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Thursday, February 2, 2012

Are on-board electric vehicle battery chargers exempt from FCC equipment authorization?

English: Google Electric Car Seciurity 2008 (V...
Image via Wikipedia
Under Title 47, Part 15 Subpart B § 15.103, the first item on the list of exempted devices is
“(a) A digital device utilized exclusively in any transportation vehicle including motor vehicles and aircraft.”
The clear answer is “Yes” to the question, “are electric vehicle battery chargers exempt”,… right? … What would you say?

As is the case with much of part 15 subpart B, in order to comply with the intent, you need a little common sense, good familiarity with electromagnetic energy propagation, the ability to think like an FCC engineer, and finally, a Knowledge Database publication (KDB) from the FCC with a clear “yes” or “no” answer to any question you may have, and you may have many.

See Publication Number: 892282
Question:
Is a battery charger and associated digital electronics on-board a vehicle that is used for charging the vehicles battery while parked and connected to AC power lines exempt from an equipment authorization under 15.103.
Answer:
No. Section 15.103, Exclusions, paragraph (a) does not apply to battery chargers for electric vehicles that can be used for charging while stationary and connected to an AC power line. The exemption is only intended for digital devices which operate primarily when the vehicle is operating in a mobile environment such as on a road or highway where the potential for interference is low. When stationary and connected to the AC power line, typically in a residential environment such as a home garage or driveway, the potential for interference by both AC lines conducted and radiated emissions is greater. The battery chargers and associated electronics on board an electric vehicle are therefore subject to an equipment authorization under the verification procedure as a Part 15  Class B or Class A (industrial vehicles) unintentional radiator (switching power supply and digital device).

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