calendar Issue 19/February 2, 2011 ACB EMC Regulatory News

Newsletter "Packets" - Wireless News and Regulatory Updates
Providing information and fielding questions for wireless manufacturers are some of the many activities that we perform at ACB. Packets provides an overview of just a small portion of the communiqués that run in and out of our office. 

In this issue

in the news 


NEWS! American Certification Body Earns EPA ENERGYSTAR® Recognition

American Certification Body has recently been recognized by the US Environmental Protection Agency (EPA) under the newly-revamped ENERGY STAR® program that requires that all new product submissions from manufacturers participating in the ENERGY STAR® program be reviewed by an EPA-recognized Certification Body (CB)

you need to know


KDB449343 – Pre-calibrated field method will NOT be accepted

Measurements to detect unwanted transmitter emissions in the spurious domain that may be radiated from an Equipment Under Test (EUT) cabinet, control circuits, power leads, or intermediate circuit elements under normal conditions of operation are required per Section 2.1053 of the FCC rules, and must be performed on a radiated basis. Additionally, radiated measurements are often required to determine the maximum output power from a licensed transmitter that features an integral transmit antenna but does not provide an access port for performing conducted measurements.

FCC laboratory policy requires the use of a signal/antenna substitution methodology, as described in Sections 2.2.12 and 2.2.17 of TIA-603-C, to perform these measurements.

The FCC has received several inquiries regarding the acceptance of an adjunct methodology, whereby a signal generator is used to radiate a signal that is swept over a pertinent frequency range and then recorded at a single point in space at a distance corresponding to the measurement distance required for compliance testing. A table of data collected from this site "pre-calibration" is then to be used to replace specific substitution procedures as described in Sections 2.2.12 (j) through (l) and/or 2.2.17 (c) and (d) of the TIA-603-C standard.

Since the pre-calibrated field methodology has not been recognized as part of an industry standard or formally submitted to the FCC for consideration, data collected using this method cannot be deemed acceptable for demonstrating compliance to FCC rules, and therefore such data will not be accepted after January 1, 2011. It is our understanding that the Accredited Standards Committee C63 - Electromagnetic Compatibility is considering related measurement procedures. If C63, or another recognized standards organization, develops alternatives to the measurement methods described in TIA-603-C, then the FCC is prepared to consider the acceptability of those alternative measurement methods.

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questions and answers



KDB 447498 D02 said the (A) Horizontal-Up USB orientation should be tested within the host computer. How about the (C) Vertical-Front, or (D) Vertical-Back USB orientation? Does it also need to be tested within the host computer? How do you understand the "remaining" Vertical USB orientation in the KDB? Does it cover C and D? Or just C OR D?

The USB dongle must be SAR tested directly connected to a laptop USB port for the Horizontal-Up (A) position. The USB dongle must be tested directly connected to a laptop USB port for one of the vertical positions, either the Vertical-Front (C) or Vertical-Back (D). For the remaining vertical position and the Horizontal-Down (B) position, you may use a 12 inch long or less USB extension cable to connect the USB dongle to the laptop USB port. You get to choose which vertical position to connect directly to the laptop; it probably depends upon what vertical USB port is available on the host laptop.

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How to test external antenna(s) for the licensed devices?

Licensed devices, such as a 3G router, that have integral antenna(s) are tested with the antenna. Removable antenna(s) are tested at the antenna port. Basically, what is done for an external antenna is antenna conducted tests as follows:

1. Measure conducted antenna power at the antenna connector (for the internal antenna, if it can be removed then remove it and measure power at that antenna port. If it cannot be removed then measure eirp/ERP).

a. If the device is in the mobile category (i.e. is not a licensed base station or cellular repeater etc) or a device which receives its own license to operate, then you must measure ERP/eirp of both the internal and external antenna port using the highest allowed antenna gain. Remember parts 22 and 24 and 27 have ERP/eirp maximums for non-base station, non-cellular repeater etc devices. See sections 22.913, 24.232 and 27.50.

b. The manufacturer cannot relieve himself of the obligation to insure that his device does not exceed the ERP/eirp limits by saying he does supply the antenna. It would have to be made clear that a maximum antenna gain restriction applies to his device is it is not licensed at the time of installation.

c. This also deals with MPE. If the device is not licensed at the time of installation, then the manufacturer MUST provide MPE calculations (and possibly MPE measurements) at the time of grant. In order to do this he would have to also limit the gain of any external antenna used for his device. This maximum gain would be listed ON THE GRANT. The ONLY way the manufacturer can get out of MPE at the time of grant is to show how he NEVER sells his device to anyone not getting a license to operate for the specific transmitter. IF he sells to ANYONE not obtaining his own license to operate, thus operating under the license of a base station (i.e. CPE equipment), then MPE and thus a maximum stated antenna gain, must be done at the time of granting of the device.

2. Measure antenna spurious power at the antenna connector. This includes spurious and harmonics as well as band edges.

3. Measure radiated spurious emissions with the external port terminated in its characteristic impedance.

a. Radiated emissions is not an alternate spurious emissions, but an ‘also ran’. BOTH conducted and radiated spurious emissions must be done on a licensed rule part transmitter.

4. Test frequency drift (voltage and temperature) for frequency and power stability at the antenna port.

5. Measure occupied bandwidth at the antenna port

6. Measure any other required test for licensed devices

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To do a DoC for the FCC, does the applicant or manufacturer need to be within the United States?

The responsible party for the applicant or manufacturer as defined in 2.909 must be in the U.S. Note this is not necessarily the applicant or manufacturer. Note from 2.909:

In the case of equipment subject to authorization under the Declaration of Conformity procedure:

(1) The manufacturer or, if the equipment is assembled from individual component parts and the resulting system is subject to authorization under a Declaration of Conformity, the assembler.

(2) If the equipment, by itself, is subject to a Declaration of Conformity and that equipment is imported, the importer.

(3) Retailers or original equipment manufacturers may enter into an agreement with the responsible party designated in paragraph (c)(1) or (c)(2) of this section to assume the responsibilities to ensure compliance of equipment and become the new responsible party.

(4) If the radio frequency equipment is modified by any party not working under the authority of the responsible party, the party performing the modifications, if located within the U.S., or the importer, if the equipment is imported subsequent to the modifications, becomes the new responsible party.

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Can a Part 15 transmitter such as an 802.11b/g, or a UNII device, allow users or professional installers to set the country code to ensure compliance; if the user’s manual contains the following statement: " WARNING: Select only the country in which you are using the device. Any other selection will make the operation of this device illegal."?

No. As specified in Section 15.202 of the rules, master devices marketed within the United States must be limited to operation on permissible Part 15 frequencies, and such devices cannot have the ability to be configured by end users or professional installers to operate outside the authorized bands. Selecting country codes for different regulatory domains is not permitted. If the device is certified for professional installation, installers may be allowed access to configuration parameters when on site (remote access is not permitted); and only the configuration parameters identified in the equipment authorization may be configured on site. Frequency selection using country codes is not permitted.

Any device meeting the definition of a client as specified in Section 15.202 may have the ability to operate on other regulatory domain frequencies if it is under control of (automatically associated with) a certified master device. In this case, the "WARNING" statement mentioned above would not serve any purpose since frequency selection, power or grant conditions would be automatic, and regulatory domain selection would not be permitted.

Many devices referred to by the WiFi industry as "client devices" may not meet the definition of a Section 15.202 client, and must be limited to operating as master devices on US frequencies, and within the grant conditions. To qualify as a Section 15.202 client, a device cannot initiate, or be configured to initiate, any transmission for any reason on non-US frequencies, or on frequencies not authorized for use. This includes probes, beacons, and ad hoc mode transmissions. Only if all features and functions that utilize initiating transmissions are within the frequencies as granted, can the device be authorized as a Section 15.202 client device. These devices can then automatically associate and operate on non-US frequencies when outside of the US, under the control of a foreign master device authorized on other regulatory domain frequencies.

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fun with emc

Antennae or Antennas?

There are two main types of antenna. There are the little things that stick out of the head of an insect (antenna) and the things which connect to radio transmitters and EMC test sites (antenna). If you have multiples, the spelling is different…

Bee If you are talking about insects and bugs, the plural of antenna is antennae.
Antenna If you are talking about transmitter radios and EMC labs, the plural is antennas.

So, a bug has an antenna or perhaps two antennae.
A test lab has an antenna or perhaps several antennas.
A radio with antennae must have a bug inside it. Perhaps it is in the garden by the flowers?
A bug with antennas… is listening to the radio.
(Thanks for Michael Derby’s contribution.)

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latest KDB publications

arrow 941225 What are the current SAR test procedures for 3G devices?

arrow 285076 What are the equipment authorization requirements for hearing aid compatibility of mobile handsets?

arrow 552295 What are the guidelines for providing a Contention Based Protocol (CBP) operational description, as required by Part 90Z?

arrow 643646 What are the Specific Absorption Rate (SAR) test requirements for occupational push-to-talk (PTT) radios?

arrow 449343 Can a pre-calibrated field methodology be used in conjunction with the procedures described in the TIA-603-C standard to measure the radiated output power and/or the spurious emissions generated by a transmitting device for demonstrating compliance to FCC rules?

arrow 971168 What are the procedures for compliance measurement for the fundamental emission power for licensed wideband (> 1 MHz) digital transmission systems?

arrow 412172 How do you determine ERP and EIRP Values for a RF Transmitting System?

arrow 966099 Can a log average detector be used to make average measurements on intentional radiators?

arrow 714737 What average detector should be used to measure radiated emissions from an unintentional radiator?

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Washington Laboratories espresso engineering rhientech laboratories


Please note that the above represents, in most cases, technical opinions with justification in regulatory agency requirements, however the particulars of the product must be considered. Thus, we welcome a call or email if you have any special needs or questions.

American Certification Body, Inc.
6731 Whittier Avenue, Suite C110
McLean, VA 22101
Office: 703-847-4700