At the recent TCB Council Workshop in Baltimore, TCBs – including MET Labs – were given a refresher on the fundamentals of modular approvals.  Here is a summary.

In the U.S., wireless module approvals fall into one of three categories:

• Full modular approval – A radio module to be approved for use in any host and sold to anyone
• Limited modular approval – A radio module to be approved for restricted use
• Split modular approval – A radio module where the transmitter firmware is held on a host

FCC Full Modular Approval
Full approval is defined in FCC Part 15.212.  The module will have the FCC ID; any host incorporating the module will show that the module is contained within it: Contains FCC ID: XXXYYYYY. 

There are 8 criteria for full approval:

1. Transmitter must have its own shield
2. Must have buffered modulation/data inputs
3. Must have power supply regulation
4. Must meet Part 15 antenna requirements
5. Must be tested in stand-alone configuration
6. Must be labelled with the FCC ID
7. Must meet its own FCC rule part
8. Must meet RF exposure requirements

The module host must still comply with its own requirements (e.g. Part 15B, Verification or DoC).

FCC Limited Modular Approval
FCC limited approval is for modules that don’t meet all eight criteria for full approval.  Limited approval is possible when the host or end environment is known:

• The module will be certified for a range or series of devices, similar in construction
• The module will be certified for use by the grantee or an authorized OEM
• The module will be tested in a representative host

FCC Split Modular Approval
Split approval can only be certified by the FCC, and is included on the TCB Exclusion List.

For module approvals, Knowledge Database (KDB) 996369 is key.  Other important KDBs include:

• KDB 784748 contains labelling requirements
• KDB 447498 contains RF exposure, MPE and SAR test guidance
• KDB 616217 contains SAR host guidance

Canada IC
Canada IC modular approvals are to RSS-GEN section 3.2, with requirements and labelling similar to FCC.  Unlike FCC, unlicensed modules use the same eight criteria as licensed modules.

For limited modular approval, guidance comes from RSS-GEN section 3.2.3, and is also similar to FCC.

MET is an FCC TCB and an Industry Canada CB.

Europe R&TTE Directive
In the EU, there is no certification or modular approval, but rather Declaration of Conformity (DoC).

A module placed on the market should be fully assessed to the R&TTE Directive (Radio, EMC and Safety), either as an independent radio or as a radio component intended for use within a host.

There are not eight criteria, so the manufacturer must assess to all possible installation environments.  By CE Marking a module, you are stating that it will comply in its intended use and environment.

For integrating modules into a host, the host company is ultimately responsible for compliance, unlike with the FCC and IC.  However, previous testing may be taken into consideration by the module integrator.  If module testing is trusted for the DoC of host, the module’s Technical Construction File (TCF) becomes part of the host’s TCF.

For the R&TTE Directive, these guidance documents exist:

• ETSI TR 102 070-1 – Application of EMC standards
• ETSI TR 102 070-2 – Application of Radio standards
• R&TTECA, TGN 01 – Requirements for a Final Product that Integrates an R&TTE Directive Assessed Module

Read about the proposed changes to the R&TTE Directive.

Japan
“Modular approvals” do not appear in Japanese radio law.  However, in July 2012, MIC announced that a module could be certified as a radio device, even if it used soldered connections, if it was the type: WLAN, Bluetooth, Zigbee, etc.  In other words, a FCC 15.247 type of device.  It is not modular approval, but it does allow soldered modules to be certified as radios.

In February 2013, MIC announced that modular approvals will be integrated into Japanese radio law.  Requirements are being developed now.  Currently, there is no timeline or estimated implementation date.

For questions or for a modular approval quote, visit our Quote Center.

We will be at CTIA Wireless next month.  Request to meet with us.

The U.S. Federal Communications Commission (FCC) has proposed important changes to its equipment testing and authorization program under Part 15 and Part 68 of its rules.  The FCC says the changes will streamline the approval process and expedite the introduction of new devices to the market.

In a Notice of Proposed Rulemaking issued last month, the FCC proposed a number of changes to its existing equipment authorization program. The key proposed changes include:

TCB Accreditation – Telecommunications certification bodies (TCBs) – like MET Labs – will be accredited in accordance with the requirements of ISO/IEC 17011 and ISO/IEC 17065. These standards replace ISO/IEC Guides 58, 61 and 65.

Testing Laboratories Accreditation – Laboratories that test equipment subject to certification or approval under any of its rules must be accredited to ISO/IEC 17025.

TCB Authority – The FCC will no longer directly issue any grants of equipment authorization. Instead, TCBs will authorize and deny all products subject to certification.

Post-Market Surveillance – For post-market surveillance, the FCC will specify the number and types of samples that a TCB must test.

Assessing TCB Performance – NIST will assess TCB performance. The Commission also outlined a process to address TCB non-performance issues.

Measurement Procedures – ANSI C63.10-2009 will be the procedure used to determine the compliance of intentional radiators, and ANSI C63.4-2009 will be the procedure for assessing unintentional radiators.

We understand these proposed changes are likely to go through without significant modification, but first there is a comment period to elicit feedback.  Comments on the Commission’s proposed rule changes are due by late March here.

Read the complete text of the FCC’s Notice of Proposed Rulemaking regarding important changes to its equipment testing and authorization program under Part 15 and Part 68.

MET Labs is an accredited testing laboratory and TCB.  Contact us for FCC Testing or Certification assistance.

At the recent Telecommunication Certification Body Council Workshop  in Baltimore, Kwok Chan and Mark Neumann of the Federal Communications Commission (FCC) Office of Engineering and Technology outlined testing and certification requirements for Consumer Wireless Charging Devices. 

Wireless Charging Device

Wireless charging devices are generally used to charge batteries in portable electronic devices via magnetic induction.  Chargers can deliver up to 5W of power, enough to charge most wireless handsets, and work at distances up to 10mm.

These products have been around since the 1990s, but only have become practical in recent years, so FCC thought it was worthwhile to cover how these devices fall into the existing regulatory compliance framework.  Following are main points from the presentation.

Authorization
Chargers and clients are generally approved separately; however, they should satisfy compliance in both standalone mode and as a system.

Wireless charging devices can be approved under Part 15 or Part 18 or both rule parts. 

Part 15 authorization required if:

• Primary charging frequency includes information not related to power management
• A secondary frequency is used for communications

Part 18 authorization for the charger and clients:

• Load and power management must be integral to wireless charging operation and frequency
• May not communicate any information not related to power management and control
• Proximity of the charger and client device(s) must satisfy Part 18 requirement that the RF energy is locally generated and used
• Other communications are authorized separately under Part 15

Electromagnetic Compatibility (EMC) considerations:

• Charger must be evaluated with appropriate client(s) in place
• The worst case transmitting conditions for the system as a whole must be evaluated for each applicable configuration: Bluetooth, WWan, WLan, etc.

Radio Frequency Exposure
Single client low power devices generally do not present exposure concerns for nearby users, but multi-client devices or short-distance power transfer can result in widely varied fields and potential exposure concerns.

For most small consumer chargers, exposure conditions identified in §2.1091(d)(4) may apply.

Specific Absorption Rate (SAR) and Maximum Permissible Exposure (MPE) limits do not cover wireless chargers operating below 100 kHz and 300 kHz, respectively.

Conclusion
The presentation concluded with two points:

• A KDB Inquiry should be submitted for guidance for wireless charger applications
• Wireless Chargers remain on the Permit But Ask (PBA) list

Contact us for safety, EMC, SAR & FCC testing of wireless charging devices or other electrical/electronic equipment.

Sign up for a Wireless Testing & Certification Seminar in Austin, Texas in December.

The U.S. Federal Communications Commission (FCC) has issued draft revisions to six Knowledge Database (KDB) publications for RF exposure and SAR compliance.

They are:

KDB Publication 447498 – General RF Exposure Policies for Equipment Authorization

• Draft revision
• Existing publication

KDB Publication 941225 – SAR Evaluation Considerations for LTE Devices

• Draft revision
• Existing publication

KDB Publication 865664 – SAR Measurement Requirements, Compliance Reporting and Documentation for 100 MHz – 6 GHz

• Draft revision
• Existing publication

KDB Publication 616217 – SAR Evaluation Considerations for Laptop, Notebook, Netbook and Tablet Computers

• Draft revision
• Existing publication

KDB Publication 648474 – SAR Evaluation Considerations for Handsets with Multiple Transmitters and Antennas

• Draft revision
• Existing publication

KDB Publication 643646 – RF Exposure Evaluation Considerations for Occupational Push-to-Talk Two-Way Radios

• Draft revision
• Existing publication

The public may post a comment on these proposed revisions through June 1, 2012.

Other RF Exposure KDBs
Remaining RF exposure KDB publications that do not have draft revisions are:

• KDB Publication 248227 – Additional SAR Measurement Procedures that Specifically Address 802.11 a/b/g Devices
• KDB Publication 615223 – SAR Requirements and Procedures for 802.16e/WiMax Devices
• KDB Publication 450824 – SAR Probe Calibration and System Verification Considerations for Measurements from 150 MHz to 3 GHz
• KDB Publication 680106 – Rules Regulating Short Distance Wireless Inductive Coupled Charging Pads or Charging Devices

Questions about SAR compliance? A SAR testing expert will be available next week at 2012 International CTIA Wireless at the MET Labs exhibit.

Get more information and pricing on SAR testing and certification.

This week, MET Labs, Federal Signal Technologies, Concurrent Technology Corporation, and OmniAir Consortium, Inc. are performing a 4th round of regression testing on Dedicated Short Range Communications (DSRC) Vehicle Awareness Devices. The testing is being performed at Southwest Research Institute in San Antonio, Texas. The Vehicle Awareness Device specification produced by the U.S. DOT has undergone updates – the latest as recent as last week – and device manufacturers have now incorporated these new requirements into their products in time for this week’s testing.

A last round of regression testing has been scheduled for December and this testing will be performed at MET Labs in Baltimore.  For testing that requires vehicles moving at certain speeds and for measurements requiring an open field, testing will be performed at New Jersey Motorsports Park in Millville, New Jersey.  In addition to using the racetrack, MET Labs has also received permission from the city of Millville to use an open adjacent field.

The December regression testing is for device manufacturers to fine tune their devices before they move into official Qualification testing in the first quarter of 2012.  Qualification testing will be performed at MET Labs. Devices that comply with the specification based on the Qualification testing will be picked for the U.S. DOT Safety Pilot Model Deployment.  The pilot will commence in late 2012 in Ann Arbor, Michigan and will include at least 2,500 vehicles fitted with these DSRC radios. The purpose of this safety pilot is to ascertain how effective these devices are in mitigating accidents involving vehicle-to-vehicle collisions.

Read about previous testing for this program.

Read about other types of automotive testing.

Last week, MET Labs attended the FCC Telecommunication Certification Body (TCB) Council TCB Workshop in Baltimore.  Here was the agenda.  

One of the workshop’s more interesting presentations was on the R&TTE Directive.  Following is a summary of the key points.

The Radio and Telecommunication Terminal Equipment Directive applies in Europe and the European Economic Area.

There is no certification for the R&TTE Directive 1999/5/EC.  Meeting the requirements is the responsibility of the manufacturer or whoever puts the device on the market.

• Products must have CE mark to show compliance
• Declaration of Conformity (DoC) must be created for each device
• Technical Construction File (TCF) is necessary to demonstrate compliance

The CE mark must be visible on the label, user manual, and packaging, and must include the Notified Body and Alert Symbol, if applicable.

The DoC must be available in each language, and must be traceable to a signatory.

The TCF must be kept for at least 10 years after the final version of each device has been made.

R&TTE Directive does not give test limits.  It instructs the manufacturer that the device must comply with certain performance requirements:

• Article 3.1a – Health (RF exposure; boundary calculations; acoustic safety; typical operation)
• Article 3.1a – Safety (EN 60950 for IT equipment; EN 60065 for Audio/Video equipment)
• Article 3.1b – EMC Performance (EN 301 489 series for radio; EN 55022 & EN 55024 for TTE)
• Article 3.2 – Radio Spectrum (output power; frequency tolerance; spurious emissions; receiver performance tests; tests at extreme voltage/temperature)

R&TTE Directive divides products into two classes:

• Class 1 – No restrictions on putting the device into service
• Class 2 – Restrictions exist for use of the device, and Country Notifications may be necessary

Ideally, all devices fall within an existing harmonized (harmonised) test standard.  If you test to a harmonized standard and pass, there is a presumption of conformity to the essential technical requirements.

Harmonized standards are listed by the European Commission in its Official Journal (OJ).   

When a standard is superseded, the device should meet the new version of the standard to stay compliant.  There is an overlap period.

A Notified Body opinion is required if harmonized standards are not fully applied in these situations:

• Device has new technology with no applicable standards yet
• New standards are not yet harmonized
• Family of products, where the standard has not been applied to some models
• Test procedures or processes of the harmonized standard were not followed

If the technology is new and no harmonized standards exist, the manufacturer works with a Notified Body – like MET Laboratories – to determine a test plan, or parts of another standard to use.  Alternatively, use a new version of a standard which has not yet become harmonized.

For most Radio and Telecommunication Terminal devices, the R&TTE Directive alone is sufficient – the EMC and Safety (Low Voltage) Directives do not apply.

R&TTE Directive was written in 1999.  The new version of the directive is being written now, with these goals in mind:

• Improve traceability to DoC signatory
• Improve compliance rates
• Improve process for dealing with non-compliant products
• Maintain equipment quality
• Maintain trade

The next TCB event is a FCC/TCB Conference Call on December 13.  The call is restricted to TCB personnel, but Associate Members can receive the call minutes.

Find out more about compliance with the R&TTE Directive.

Last week, MET Labs joined with OmniAir Consortium, Inc. to test 5.9 GHz DSRC “Here I Am” (HIA) devices at Southwest Research Institute in San Antonio, Texas. 

The purpose of the testing was to:

• Qualify devices for ITS World Congress 
• Validate procedures, standards, and specifications for device qualification and certification in support of the upcoming USDOT Connected Vehicle Safety Pilot

The ITS World Congress is the 18th World Congress on Intelligent Transportation Systems, and is the largest gathering of intelligent automotive experts, policy makers, and technology.  USDOT is incorporating these HIA devices into vehicles for demonstration purposes at this event and OmniAir was asked to screen the devices that will be used.

The second part of the screening effort was to perform a preliminary validation of test procedures, tools, specifications and standards, in anticipation of certifying these devices in support of the Connected Vehicle Safety Pilot.  In the pilot, upwards of 3,000 vehicles fitted with devices will communicate with other vehicles and the surrounding infrastructure, while operating on everyday streets in a highly concentrated area.

Four manufacturers provided two samples each of HIA devices for testing. An additional manufacturer provided one sample.

Testing involved three stages. The first was the inspection of the HIA devices and the manufacturer test reports to make sure they conformed to the HIA Device specification.

The second involved bench testing of the HIA devices. This included making sure the Basic Safety Messages adhered to the specification on a bit-by-bit basis.

The third involved installing these devices in a vehicle. The vehicle testing was broken down into two categories itself:

1. After the unit was left in the vehicle for 2 hours with no air conditioning, verified that it was functional and that the packet error was less than 5% at 300m.
2. While the vehicle moved at various speeds in a straight line and on curves, measured the location delta between a reference GPS unit and the HIA device.

Static vehicle testing was performed in a large open area. The moving vehicle testing was performed on a 1.16 mile oval track.

In the next phase, OmniAir will qualify these devices with the recommendation of MET Laboratories.  The qualification testing will include the screening program plus additional testing, comprising a full test suite. 

Read more about OmniAir’s HIA Device Qualification and Certification Testing Program.