[Lowfer] Part 15 transmitter kits

[John Andrews]

The FCC recently fined a company for selling unauthorized pre-built AM 
transmitter kits. The company had attempted to wriggle around the rules 
by buying the unbuilt kits from another source, and then offering to 
build them for customers. Here's the text from the FCC ruling:

"We find no merit to the claim that Antique Radio Collector sold only an
assembly service of a product manufactured by a third party. We note 
that Antique Radio Collector's LOI Response included marketing material 
that stated "we [Antique Radio Collector] have your AMT3000 shipped to 
us from the manufacturer (they do not offer pre-built transmitters), 
build and test it for you and then ship your AMT3000 ready for use." 
Thus, in its LOI Response, Antique Radio Collector submitted evidence 
demonstrating that Antique Radio Collector assembled SSTRAN AMT3000 
transmitters and advertised these devices in connection with the 
assembly service. While "kits," as defined in Section 15.3(p) of the 
Rules, are not generally subject to equipment authorization 
requirements, we have found that the sale and shipment of an 
unauthorized device assembled from a kit violates Section 302(b) of the 
Act and Section 2.803(a)(1) of the Rules, regardless of the identity of 
the kit manufacturer."

The complete document may be found at:
http://www.fcc.gov/eb/Orders/2007/DA-07-4716A1.html

So, I guess that it's still OK to market Part 15 transmitter kits 
without formal authorization, but don't offer to build them for someone.

John Andrews, W1TAG