Librem 5 FCC Certification

I checked the box
hold your order until CE/FCC is available
I received my Librem 5 in France on February 3, 2021

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Did they confirm that your phone is certified? Did you find a Declaration of Conformity in the box (EDIT: that might be optional to be included)?

They put those FCC/CE marks everywhere since a few months ago, but they still ask (as of March 11, see above) ask in emails if you want " hold your order until FCC/CE is available". And they never announced yet that they completed the certifications. I think you received it by mistake.

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Purism still hasn’t applied for FCC certification according to the FCC web site. Companies in a hurry can do the testing in 4-6 weeks and then the application to the FCC should take 1-2 weeks. If the holdup was the cameras, then hopefully Purism can now send in the L5 for testing.

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Maybe. Mistakes do get made but …

There is some uncertainty as to what “hold your order until CE/FCC is available” means. It could mean “CE/FCC, whichever is relevant to the location of the recipient”. If CE is available and FCC is not available (yet) and the recipient is in France then maybe it’s OK.

If it means “both CE and FCC must be available” then at the current time it looks like a mistake.

Considering it’s two months since @bjm received the Librem 5, maybe the care factor is not there but if someone cares then the right approach would be to ask Purism support what the question means and follow up from there if appropriate.

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Yes, the holdup was the cameras:

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But if Purism gets the Librem 5 FCC and CE certified now, then they won’t have an excuse later, for not ramping-up shipping, because of FCC and CE non-certification later.

I can see the article now. It might say something like “…after the global supply chain caught up in mid-2022, we were notified by the FCC and the authorities in Europe, that shipping of the Librem 5 within the US and Europe can’t proceed until we first start and complete each respective certification process”.

Aw shucks. I guess we should have thought ahead about that in 2021. Who would have thought that shipping ramp-up would have to wait until sometime in 2023 now?

To Purism: I really hope you’re working from a pre-release and post-release check list. If these certifications aren’t on those check-lists, please add them now, before someone forgets about them.

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Here in the US, I don’t think you can get nor need more than one type of FCC certification on the same device. For an example, if your device is certified for FCC Part 90 (Land Mobile Radio - business band transceivers), you don’t also need to have a Part 15 (for non-intentional RF radiators) certification also on the same device. If the camera is not an intentional RF radiator, then Purism should have no valid reason to wait to get compliance testing done and apply for the FCC certification. All testing will automatically include tests on the whole phone, with respect to unintended RF radiation included. Intentional rf radiators are parts of an application that were created for the purpose of transmitting radio waves. If the camera is there and happens to prevent the phone from complying as an intentional rf radiator, wouldn’t purism want to know that now as opposed to finding out later?

These kinds of excuses, serial steps and accompanying excuses are what needs to end. By now, Purism should have applied for FCC certification. There should be certification laboratories that have tested the Librem 5 by now and either found the Librem 5 to be within compliance, or to let Purism know which tests are failing, so that Purism can work in those issues now, in parallel with everything else they are doing. The certification process should not wait until everything else is perfect on the phone. Everything should be worked on in parallel, not one fearful step at a time, followed with excuses and shipping delays.

Let’s say that Purism really is ramping-up on the Librem 5 and then they find that unintended noise is coming from the camera module and so a board re-design is needed. Let’s say that this is only discovered in the FCC compliance process. You would say “why did Purism wait so long to find this out?”.

Another scenario is where Purism gets an early compliance test that has the Librem 5 passes all tests. Then after they get the camera working and after that, the phone will no longer pass those same tests. Where you start looking to resolve the issue? The camera module.

But if you take one fearful step at a time, there is no R&D synergy. The bad news always comes along and negates several successes and then you have to start over several times. There should be so many Librem 5 failures in those FCC compliance testing laboratories that someone at Purusm is on a first-name basis with their counterpart at the compliance testing laboratory. They work together and learn from eachother. This scenario sure beats showing up at the testing laboratory after your device has ramped-up production and been shut down by the FCC. So Todd shows up and says “hi, you don’t know me but by this report you wrote, my Librem 5 fails your compliance testing for a thousand reasons”. Then the next day he writes an article, blaming the compliance testing laboratory or the FCC and announcing yet more shipping delays

This may seem like extreme possible scenarios. But Purism should be working with the compliance testing laboratories and writing articles about that process. This most likely explains how Purism is only taking small baby-steps and mostly in series where any mis-step stops the whole process (and it does). They need to do a lot more things in parallel. And that includes FCC compliance testing.

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Purism does not only sell in the US.

The FCC only has jurisdiction in the US. So FCC certification should have no bearing on the customers outside the US?

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I personally have no idea, but

I can’t speak for why that post didn’t just use CE, but everything I’m aware of for Germany pertains to the CE marking as that is the relevant equivalent for Europe. FCC certification does not guarantee CE and vice versa.

When selling to both markets you would want both certs, but they are independent of each other as they have 2 separate jurisdictions.

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I don’t know how the CE certification works. I only omitted any mention of it in my posts because I don’t know much about it and not because I don’t think it’s important. My point is that Purism being a US company, they should get the FCC certification first and most importantly when it comes to their own survival and the overall success of the Librem 5. Purism doesn’t have to deal with import issues in the US. But if the FCC shuts down Purism’s sales of the Librem 5 in the US, they don’t have a product to sell except possibly outside of the US and then only by sending an uncertified product through customs of various other countries. So if Purism did only one thing, they should get that FCC certification… which they haven’t done yet. Second to that, they need the CE certification also. If Purism were based in Europe, I would think that CE certification should be the most important and come first.

At work there is a restaurant that has a section where you can order grill items and the cook makes your lunch right there where you can watch the food cooking and being prepared. A new chef started work there one day. With a line of between five and ten people, he would take only one order. After he finished preparing that one order and handing it to the person who ordered it, he would then take the next order. The previous chef would keep four or five meals cooking all at the same time as he rushed from one meal to the next, to keep them all going at once while preparing the rest of each meal as everything cooked for several meals at once. On this new chef’s second day, someone ordered a hamburger. The second guy in line said “hey, can you throw one of those on the grill for me too?”. The chef said “wait, wait, this is too much at once”. That chef didn’t last long. The way that Purism is handling their development and release of the Librem 5 reminds me of that chef who couldn’t cook more than one hamburger on the grill at once. Although they do have many parts of the Librem 5 project going at the same time, most new product teams carry-out a huge number of actions in parallel as all required steps are represented by different team members who keep moving their respective parts of the process moving. If one function lags, the whole product timeliness also slips. The way Purism is handling the release and ramp-up of the Librem 5 reminds me of that chef, who got confused if someone asked him to throw a second patty on the grill. I hope they’ve identified and contracted for any required lab work to get the Librem 5 FCC and CE certified. If they haven’t started on that part by now, they are like that chef who is afraid to throw that second hamburger patty on the grill before the first one is finished.

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Question to all Evergreen owners: Is there a CE mark somewhere on the device?

It appears so

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Both FCC and CE marks are on the box too.

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In projects there can be actions that depend on other actions to be finished first yielding a sequential order of actions while other actions can be done in parallel because they don’t have such dependencies. That’s the case for building a phone and for cooking meals.

It has been written that the camera has to work to finish FCC certification so there is such a dependency. As the camera support is on its way we hopefully see FCC certification progress.

Also you may have many actions that can be processed in parallel but if you only have a small number of people this is a bottleneck which reduces paralellism.

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See: https://fccid.io/2AT9R-LIBREM5

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Reading the link, it looks like the L5 is now FCC certified! Awesome!

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I’m relieved that there will no longer be questions about the FCC certification.

If anyone wants to read the documents from the FCC tests, they are available here:
https://apps.fcc.gov/oetcf/eas/reports/ViewExhibitReport.cfm?mode=Exhibits&calledFromFrame=Y&application_id=EyPB2%2BlYJby%2BsY6aQJj3mQ%3D%3D&fcc_id=2AT9R-LIBREM5

Just some random info for people who are curious:

  • It only took 5 days for the FCC certification to be granted. Purism submitted the FCC application on July 17 and it was granted on July 22. In contrast, it took 10 days for the PinePhone.
  • The actual testing took place in Shenzhen LCS Compliance Testing Laboratory Ltd. between April 26, 2021 and May 31, 2021, which issued its report on June 18, 2021. It took 3 months to get the FCC certification from the start of the testing, which is relatively slow. I have heard of companies getting their FCC certification in less than 2 months.
  • I can’t find any mention of which cellular modem was tested in the documents, but I would assume that it was the Broadmobi BM818, and Purism will have to do separate testing for the PLS8 modem.
  • I was disappointed that Purism requested that the following information that was submitted to the FCC not be publicized since Purism considers it to be confidential: Schematic, Block Diagram, Parts List, Operational Description, Tune-up Procedure, and Declaration of Software Security Requirements For U-NII Devices. I don’t see any reason why Purism should hide this info from the public.
  • I was happy to see the photo of the 18W charger, which supports USB Power Delivery 3.0 at 5V-3A, 9V-2A and 12V-1.5A.
  • I can’t figure out how to compare the L5’s SAR measurements with other phone models. For example, here is what is listed for the Xiaomi Redmi Note 10 Pro at gsmarena.com:
SAR 1.09 W/kg (head) 1.06 W/kg (body)
SAR EU 0.60 W/kg (head) 0.99 W/kg (body)

I can’t find this info listed as clear numbers in the L5’s documents. Does anyone know which numbers are being used?

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Schematic:

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