FCC Incorporates ANSI C63.4-2014 and ANSI C63.10-2013 into Rules for Unintentional and Intentional Radiators
On December 30, 2014, the U.S. Federal Communication Commission (FCC) issued a Report and Order in ET Docket No. 13-44, updating the Commission’s radiofrequency (RF) equipment authorization program to expand the use of FCC-recognized Telecommunications Certification Bodies (TCBs) like MET Labs as a faster and less expensive way to certify equipment. The new rules outsource the entire certification process to TCBs, in order to speed the introduction of new and innovative products to the market while ensuring that they do not cause harmful interference.
Updating Measurement Procedures
The FCC is updating equipment measurement requirements by incorporating references to ANSI C63.4-2014 and ANSI C63.10-2013 into the rules, for determining the compliance of unintentional and intentional radiators, respectively.
The new rules go into effect 30 days after publication in the Federal Register, but the FCC is providing a one year transition period for ANSI C63.4. During this transition, parties may continue to comply with either ANSI C63.4-2003, ANSI C63.4-2009 or with the new ANSI C63.4-2014. After the transition period, only compliance with ANSI C63.4-2014 will be accepted. The FCC will apply the same one-year transition period for use of the new edition of ANSI C63.10-2013.
The FCC continues to believe that there is insufficient evidence that rod antennas, artificial hands or absorber clamps produce accurate, repeatable measurements, and that short-duration emissions can produce as much nuisance to radio communications as continuous emissions. Therefore, the FCC will continue to exclude ANSI C63.4-2014 sections that allow for these methods.
The FCC also addressed the so-called “2 dB rule,” which is a method used to limit the amount of testing needed by determining the worst-case equipment configuration. ANSI C63.4-2009 included a change from ANSI C63.4-2003 that revised this procedure, but some industry stakeholders were concerned that this change would lead to substantial increases in costs. To reduce potential burdens on equipment manufacturers, the FCC will continue to accept the use of the 2 dB method in ANSI C63.4-2003 for demonstrating compliance with the requirement in Section 15.31(i), at least until the FCC adopts further revisions to the standard.
On a related matter, the FCC remains unconvinced that it should allow the use of the measurement procedures in CISPR 22 for unintentional radiators, as an alternative to the ANSI-ASC standards being incorporated into the rules at this time. The FCC also noted that the use of the ANSI C63.4-2014 standard is an improvement over the 2009 standard, in that it provides a means for the use of hybrid antennas that is appropriate and reliable for providing accurate radiated emissions measurements.
The new FCC equipment authorization program also includes a new surveillance element for already-certified equipment. This is something that has been integral in other product compliance programs, like the U.S. NRTL product safety program.
Manufacturers need to maintain methods for ensuring that their equipment continues to meet the specifications certified under the new procedures. The FCC codified the guidelines currently appearing in its Knowledge Data Base (KDB) for conducting post-market surveillance, placing them into Section 2.962 of the Commission’s rules as mandatory requirements. In addition to performing post-market surveillance on devices selected by the TCB, the FCC’s Office of Engineering and Technology (OET) may select samples for the TCB to test. This is designed to prevent a manufacturer or TCB from selecting “golden samples” that may misrepresent the actual behavior of the equipment.
Have questions about the new requirements or need a free quote for continued FCC compliance? Contact us today.
With Wi-Fi device shipments now in excess of 10 billion, the Wi-Fi Alliance® continues to innovate, developing new certification programs to support new technologies. A list of current work areas can be found here. To highlight a few:
- Wi-Fi Aware™ – a power-efficient proximity-based technology that identifies nearby users without connecting to the Internet (Certification program expected in late 2015)
- Extended Range ah – The developing IEEE 802.11ah standard will extend W-Fi’s usefulness for new device categories and applications with very constrained power requirements and need for long-range connectivity
Wi-Fi Alliance is also developing a 60 GHz certification,WiGig CERTIFIED™, a program that came from its WiGig Alliance unification in 2013. Although the best use for 60 GHz has not been determined yet, some companies use it for backhaul in cellular networks and cable replacement in the home or office.
MET Laboratories has been working with the Wi-Fi Alliance since 2013, and recently added Authorized Test Lab (ATL) accreditations. MET now tests and certifies devices for Wi-Fi CERTIFIED™ n and related standards a, b, g, WPA2, and WMM. This accreditation is a natural extension of MET’s deep experience in wireless testing and certification.
Right on the heels of EN 300 328 Version 1.8.1 becoming effective on December 31, 2014, Version 1.9.1 is expected to be published this year. Since there were significant changes between ETSI’s V1.7.1 and V1.8.1, it’s natural that electronics manufacturers are wondering what changes are in store for V1.9.1.
What is anticipated to become final harmonized standard EN 300 328 Version 1.9.1 is currently draft Version 1.8.2, which was released in April 2014. The overall scope and the essential requirements of the standard remain the same, but there are changes that include new and revised definitions, modifications to the limits, and simplification and clarification of test methods. Following are four important changes in V1.8.2.
Frequency Occupation Options
For frequency hopping equipment, the requirement for Minimum Frequency Occupation was renamed to Frequency Occupation, and it now includes two options for compliance, one being an occupation probability.
Dwell Time Definition Change
Also for frequency hoppers, the definition of Dwell Time was clarified in V1.8.2 and the conformance requirement for Dwell Time was renamed to Accumulated Transmit Time.
Adaptivity for Non-FHSS Devices Modification
The Adaptivity conformance requirement for non-frequency hopping devices using Listen Before Talk (LBT) was modified to remove the confusing random variable ‘R’ and value ‘q.’ Instead, to simplify the test methods, the Clear Channel Assessment time and Channel Occupancy time in V1.8.2 are fixed values, or a range of fixed values.
Emissions Requirement Change
The transmitter unwanted emissions in the spurious domain and the receiver spurious emission requirements have also changed. V1.8.2 includes a clarification on the requirement for both conductive and radiated measurements. The test procedures for spurious emissions were also modified and slightly better defined in the draft of V1.8.2.
There are other changes in V1.8.2, contact MET for more information.
While we wait on EN 300 328 Version 1.9.1, Version 1.10.1 is already on the horizon; a task group has been commissioned to work on it. We’ll let you know when its content is known.
If you sell products in Europe with 2.4GHz transmitters, contact MET for a free quote for EN 300 328 testing for R&TTE Directive CE marking. MET is deeply experienced in all types of wireless testing, including for the Wi-Fi Alliance.
Wireless modules are increasingly being integrated into everyday products, like refrigerators, cars, and consumer medical devices. Therefore, more manufacturers need to be aware of the regulatory requirements of wireless transmitters.
In the European Union, it is mandatory that radio equipment meets the requirements for the Radio and Telecommunications Terminal Equipment Directive (R&TTE) 1999/5/EC (replaced in June 2016 by the Radio Equipment Directive 2014/53/EC).
The manufacturer of the wireless-enabled product is responsible for its overall compliance. Module manufacturers must provide clear instructions of integration to any host product manufacturer.
Since the R&TTE Directive does not make specific reference to wireless modules, there are no strict rules to follow, but there are a few general guidelines to keep in mind:
- When an R&TTE compliant module is integrated into a final host product, no further radio compliance testing is required, provided the module is integrated in accordance with its manufacturer’s instructions
- The final host product must always meet the other essential safety and EMC requirements of the directive
- The most common method of demonstrating compliance and a presumption of conformity with R&TTE is by using harmonized standards
The R&TTE Compliance Association has issued guidance on the use of wireless modules: Technical Guidance Note 01 on the R&TTED compliance requirements for a Radio Module and the Final Product that integrates a Radio Module, May 2013.
In the U.S. and Canada, the approval process is straightforward, unless there are multiple modules integrated together.
The Federal Communications Commission’s (FCC) rules on module integration are explained in CFR 47 Part 15.212, with further detail in the guidance document KDB 996369. The Industry Canada rules for modules are similar to those of the FCC and are spelled out in RSS-GEN Section 3.
In order for a wireless module to meet the requirements of FCC Part 15, it must comply with the requirements for shielded circuitry, a unique antenna connector, stand-alone configuration, and RF exposure limits. Once these guidelines are met, FCC modular approval is granted through a TCB like MET Labs, and the product may be operated under certain conditions of use. If the conditions of the grant are met, further testing is not required for the intentional radiator part of the host equipment.
Where multiple modules are integrated together, the rules can become more complex. This is particularly true if the host device is to be used in a portable application within 20cm of the human head or body and RF exposure becomes a major issue. Then SAR testing is required.
Where the conditions of the modular grant cannot be adhered to when integrated into the final host, additional testing and certification is usually required.
To learn more about wireless compliance, attend our upcoming EMC & Wireless Design and Testing Seminar in Santa Clara, CA. If you have an upcoming need for wireless equipment testing or compliance assistance, contact us today.
When an RF product is revised due to obsolete parts, cost cutting, or product improvements, how does the engineer know what the FCC requirements are for the altered product? Will it require a new FCC filing and ID number or will a Permissive Change be allowed?
To allow products to be modified without requiring a new filing, the FCC has defined three Permissive Change options listed in Title 47 Part 2.1043, KDB 178919 D01 Permissive Change Policy v05r04.
Class I Permissive Change
This class includes modifications which do not degrade the characteristics accepted by the FCC when certification is granted. No filing with the Commission is required for a Class I Change.
Class II Permissive Change
This class includes modifications which degrade the performance characteristics as reported to the FCC at initial certification. In this case, the grantee must supply the Commission with results of tests of characteristics affected by the change.
Class III Permissive Change
This class includes software modifications of a software-defined radio transmitter that change the frequency range, modulation type or maximum output power (either radiated or conducted) outside the parameters previously approved.
In this case, the grantee must supply the FCC with a description of the changes and test results showing that the equipment complies with applicable rules with the new software loaded, including compliance with applicable RF exposure requirements.
Class III changes are permitted only for equipment on which no Class II changes have been made from the originally approved device.
For any of these changes, modified equipment cannot be marketed under the existing grant of certification prior to acknowledgment by the Commission that the change is acceptable.
In summary, changes to a modular radio or product will result in either a Permissive Change or a new FCC filing and ID number. The degree of change will determine both the process and the amount of supporting data required to illustrate compliance.
With few exceptions, a new FCC ID and a new equipment authorization application will be required in the event of changes to the basic frequency (including clock and data rates), frequency multiplication stages, basic modulator circuit, or maximum power or field strength ratings.
On October 16, 2014 the FCC published 726920 D01 Confidentiality Request Procedures, a new document that details the steps required to ensure proprietary information about your device will be held confidential.
To be granted confidentiality, your application must include a reference to 0.457(d) and 0.459 of the FCC Rules, the reason why the information should be held from the public, specific confidential information by exhibit type, name, and description, an indication if the information is a “trade secret,” a signature, and the type of confidentiality requested. Confidentiality Letters must specifically reference the documents you wish to withhold from the public.
The two types of confidentiality are long term and short term.
Under long term confidentiality, the following exhibits are held private without filing a request:
- Software defined radio, cognitive radio attachments submitted into the SDR software, security info exhibit type
- Scanning receiver information included in one of the exhibits noted as “commonly held confidential” and scanning receiver internal photos
Under long term confidentiality, the following exhibits can be held private upon request:
- Block diagrams
- Operational descriptions
- Parts list/tune up info
Under short term confidentiality, exhibits held private are the same as long term confidentiality, plus:
- External photos
- Test set up photos
- Internal photos
- User manuals
Short term confidentiality can only last up to 180 days. If you request short term confidentiality but market your device before the 180 day period is over, you must notify your Telecommunication Certification Body (TCB) so your confidentiality request can be removed.
If you are seeking confidentiality for an exhibit not listed above, you are able to petition the FCC and all approvals are made on a case-by-case basis.
Read about how Some Electronic Devices Are Exempt from FCC EMC Testing.
The European Union EMC Directive 2004/108/EU has been revised to the new Directive 2014/30/EU. After April 2016, the new directive will be required for all applicable electrical products being sold in the European Union.
Requirements listed in Annex I of the directive remain the same. But 4 key changes have been made:
- The directive now applies to distributers and importers, not just manufacturers
- Additional information is required in the technical file
- DoCs now need to be multilingual
- Notified Body requirements have been updated
In order to maintain EMC compliance, a few steps can be taken. First, be sure that all harmonized standards listed on the reports are current. Review your technical file and ensure that all operators’ information and technical instructions comply with Article 18. Your updated DoC should reference 2014/30/EU and clearly identify the product you wish to sell.
Also, read about the new Radio Equipment Directive for CE marking radio equipment.
To accommodate changes in the Federal Communication Commission’s (FCC) Docket 13-49, the Dynamic Frequency Selection (DFS) test procedure document KDB 905462 D02 UNII DFS Compliance Procedures New Rules has been issued.
The document describes the compliance measurement procedures for performing DFS tests under FCC Part 15 Subpart E Rules required for U-NII (Unlicensed –National Information Infrastructure) equipment that operates in the frequency bands 5250-5350 MHz and/or 5470-5725 MHz.
A U-NII network will employ a DFS function to detect signals from radar systems and to avoid co-channel operation with these systems.
Section 6 provides the parameters for required test waveforms, minimum percentage of successful detections, and the minimum number of trials that must be used for determining DFS conformance.
One of the new requirements is for devices to detect a new radar waveform for DFS testing. Historically, the FCC has required devices to detect 5 radar types. The new rules require detection of a 6th radar type which they designated as Type 1. A previous waveform which was designated as Type 1 is now called Type 0. See the accompanying Table 5.
These rules became effective on June 2, 2014. FCC has established a transition period:
- New devices will be permitted to be approved until June 1, 2015 under the old rules
- Starting June 2, 2016, all devices approved partially or completely under the old rules cannot be marketed, and permissive changes will not be permitted for devices approved under the old rules, unless they meet the requirements of the new rules
MET Labs has the capability to generate the new radar type using Agilent hardware coupled with custom software. Get tested to the latest DFS requirements on new products or update an existing product with a Class II Permissive Change. Get a free quote now.
On July 11, 2014, the FCC’s Office of Engineering & Technology (OET) released new guidance giving some consumer electronics manufacturers more flexibility in digitally labeling (e-labeling) their products.
The guidance advises that all devices with an integral (non-removable) screen can now display that label digitally on that screen, and up to three steps deep into the device menu. The user manual must include information on accessing that FCC info, or it can be on the equipment’s Web site.
Removable labels with the FCC info must still be on the product or its packaging when it is shipped and sold.
Formerly, the FCC required equipment that requires FCC certification to have a fixed nameplate or etched label (see the iPhone hieroglyph) listing its FCC ID and any other requirements of operation.
The benefits of e-labeling include:
- Cost savings, especially as devices become smaller
- The potential to provide more information, like recycling or trade-in opportunities
- The ability to update information remotely to address any inaccuracies
The FCC had already permitted e-labeling for a small subset of devices. In 2001, the Commission’s rules authorizing software defined radios (SDR) permitted the voluntary use of e-labeling by device manufacturers.
Meet with MET at Super Mobility Week, North America’s largest forum for mobile innovation, powered by CTIA.
Most electronic devices destined for sale in the U.S. fall under Part 15 (CFR 47) of the Federal Communications Commission (FCC) rules for limits to the unintentional and intentional emission of radiation. However, there are some exemptions that you may be able to take advantage of, depending on the nature of your product. You can find the bulk of this information in Section 15.103 of the rules.
The FCC says it is “strongly recommended” that you still attempt to comply with the rules, regardless of your product type. They have the power to halt sales of your device if the device has been found to cause harmful interference, so proceed with caution.
Here is a simplified description of product types that are FCC exempt from digital emissions testing:
- A digital device utilized exclusively in any transportation vehicle including motor vehicles and aircraft. Note: wireless devices are subject to other FCC rules.
- A digital device used exclusively as an electronic control or power system utilized by a public utility or in an industrial plant.
- A digital device used exclusively as industrial, commercial, or medical test equipment.
- A digital device utilized exclusively in an appliance, e.g., microwave oven, dishwasher, clothes dryer, air conditioner, etc.
- Specialized medical digital devices (generally used under the supervision of a licensed health care practitioner) whether used in a patient’s home or a health care facility.
- Digital devices that have a power consumption not exceeding 6 nW.
- Joystick controllers or similar devices, such as a mouse, used with digital devices but which contain only non-digital circuitry or a simple circuit to convert the signal to the format required (e.g., an integrated circuit for analog to digital conversion).
- Digital devices in which both the highest frequency generated and the highest frequency used are less than 1.705 MHz and which do not operate from the AC power lines. Digital devices that include battery eliminators, AC adaptors or battery chargers which permit operation while charging or that connect to the AC power lines indirectly do not fall under this exemption.
Although not noted in section 15.103, equipment authorization is also not required for:
- Personal use home-built devices (not kit-constructed) that are assembled in quantities of five or less
- Low-frequency devices that don’t generate timing signals or pulses at a rate in excess of 9,000 pulses (cycles) per second (i.e., 9 kHz)
Note that equipment is not exempt unless all of the devices in the equipment meet the criteria for exemption. For example, if you have a specialized medical digital device with a wireless transmitter, the wireless transmitter still has to be tested.
Please confirm with MET Labs whether you are indeed exempt as there are some caveats to this information.
And, of course, FCC-exempt devices might be required to undergo other types of testing, like product safety certification for U.S. OSHA compliance or EMC testing for CE marking in Europe. Contact MET for a full evaluation of your product line and its intended markets.