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.
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.
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.
Earlier this month, MET Labs attended the FCC Telecommunication Certification Body (TCB) Council TCB Workshop in Baltimore. Here was the agenda.
Some highlights from the workshop overview:
Equipment authorization certifications continue their upward trend, reaching nearly 12,000 in 2010.
98.5% of products were approved by TCBs, continuing the downward trend of TCB exclusions.
An increasing number of complex devices are creating new challenges, like additional Permit But Ask (PBA) requests (see below for the latest on PBA).
The first potential FCC ID revocation raised some questions on the process.
FCC identified complex products as a challenge for the equipment authorization program. Following are their focus areas:
- Continued updating of technical expertise of laboratory testers, reviewers, and assessors
- Detailed review of operations descriptions
- Challenges for timely review considering volume of applications
Knowledge Database (KDB) publications since January 1, 2011 include:
Administrative and General Policies
628591 – TCB Exclusion List (02/24/11)
442812 – Software Defined Radio Guidance (02/24/2011)
388624 – Permit But Ask (02/03/2011)
388624 – Permit But Ask (04/04/2011)
996369 – Modular Equipment Guide (02/03/2011), Draft
178919 – Permissive Change Policies (02/24/2011), Draft
594280 – Software Configuration Control (02/24/2011), Draft
848637 – DFS Client Device Guidance, Draft
634817 – Frequency Range Listing, Draft
Measurement guidance publications since January 1, 2011 include:
EMC Measurement Procedures
662911 – Multiple Input-Output Guidance (04/04/2011)
Hearing Aid Compatibility
285076 – Hearing Aid Compatibility Guidance (02/03/2011)
DVDs of the April 2011 TCB Workshop are available for pre-order.
The next TCB Workshop will be October 25-27, 2011 in Baltimore.
Find out more about FCC TCB Certification.