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2010-12-01 10:46:59 (9191 views) In descending order of website visits:
Canada: just need to change the title on our EMC report, needs to say "RSS-210" which is the Canadian equivalent of FCC 15.247. We unfortunately need to use those "i-pod mode" and "led as laser" guys again, and needless to say they'll probably try to charge us, now getting a quote...
Australia: we may be able to use existing test reports through some loopholes (and by a hair since the rules were just changed in our favor) but there are a couple things we're trying to sort out and confirm. Worst case selling in this country will require new tests to be carried out, possibly we'll need to get a government permission and pay them a fee, best case neither.
Japan: this is a very juicy target for us though we can't see the visits yet because the site is only in English. We found that it won't be as expensive as we thought to do testing for Japan. EMC emission testing according to some odd standard is possible but voluntary (scratch that right off!). Only intentional radiation (actual transmission) is regulated; the test standard is completely different from what we've done and we can't even rely on that portion of the tests carried out ahead of time by the manufacturer of the RF circuitry. However, we were told that we can do the tests in China and then forward the results to a Japan accredited lab for certification. Fortunately as far as safety is concerned we don't fall in either the prescribed or non-prescribed lists of Denan law and our battery is less than 400Wh/L in power density so there's no special safety testing required.
On top of safety and EMC, there's the issue of SAR (measuring how much power the body actually absorbs from radiation). Only the DL2K-LINK is powerful enough to require this and it was almost exempted but it won't be since it can be plugged into a laptop which can be held less than 20cm from parts of the body other than the hands (still fighting and researching it to make sure the lab isn't pushing it needlessly). SAR testing is needed for the US and EU and probably these results will suffice for Canada as well. The manufacturer of the radio circuitry within it has agreed to do it themselves so that's very good news. If we do any further testing for Australia or Japan, though, we may have to do SAR testing according to Australian or Japanese SAR standards (assuming we can't find a loophole here too which might be doable for Australia but is very unlikely for Japan). It's not a given since many places (such as EU, Australia) limit power output to 10mW anyway and we will comply via software so at that power output SAR testing would not be needed.
Aside from testing and certifications there's a duty to have a local "authorized representative" to hold the technical construction file and other paperwork. This is actually way more expensive than it should be given they just hold some papers. Of course it's this way because it's big foreign companies selling in multiple markets that need to purchase such a service. This will be needed for the EU and Australia for sure, probably also Canada and Japan. Speaking of which now we have all the EU tests it's time to find a company to be the authorized rep in the EU...
Any work towards expanding our sales to other countries will obviously depend on demand and other impending concerns and expenses. We've got to stock up on components so they don't get depleted, pay back the mold guys, give the assembly guys decent quantities so that they don't drop us, and so forth.
Currently, traffic from Canada is 1/10th that of the US. Australian 1/21st.
Regarding the question "can the buyer assume responsibility?" for shipment of products from us the answer is 99% no, and also there are fines up to hundreds of thousands of dollars and 1 year imprisonment for trying this so it would not be worth attempting even if you can find the 1% loophole.
That's our current state of understanding. It's not easy to start an electronics company, especially if you want to do it legally, especially if you want to sell everywhere!
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1.- Be in Europe Union
2.- ....