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There have been 5 comment(s) made on this document:
  • Brian Scarpelli commented on 2014-06-13 18:25:44.623:
    Please see attached for the comments of the Telecommunications Industry Association. Brian Scarpelli Director, Government Affairs Telecommunications Industry Association (TIA) d: 703.907.7714| m: 517.507.1446 BScarpelli@tiaonline.org | tiaonline.org View attachment associated with this comment
  • Praveen Rao commented on 2014-06-13 10:44:04.293:
    Fujitsu thanks FCC for updating the electronic labeling KDB. The allowance of e-labeling helps and benefits Industry enormously. However, there are some major impediments in the proposed draft which can deter the full utilization of this KDB. Following are our comments on Draft KDB 748748 D02 e labeling DR01-41768. 1. Section I. Introduction: This guidance is to be made applicable to all devices that have display capability and not just devices subjected to “certification” type requirements. Please make this applicable to DoC, Verification, Certification with FCC ID via modular or system approvals. 2. Section IIc. Removable Adhesive Labeling seems to partially defeat the purpose of e-labeling. If the intention of this is for importation and visibility of ID to the purchasing customer, the ID is on the packaging box. A leaflet or flyer with printed ID to be included in the packaging of the product can be another option but is still not preferred as an additional requirement. Alternatively a feasible much preferred option is to show the webpage URL on the packaging. This webpage must be easily accessible and have all required information. This can eliminate the need for other forms of physical labeling. Please consider and remove this additional requirement.
  • Mark Arthurs commented on 2014-06-12 15:21:52.433:
    Sony agrees with the proposal to allow the use of e-labeling. We do have several concerns and requests. We have many products with displays that are subject to DoC or Verification level of authorization and would like these products also to be able to take advantage of e-labeling. The benefit of e-labeling is diminished by the requirement to use a detachable seal or label. One of the benefits for using e-labeling is to reduce the costs and the requirement for a detachable label would reduce this benefit. If necessary to include the label information with the product we suggest that an option to include printing the information on a plastic bag wrapping the product or a leaflet bundled with the product be allowed. Sony believes that providing the label information on the plastic wrap or leaflet is also not necessary and believe that the requirement specified in b iii “Users must be provided specific instructions on how to access the information. The instructions may be included in the User’s manual, operating instructions, insert in the packaging materials, or other similar means. The access information must also be available on the product related website.” is sufficient. We also have a concern about the requirement in d ii. “ Product packaging material must display the FCC ID and, if applicable, the Doc logo as required by the applicable rules. “ This might be confusing as we are not aware of a requirement to place the FCC ID or DoC logo on the product packaging.
  • Jack Parmentier commented on 2014-06-06 08:10:52.253:
    Lenovo supports the proposed updates to the e-support requirements as identified by the FCC. In addition, Lenovo also supports the changes and additional requirements as identified by Hewlett Packard in their comments from 6/2/2014. The allowance of the use of a QR code or web-site URL would be very beneficial to the customer, shipping agent, or customs official to verify the FCC ID for the product. Best regards, Jack Parmentier Lenovo WW Homologation Team Lead
  • Walter Overcash commented on 2014-06-02 11:11:59.186:
    Please see the comments from the Hewlett-Packard Company attached. View attachment associated with this comment

Note: It is important to understand that the staff guidance provided in the KDB is intended to assist the public in following Commission requirements and does not constitute rules. Accordingly, the guidance is not binding on the Commission and will not prevent the Commission from making a different decision in any matter that comes to its attention for resolution.