot of confidence.

I admire their dedication and it seems like a fun project. I don’t think it’s something a lot of people will pay money for though.

[+] biosboiii|1 year ago|reply
The FAQ is hilarious.

He is writing this entire article to save 3-5k conformity tests, but bases his entire software on FreeBSD because "it's more commercially friendly.

[+] sgerenser|1 year ago|reply
Looks very weird. No LCD screen, but presumably it’ll plug into a monitor? Seems like just pointing out expected use cases would go a long way.
[+] practicemaths|1 year ago|reply
"The testing and certification industry is odd. In theory, it exists to serve the public good and uphold consumer protection laws. On the other hand, its customers are in the private sector. Normally, market forces would dictate that by now it would be straightforward, fast, and affordable to get your product tested as frequently as desired. However, in reality, the labs are “too busy” to respond or reply very late and generally sound less than eager to work with you. Not to mention, the fees that they quote are rarely palatable to a bootstrapping startup. And yet, working with them is generally required to get your product to market."

Market forces naturally determined this outcome though. If you're big companies you naturally want to limit the threat of new competition. Making compliance more costly achieves this.

[+] tootie|1 year ago|reply
I used to work at a place that did some custom hardware development. Usually one-off or very limited run. Any time we fabricated a case and plugged in off-the-shelf devices, certification was not necessary. If we did custom wiring we got ETL certified. I didn't run the process myself but I recall it being easy and not very costly (few thousand?) It's a barrier but a pretty low one. Our electronic work was like advanced amateur level and it still passed with minimal modifications.
[+] Aurornis|1 year ago|reply
> Market forces naturally determined this outcome though. If you're big companies you naturally want to limit the threat of new competition. Making compliance more costly achieves this.

Compliance for basic products isn’t costly, though. It’s a rounding error relative to the wages you have to pay engineers and the costs involved in manufacturing the product.

[+] femto|1 year ago|reply
Big companies are often outside "the market", in that they have internal labs which are accredited to test their own products.
[+] taneq|1 year ago|reply
Also, by definition, testing and certification companies have a captive market and will tend towards being lazy and exploitative. Any competition that springs up might temporarily improve things but then it too will get used to having a captive market and start sliding in the same direction.
[+] Joel_Mckay|1 year ago|reply
You do know many devices like Raspberry CM have FCC/IC modular pre-compliance, and thus usually only require LAB EMI testing under the rules.

The primary problem with mystery-parts is they tend to have issues with RoHS documentation, complex customs clearance requirements, and unknown specifications.

DIY evaluation kits people assemble do fall under a sort of gray area, but if your hardware does splatter the RF spectrum it is a $1m fine in the US, and a $5k fine + up to 5 years in jail in Canada.

Unshielded RAM, USB/PCI to Ethernet, and Video GPU chips will often just barely pass EMI testing under ideal circumstances. Cheap stuff from the mystery bins will usually just glean the FCC id off a refrigerator to get through customs.

Have a nice day, =3

[+] AnarchismIsCool|1 year ago|reply
Ok so as someone working on something vaguely similar (portable computer, slightly different market, more RF focus) I assure you this person is just rambling on a blog.

Basically everything on their blog/faq ranges from inept to dangerously misleading.

[+] mschuster91|1 year ago|reply
> Variations of the FCC exist in pretty much every developed economy. Putting a poorly tested hardware product on the market immediately puts a target on your back. Maybe you’ll get lucky, but chances are that someone somewhere will report you. And, unless you are operating entirely out of China, it will hurt. A lot. Both your company and maybe even you, personally.

And that for good reason. Any bad actor on the RF spectrum can be an actual, significant and direct threat to people's lives - particularly the EMS bands as well as the rail, marine and flight safety/coordination channels are absolutely vital. Up next is stuff like GPS, radio and television where disturbances affect a lot of people, and then there's local stuff like wifi, Bluetooth, Zigbee, door openers and whatnot that only affects very few people.

Unfortunately it is very, very easy to be a bad actor on the airwaves. Powerline/PLC is hated by radio amateurs for a reason, and that one is actually even licensed. The other stuff is much, much worse.

[+] fxtentacle|1 year ago|reply
I wonder how much research this person did. At least in Germany, cheap DIY kits are everywhere !!!

https://www.pollin.de/p/bausatz-led-wechselblinker-810051

German company selling a German-made electronics kits in Germany without CE certification. And they have lots of them:

https://www.pollin.de/bauelemente/bausaetze-module/bausaetze...

As long as you don't connect to mains power and you don't ship a finished product, you're exempt from CE certification. So use an USB plug as your power supply and sell it as DIY kit to be assembled by the customer and you're good to go.

[+] ctrlw|1 year ago|reply
DIY/parts are a fuzzy area and might not need the certification, but the board at your first link does have a huge CE print near the LEDs.

Edit: I found this Make article (paywalled and in German) a good overview for makers wanting to sell hardware in the EU: https://www.heise.de/select/make/2017/6/1513996282631753

[+] pjc50|1 year ago|reply
The US and EU regulatory systems are quite different.
[+] liminalsunset|1 year ago|reply
There are plenty of products which ought to be certified but are not, and plenty of products that probably do not need to be that are.

This is across large and small companies, so I'm going to take a guess and say that in the AliExpress and Temu age, simply mailing the device from China will solve all of your problems.

[+] Aurornis|1 year ago|reply
> so I'm going to take a guess and say that in the AliExpress and Temu age, simply mailing the device from China will solve all of your problems.

Your guess would be wrong. The regulatory agencies aren’t inept. They’ll figure out where the headquarters is, not just where the products are being shipped from.

So unless you’re moving the entire company, and your bank accounts, to China and you have a backup plan for what happens when they start seizing your shipments at the border, this isn’t a solution.

[+] dublin|1 year ago|reply
Regulatory certification is a shakedown racket that makes the Ticketmaster monopoly discussed a few items down look like a friendly environment.

Do you wonder why all of your new electronics are made in China? One big reason is that China has its own regulatory labs (which may or may not do testing - who knows?) that are literally at least an order of magnitude cheaper than getting certification done in the US or Europe.

I'm working on two client products now that I and the clients would prefer to have made here in the US, but both will be made in China because the companies literally cannot afford the rapacious cost of getting them certified here. (And China mfg is way cheaper, too - partly because of parts distribution models: It's literally cheaper to buy a finished product from China than to buy the components here to assemble the same product!)

[+] pedalpete|1 year ago|reply
We've been developing a wearable, which is classified as a medical device, so we've been looking at the FCC/CE/etc regulations for a while.

We're using ESP32s, and are currently going through ethics approval, which, from what I understand, means we can use the device prior to sale, but maybe we've got that wrong. I can't imagine having to have each hardware iteration certified by the FCC.

What struck me more about this article is the subject of marketing.

For companies that are doing pre-sales, and are still in development, and likely haven't been certified yet. Isn't that considered marketing? How are other companies handling this? We're looking to run a marketing trial in a few months, and marketing is part of the recruitment process for a trial.

[+] negative_zero|1 year ago|reply
Ethics approval for a medical device is a completely different thing from EMC regulations (which is what normally people mean when talking about FCC and CE for a device).

"I can't imagine having to have each hardware iteration certified by the FCC."

Depending on your device and the magnitude of the changes, this might simply be the reality for you. This is why I always try to tell people that you need compliance at the table from the start or you really risk making life very difficult for yourself. Find yourself a compliance specialist or at least a hardware engineer who is familiar with the regulations.

EDIT: You CAN'T just iterate ad-infinitum for free without consequence like you do for software. This thinking and approach, only works in software land. No where else.

It would be ridiculous to build a house and having the builder iterate on your house over 2-3 years to finish it, no?

[+] jvanderbot|1 year ago|reply
I never understood the nuance here. If I put a rasp pi in a box, does it need certification? What about with connections soldered on if all connections are already certified? How about the logical next step of a board with certified components?
[+] TheCleric|1 year ago|reply
I’m no expert but I think the problem is that once you start combining certified components in a new configuration that it’s theoretically possible for the sum of the parts to be non-compliant. Perhaps a wire you added becomes, in essence, a transmission antenna of the noise in the circuit and thus could interfere with other devices.
[+] utensil4778|1 year ago|reply
As far as I understand, modules like an ESP32 for example, carry their own FCC certification. If you include them in your product, you do still need certification of the product overall, but you don't have to worry about the radio certification, just unintentional radiators.

For instance, if your widget includes an ESP32 and a switching power supply, you are (notionally) guaranteed to never fail certification due to bad behavior from the ESP, but if you botch your power supply design and are spewing out noise in the KHz to MHz range, you still fail certification.

Even if every individual component in your device carry their own certification, you still have to certify the product as a whole. Poor PCB design can produce bad EMI. Maybe you're running SPI over a long wire or your traces are routed in a way that accidentally creates an antenna at your SPI clock frequency. Hell, even something as simple as toggling a GPIO pin once a second can emit high frequency EMI under the right conditions.

There are a lot of ways to unintentionally produce harmful EMI, and that's exactly why FCC certification is required for everything. This stuff is hard to get right and there are endless gotchas and exceptions and edge cases and you have to know about and account for all of them.

[+] analog31|1 year ago|reply
Is there such a thing as low-cost testing and certification services operating overseas?
[+] Aurornis|1 year ago|reply
There are labs in China that will wink wink pass any product you send them for a flat fee.

The problem is that having passing test results from a random lab doesn’t help you if the FCC (or one of your competitors) discovers that your device is not actually compliant. So you have to be careful about what you’re getting.

[+] miki_tyler|1 year ago|reply
That's a TERRIFIC idea and a great business model.
[+] WhereIsTheTruth|1 year ago|reply
> I don’t need to sell the development boards. I just have to tell my customers which boards to buy and how to set them up. This way, the electronic device liability will fall on the manufacturer, and the magic of ~friendship~ EULA should afford me enough protection to make this a pure software play.

Parasite of the economy, right there

[+] cwoolfe|1 year ago|reply
Yes! And don't forget to somehow encrypt the data on your SD cards, or do a check-in with the cloud to activate, otherwise your customers can make copies and give away all your software for free!
[+] zkirill|1 year ago|reply
I am opposed to DRM and would never do that.
[+] RecycledEle|1 year ago|reply
I have rarely seen someone this happy to add friction that prevents his customers from buying his product.
[+] iamleppert|1 year ago|reply
Is it possible to couple compliance testing with an LLM? I smell a new business model.