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Issue 21

January 2014

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

Required Documents for Integrated Modular Device in Final Product
MIC Radio Certification Quality System
MIC Bandwidth Measurement
MIC Body SAR Update
CAB Responsibility in Determining Acceptable SAR Test Methods
Body SAR Requirements for Modules

questions and answers

Required Documents for Integrated Modular Device in Final Product
Question 1:
We recently received a modular approval for Japan. What kind of testing and documentation do we need when the module is integrated into a final product?
Answer 1:
Currently, manufacturers do not have to take any additional actions when certified radio modules are integrated into host equipment for Japanese certification. The Japanese Radio Law does not address the concept of modular approvals. The Ministry of Internal Affairs and Communications (MIC) defines radio modules as simply being “self-contained” individual transmitters/transceivers. As a result, in contrast to the FCC or IC, Japan certificates for radio modules do not contain any reference to a modular approval.
During the February 2013 MRA workshop in Tokyo draft Guidelines of ICCJ (Information & communication Certification Conference Japan) were presented. These draft Guidelines stated that it is recommended to place the following statement on the label of devices that contain certified radio modules:
“This equipment contains specified radio equipment that has been certified to the Technical Regulation Conformity Certification under the Radio Law.”
Most importantly, radio modules must be labeled with the certification number for Japan and the Japanese approval mark (GITEKI mark); see the labeling instructions below for more information.

Table 4 Table 4

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MIC Radio Certification Quality System
Question 2:
We would like to apply for Japanese product certification. It appears that the quality system confirmation document requires that the manufacturing facility that assembles our final product, and we the applicant, must have ISO 9000 certifications.  However, only the manufacturer of the Bluetooth module that we integrated into our final product is ISO 9000 certified. Is there a way to proceed with certification, or do all parties need to be ISO 9000 certified?
Answer 2:
There is no requirement that parties involved in the manufacturing of the product and/or the applicant must have an ISO 9000/9001 certified quality system. However, there is a requirement that a quality system must be in place.
In cases where there is no ISO certified quality system in place, applications must contain a quantitative amount of detail about the quality system of the manufacturer (and any party involved in the manufacturing of the product) and the applicant.
Please review the table below from the Japanese “Ordinance concerning Technical Regulations Conformity Certification etc. of Specified Radio Equipment”.
The table contains the requirements for documents, descriptions, and explanations that must be submitted in the event that the manufacturer and/or the applicant do not have an ISO certified quality system in place.

Table 4

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MIC Bandwidth Measurement
Question 3:
We are measuring the occupied bandwidth of the carrier of a wireless device whose date rate is 64 kbps and uses binary frequency shift keying (FSK) modulation with a 32 kHz frequency deviation, for Japanese certification in accordance with the Rules for Regulating Radio Equipment (Radio Regulatory Commission Rules No. 18 of 1950.

The test method, as published by MIC, states that the resolution bandwidth (RBW) of the spectrum analyzer must be set to “3% or less of allowable value” (tentative translation of the original Japanese text). What does “3% or less of allowable value” actually mean?
Answer 3:
Since the recommended test method for measuring the occupied bandwidth is only published in the Japanese language we understand why the English translated version may lead to different interpretations or confusion. The correct interpretation is “3% of the maximum allowable occupied bandwidth value (300 kHz in this case), or 3% of the necessary bandwidth, whichever is smaller”, as opposed to “3% or less of allowable value”.
In this case the maximum allowable occupied bandwidth is 300 kHz, and a 3% setting of the allowable occupied bandwidth equates to a 9 kHz RBW value. However, this may not be the optimum setting for the carrier in question.
To determine the optimum RBW setting, you must first determine the expected occupied bandwidth by calculating the necessary bandwidth. To do so, apply the necessary bandwidth formula (Bn) found in Industry Canada (IC) TRC-43 standard and the technical characteristics of the carrier.
The necessary bandwidth formula (Bn) = (2.4 * D) + (1.0 * R), where
         R= Data rate = 64 kbps = 64000 bps
         D = Frequency deviation = 32 kHz = 32000 Hz
         FSK = Modulation type
Applying the necessary bandwidth formula yields Bn = 140.8 kHz. If the technical characteristic parameters of the carrier are properly set, the expected occupied bandwidth value should be less than or equal to 140.8 kHz. If the expected occupied bandwidth is larger than the necessary bandwidth, then one of the carrier’s technical characteristic parameters may have been improperly set (e.g. the frequency deviation).
A RBW set to 3% of the necessary bandwidth equals 4.22 kHz. If you set the RBW to 4 kHz, your measured occupied bandwidth value would yield the best results and should be close to the value of the calculated necessary bandwidth.
Your equipment may not support a 4 kHz RBW setting; if that is the case use a 3 kHz RBW instead (or choose the closest value to 4 kHz), with a peak detector.
You must state in the test report that you calculated the necessary bandwidth in accordance with IC TRC-43 and that the RBW was set to 3% of the calculated necessary bandwidth as a justification of how the RBW setting was determined.

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MIC Body SAR Update
Question 4:
What are the latest Japanese SAR requirements?
Answer 4:
Japan has had head SAR requirements since 2002. Effective April 1, 2014, a body SAR limit at 2 W/Kg or 4 W/Kg for limbs will become a requirement. The increased use of smart phones and tablets operating with multiple simultaneously transmitting transmitters necessitates this requirement. The test standard for any transmitters operating within 20 cm of the human body is IEC 62209-2.
Devices that may require body SAR testing and which have been certified before April 1, 2014 are exempted from body SAR testing - that is, they do not need to be re-tested for body SAR. However, if changes are made to the device or the device certification is modified after April 1, 2014, a body SAR test report must be provided for certification.
Any applicable devices submitted for certification after April 1, 2014 must be tested for body SAR (even if device testing and the application for certification preparation started before April 1, 2014).

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CAB Responsibility in Determining Acceptable SAR Test Methods
Question 5:
What is the CAB’s responsibility for determining acceptable SAR test methods for MIC certification?
Answer 5:
With respect to CAB SAR review, it is the responsibility of the CAB to decide if the SAR test methods used to test a particular device for which certification is sought are acceptable. The ICCJ intends to discuss and issue guidance to the CABs in the coming months in order to best ensure consistent review and approval of acceptable SAR standards across the CABs.

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Body SAR Requirements for Modules
Question 6:
Considering the new MIC body SAR requirements, is it possible to get certification for a module when the module is installed in another device?
Answer 6:
It is already possible to get a module certification when the module is installed in another device. Body SAR testing is not required when modules are used greater than 20 cm from the human body.
Based on the host type of the installed module, SAR testing may be needed. For example, if the module’s host type is known, e.g., a laptop computer, then SAR testing can be performed on the host (the laptop computer).
If the module’s intended host type is not known then, SAR testing cannot be performed on the module. As such, the module cannot be certified to include body SAR, which prohibits the module from being used within 20 cm of the human body. If the module is installed in a host to be used within 20 cm of the human body, the host must be tested for body SAR and certified.
Originally certified modules hosted by tablets/laptop computers with less than 20 cm distance from the body must be certified by the host/tablet manufacturers. The certification number/mark must then be placed on the host, and the module also remains certified and valid.

MIC will issue guidance before April 2014, to advise on the scope of the requirements, its application with regard to modules, possible test reductions, and the possible use of fast SAR test equipment, etc.

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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. contact us

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