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.
The Radio Equipment Directive (RED) – 2014/53/EU – has been published in the Official Journal. This Directive is replacing the RTTE Directive (1999/5/EC).
You can read more about the changes in the new RED in a previous Compliance Today post.
May 22, 2014 – Publication in OJ
June 12, 2014 – Entry in force of RED
June 12, 2016 – Member states transposition period end date
June 12, 2016 – RTTE Directive 1999/5/EC repeal date
June 13, 2016 – Member states must apply the new RE Directive by this date
June 13, 2017 – Products compliant with the old Directive market placement end date
MET Labs is a leading provider of EMC and Wireless Testing services. Contact us today to test your radio equipment devices for Europe or any other major global market.
The FCC released a First Report and Order (ET Docket No. 13-49) on April 1, 2014 allowing devices in the U-NII-1 band to operate with higher power. The R&O also allows this band to be used outdoors, whereas this has only been an indoor band previously. Some of the key points in the First R&O are:
- Devices operating in the U-NII-1 band will be allowed 30 dBm (1 W) conducted power, a PSD of 17 dBm/MHz and an allowance of a 6 dBi antenna. However, the maximum EIRP above 30 degrees elevation is limited to 21 dBm.
- The upper edge of the U-UNII-3 band has been extended by 25 MHz. Therefore, the band is now 5.725 – 5.850 GHz which is in line with the 15.247 DTS band. Both rule parts will be consolidated.
- Bin1 radar waveform will be updated to better account for actual Terminal Doppler Weather Radar (TDWR) waveforms.
For equipment that is already certified, a Class II Permissive Change may be performed to update the device to the new rules. A Class II PC is performed when there are changes to the radio, such as addition of new antenna or if a rule change allows for additional provisions.
The new rules will take effect 30 days after being published in the Federal Register. The publish date is expected soon.
The FCC has also updated the TCB Exclusion list. The exclusion list is now “empty.” Therefore, TCBs can now grant almost all applications, including equipment operating in the DFS bands and UWB equipment. However, TCBs will have to follow a Permit But Ask (PBA) procedure with the FCC to grant these devices. DFS equipment will still be independently tested by the FCC as before. But this is still expected to reduce the time to market for manufacturers.
The R&TTE Directive is getting a face lift. It will now be called simply the Radio Equipment (RE) Directive. Telecommunications equipment will be moved over to the EMC Directive. The RE Directive will be limited to wireless RF transmitter devices and receivers. The use of the exclamation mark (i.e. !) and the NB number (if applicable) will not be required adjacent to the CE mark.
EN 300 328 v1.8.1 will become effective end of the year and any new radio device placed on or after this date will need to meet the new standard. The previous version of the standard will cease to give presumption of conformity with the requirements for Article 3(2) of the Radio Equipment Directive.
The new Radio Equipment Directive (RED) was adopted by the Members of the EU Parliament (MEPs) on March 13, 2014 by 550 votes to 12. It is now awaiting approval by the EU Council and then publication in the Official Journal (OJ) of the European Union. Member states will have two years to transpose the rules into their national laws and manufacturers will have an additional year to comply.
The RED will take the place of the R&TTE Directive. You can read more about this change in a previous post. The draft directive lays down harmonized rules for placing radio equipment, including cellular telephones, car-door openers and modems, on the market. The new rules aim to keep pace with the growing number and variety of radio equipment devices and ensure that they do not interfere with each other or human health.
On the same day as the vote, MEPs called for a renewed effort to develop a common charger for certain categories of radio equipment, in particular mobile phones, because it would simplify their use and reduce waste and costs.
MEPs also backed provisions in the directive that would give the authorities additional market surveillance tools to detect radio equipment products that fail to comply with the new safety rules. After an evaluation, the European Commission will identify those categories of equipment which will need to be registered before they can be put on the market. A similar database already operates in the U.S.
The next meetings of the RTTE Compliance Association (CA) and the European Union Association of Notified Bodies (EUANB) will take place May 19-20, 2014 in Amsterdam, The Netherlands. The details of the new RED will be the main subject of the meeting.
The FCC took 20 enforcement actions in 2013 against RF equipment manufacturers and vendors for violations of the FCC’s marketing rules and technical standards. These actions include enforcement of Rule Parts 2, 15, 18, 22, 24, 27, 90, and 95. Fish & Richardson P.C. summarizes FCC Equipment Manufacturer Violations from 2006-2013 here.
Four of the six largest violations (with Consent Decrees ranging from $100,000 to $280,000) involved the FCC’s hearing aid compatibility (HAC) rules. The HAC rules require handset manufacturers to report annually on their HAC compliance status, so manufacturers should expect that the FCC will continue to pursue HAC violations.
The FCC also continued its focus on Part 15 U-NII devices and digital devices. Violations involving equipment in the music industry, such as amplifiers and mixers, led to some of the year’s largest Consent Decree payments.
Effective September 13, 2013, the FCC raised the maximum penalty for most equipment violations from $112,500 to $122,500 per single violation.
The bottom line is that manufacturers and importers need to be careful about FCC compliance. Manufacturers with compliance issues can face delayed equipment approvals, contract disputes and lost sales opportunities, and even competitor or consumer lawsuits.