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.
Labs must follow
accepted test procedures
In the TCBC training recently the FCC
made one thing very clear. They are not happy with the TCBs and
Labs that do not follow accepted test procedures. In an FCC
review of many certification reports, there has been a lack of
detail on the accepted test procedure that were used to claim
Please note that reference to the
rule part IS NOT a test procedure. In order for a TCB to certify
a device the report must clearly and unambiguously state what
test method (test procedure) was used.
All test reports must be adequately
reviewed and the labs need to be required to make clear and
unambiguous reference to proper accepted FCC test procedures. back
FCC Annual Surveillance Report
adopting rules to streamline the Equipment Authorization Process
and establish Telecommunications Bodies (TCBs) to grant
Certification in lieu of the Commission, as adopted on December
17, 1998 (See Report and Order, GEN Docket No. 98-68, FCC No.
98-338 released December 23, 1998), the Commission placed
certain responsibilities on TCBs. The Commission stated, in the
Report and Order that in accordance with ISO/IEC Guide 65, TCBs
were to perform surveillance on products that they had approved.
Currently we have established (see KDB publication 610077) that
a TCB should conduct surveillance of 2% of the total number of
products approved by them for a given year. As we discussed in
the October 2007 TCB Workshop in Maryland, the Commission is
considering raising this percentage of required surveillance
sample testing for calendar year 2008. We will inform you of the
revised requirements for 2008 soon.
In order for the Commission to evaluate the TCB surveillance
program, we ask that TCBs report to the Commission by December
15, 2007, on post grant testing that has been conducted and
surveillance data that they have compiled since the inception of
the TCB program. The report should include the number of
approvals per scope, the number actually audited and the numbers
passing or failing. Also, you should report the same numbers for
surveillance testing of EUTs that had an RF Exposure evaluation
and corresponding surveillance data.
December 18, 2007 the FCC has raised the required audit sample
testing requirements from 2% to 5%. This is an increase of 2.5
times previous requirements. The FCC has also stated that this
increase will affect all TCBs both foreign and domestic. A
clarification of this new requirement will be provided by the
FCC in the next few weeks. back
ACB announces opening of UK Office, Michael Derby to
Head Effort in European Union
ACB is pleased to announce the opening of its first
European Office with the hiring of Michael Derby. The office,
which will serve as the central nexus for servicing the European
Union Market, commenced operation on November 1, 2007. This step
expands ATCB’s coverage for Certification and Wireless
Engineering support to the EU. Adding to offices across the US,
Taiwan, Shenzhen, Shanghai and Beijing, ATCB is prepared to
serve international markets in all time zones.
Michael has direct experience performing radio measurements,
supporting standards activities and managing teams of test
engineers in a laboratory setting. He most recently was manager
of the Radio Performance Group at RFI Global Services in the UK,
managing product approvals for telecommunications clients. His
foundation in EMC, Radio, Microwave and Site Survey work brings
a critical set of tools to ATCB’s clients.
Michael has spent much time developing standards for ETSI (The
European Telecommunications Standards Institute), supporting the
work of the BRAN and TG committees. This direct lab and
standards-basis set of skills will provide invaluable support
for TCB as well as Notified Body work.
Use characters for IC application
Industry Canada has indicated that if
the use of the same character in succession such as
"- - -" or
“XXX” in a model name is not used for the purpose of identifying
multiple models, it would be acceptable to IC. This applies only
to model numbers and not to IC identifiers. back
Permissive Change Policy
The FCC has released the latest
Permissive Change guidance document, the document in PDF form
can be found
here (Permissive Change Guidance).
back to top...
Authorized Individual Policy (Form 731)
The “authorized” individual, when referred to in relation to
both an FCC and TCB Form 731 Application for Equipment
Authorization, is identified as either the applicant / grantee
contact of record in the Grantee Code data base, or the agent
authorized by the applicant / grantee. Only an authorized
individual may “sign” the Form 731, and only an authorized
individual may request confidentiality – i.e. the
confidentiality letter must be signed by an authorized
individual and uploaded into the Cover Letters exhibit folder.
This document can be found in PDF format
back to top...
Questions and Answers:
Our client is designing a WLAN device; can they allow any
channel to be selected by the user? For example, the device has
1-14 Channels available for WLAN operation. During the
installation, the user can choose the region, then the software
selects any channel from 1 to 13. Is this acceptable?
ANSWER: No. This is not acceptable by FCC. For 802.11b/g
WLAN device, FCC only allows channels 1 to 11 to be used.
Usually the applicant will be asked to provide an attestation
letter to state this device can not be selected to operate in
12, 13, and 14 channel by end user.
back to top...
QUESTION: Why doesn’t my wireless
keyboard or mouse need to affix the RF warning statement for
ANSWER: Simply stated, the power is below the threshold.
From the TCB Exclusion List dated July 2002, any device below
the "Low Threshold" [60mW/f(GHz)] is not required to do any SAR
testing. However, it is still necessary to consider co-location
issues if adjacent to another transmitter. And, if you look at
the footnotes in the Exclusion List, devices with an RF Pout
(radiated AND/OR conducted) below 5mW are not at risk of
co-location problems. Therefore low power items such as
Bluetooth do not have to deal with RF Exposure concerns. (The
TCB Exclusion List provides essential information, however, the
FCC's Knowledge Database is considered to be the most up-to-date
information on compliance issues.)
Please note that while a device may have a very low power level
and is categorically excluded, all devices still must abide by
RF exposure and need a RF warning statement. The way these low
power devices deal with this is by being categorically excluded
(categorically excluded does not mean exempt). back to top...
QUESTION: Our system operates at two
different frequencies: 433MHz and 2.4GHz. Can a single FCC ID be
used for the system?
ANSWER: If the two transmitters are assembled together in
the same product, one FCC ID is used for the product.
QUESTION: Could you tell me how to apply
for FCC Part 68 SDOC(Supplier Declaration of Conformity)?
ANSWER: Login in at
http://www.part68.org/ submit your files and remit
appropriate fees. back to
QUESTION: I forgot my FCC FRN password,
how can I find it and how can I update my FRN info?
firstname.lastname@example.org for these questions. You should expect to
get complete instructions on how to reset the password and a
host of other information from this group at FCC. You will need
to prepare a formal letter indicating the new contact person,
address, phone, and email associated with your Grantee Code.
This letter should be on your corporate letterhead. And please
keep the Grantee Code password in a safe place for any future
changes to the Grantee code database, which can be made after
logging into the system.
back to top...
QUESTION: Which FCC standard is
applicable to the RF device operating at 150KHz?
ANSWER: Most RF devices are Certified under 15.209. But
be careful - do not allow any carriers emissions within the
restricted bands of 15.205, and make sure that the spurious
emissions are less than the fundamental. back to top...
QUESTION: We have a mobile phone that
already been certified for FCC ID. Now we are going to change
the software part to add the function of GPRS/EDGE, and all the
other hardware, circuit board, RF will remain the same. If the
software upgraded model can be subject to permissive change and
use the original ID number. Is this subject to PC III?
ANSWER: If you already have a GSM phone but are adding
GPRS functionality with absolutely zero changes in hardware, a
PCII may be appropriate (still must have same output power). But
if they are changing from another modulation format like CDMA to
GSM/GPRS then a new ID is required.
Note that Class III PC is applicable only to 'software defined
radios' and can only be approved by FCC.
back to top...
QUESTION: Are 802.11 b/g devices
harmonized within EU? Or is notification necessary?
ANSWER: France has yet to fully harmonize the band that
is normally used for 802.11 b/g devices.
802.11b/g is acceptable over the full frequency band (2400 MHz
to 2483.5 MHz) and at the full EIRP level (100mW) in all EEA
(European Economic Area) Countries except for France.
In France, the band is only acceptable from 2400 MHz to 2454 MHz
at 100 mW. You can continue to use the devices in France from
2454 MHz to 2483.5 MHz but must drop the EIRP down to 10 mW or
must insist on indoor use only.
Most manufacturers do not want to reduce the output power 10 mW
and don't want to have a separate device just for France, so
most manufacturers make their European model operate from 2400
MHz to 2454 MHz at 100 mW. When testing, most manufacturers test
their USA (FCC) devices using WiFi channels 1 to 13, then test
their European devices using only channels 1 to 11.
Although the device is Class 2 (because the band is not
harmonised), the countries do not require Notification as long
as the rules of use are included in the user manual (must not
use channels 12 and 13 outdoors in France).
The bands used by 802.11a in Europe are now harmonised and
therefore all countries will accept them.
However, they can be a little confusing.
The bands of use are: 5150 MHz to 5350 MHz and 5470 MHz to 5725
A summary of the limitations are:
5150 MHz to 5250 MHz: 200 mW EIRP, indoor use only.
5250 MHz to 5350 MHz: 200 mW EIRP, indoor use only, DFS test
5470 MHz to 5725 MHz: 1 W EIRP, DFS test required.
The bands are harmonized and therefore Country Notifications are
not required; the device is still considered a Class 2, because
the indoor use requirement means it can't be used "anywhere".
The EU may be rewriting the DFS section of the standard to deal
with weather radar in the 5600-5650MHz range. The existing DFS
test requirements do not adequately test DFS for this type radar
and the EU is finding some cases of interference. This would be
a case where, while there is a harmonized standard, that
harmonized standard is not adequate enough to give a presumption
back to top...
QUESTION: What is 802.11n? If countries
in EU accept 802.11 b/g, do they accept 802.11n?
ANSWER: The suffix "n" after the 802.11 name means that
it allows a multiple input/multiple output antenna system to be
used. This is often known as “MIMO”.
MIMO operation is allowed for both 802.11b/g and 802.11a). These
standards, including the MIMO tests, are harmonised (accepted).
Therefore, the addition of "n" should not change anything with
regard to acceptance in Europe. If a country accepted 802.11b/g
and 802.11a, then there would be no problem with adding 802.11n.
back to top...
QUESTION: If a device incorporates a
transmitter with full module approval, does the host device
require a PCII change or just affix “Contains FCC ID:XXXXXXX”?
ANSWER: Please See FCC rule 15.212 and attached FCC
modular approval document. Neither DA001407 nor 15.212 say or
even suggest that a PC is needed if a full modular (single
modular) approval is done. You do not have to do a PC for a full
modular approval if you follow the grant notes. You only need do
a PC when a LIMITED Modular Approval is involved or when you are
not following the full modular approval grant notes or when
collocation is involved. Again full modular approvals do not
require a PC simply to put it in a host.
back to top...
QUESTION: If a lab is approved and
certified as an ANTENNA and SAR probe calibration body, can they
calibrate their own SAR probe? Or msut labs return equipment
back to the original factory for the SAR probe and dipole
ANSWER: There is nothing that prevents a capable lab from
calibrating their own probes and dipoles as long as they come
within the allowed tolerance in the standard. Of course the
calibration would have to meet the US requirement (not EU
requirements for US use, i.e.). They would still have to provide
the actual calibration data and certificate and justify the
calibration as being traceable to the acceptable standards
organization. back to
While there may be no requirement from the FCC on who calibrates
SAR probes, there will be requirements from the labs accreditor
to use an accredited calibration source for their equipment or
to have an acceptable calibration method included in their QA
system. If the lab is not accredited then the TCB must be
confident in the source of equipment calibration as well as the
testing capabilities of the lab doing the SAR. back to top...
QUESTION: If our lab has some test
facilities but does not have FCC 2.948 test site, which test
parameters have to be tested in the listed site and which test
parameters can be tested it in a non-listed site with our
facilities? Or must every test parameter be completed in listed
ANSWER: As long as the 15.209/15.207 testing requirements
are met at a listed site, it is does not matter where the "bench
tests" or RF conducted tests are performed. So the Part 15 AC
conducted test and Part 15 radiated test must be performed on a
listed site. But bench tests on the RF conducted parameters can
be done anywhere. back to
QUESTION: Regarding an analog fixed
telephone subjected to FCC Part 68. What is required?
ANSWER: While 15B for computers and computer peripheral
devices are DoC or Certifications, most digital devices are is
still required to meet the FCC rules. Digital devices under part
15 are Class A and Class B. Consequently, any digital device
must comply with the rules but digital devices used as computers
or computer peripheral devices require either DoC or
certification. A loop start analog POTS phone without any AC
power required and NO digital circuitry would require Part 68
only. If the phone device is a computer peripheral, it will
require both Part 68 and Part 15B.
back to top...
QUESTION: Some Power Amplifier (PA)
transistors are being changed in our transmitter device; the
power output and frequency are still the same as before.
Meanwhile several resistances, inductances and capacitances in
the PA circuit are also changed accordingly. Except for the
above change, no other change happened. What we should do
accordingly for the IC certificate?
ANSWER: One must be very careful about changes in the PA
circuitry in a device. The new component must be verified that
it is electrically identical and a pin-for-pin replacement. A
new ID is usually required if new RF amplifier or frequency
determining components are changed.
back to top...
QUESTION: Can your provide some
information about the FCC, IC certification for TD-SCDMA base
station operating in the frequency range of 2010-2025MHz?
ANSWER: In North America, 2010-2025MHz band is not
allowed. The closest frequencies are the Part 24 bands of
1850-1910MHz (subscriber) and 1930-1990MHz (base) or Part 27
(2100MHz and above). For Part 27 you may be at a disadvantage
because of advances in WiMax-related technologies which will
allow very high data transmission rates, more than TS-SCDMA may
allow. Currently, 2000-2020MHz is a Part 25 (satellite services)
frequency band; under this allocation, both ATC (Ancillary
Terrestrial Components) mobile devices and base stations can
operate in this band. back
QUESTION: If a product is tested for
SAR and is issued under an FCC report, could the SAR report be
used for IC certification?
ANSWER: While IC does not require a SAR report to be
uploaded to their site, they do require annexes A and B of
RSS102 to be uploaded. These annexes are the attestation to SAR
compliance and the highest SAR data from the SAR report. IC and
FCC SAR requirements are very similar so you can use your
FCC-SAR test data to fill out the RSS102 annexes and provide
this with the IC application.
back to top...
QUESTION: What are the FCC/CE
requirements for the test reports of MIMO and DFS test cases?
ANSWER: MIMO testing is straightforward. The only real
differences have to do with how Pout is tested because, in
essence, you have two transmitters working in parallel with a
lot of signal processing. TCBs can handle all MIMO
certifications for the 2.4GHz band with no problem.
DFS is trickier. In general "full" DFS approval for a "master"
station must be performed by FCC and a sample submitted directly
to them. However, if you have a "client-only" DFS project with
no "ad-hoc" capabilities (such as for notebook PC) then the TCB
route is available to you.
Also, be mindful of RF Exposure requirements. For 2.4GHz work
SAR testing may be required for all RF category "portable"
equipment if the power is above 60mW/f(GHz) if the user can
contact the antenna or 120mW/f(GHz) if the antenna is 2.5cm away
from the user. But according to our radio law, all 5GHz 802.11a
"portable" devices under 15.407 must have SAR testing regardless
There is nothing new for the process within Europe; the same
standards and processes for applying the CE Mark for MIMO
devices. For testing procedures, MIMO (“smart antenna”) issues
are addressed in the latest versions of both the standards, EN
300 328 (for 2.4 GHz) and EN 301 893 (for 5 GHz) devices.
Both standards explain how the antenna ports should be
configured for the power and emissions measurements. EN 301 893
explains how the receiver antenna paths should be configured for
DFS. Basically, there are just one or two extra lines of text in
the standards, to address the MIMO and 802.11n issues. back to
QUESTION: For a Wi-Fi access point:
1) Should the application be sent to FCC directly for DFS test
and approval, or can 2.948 listed site perform DFS test for it
and go TCB route?
2) Does 802.11a/802.11n laptop or Wi-Fi card need to do SAR
3) Do 802.11a/802.11n AP need SAR testing?
1) An 802.11a/g access point with DFS detection capabilities
will need to be tested at a Part 15 listed laboratory which has
DFS testing capabilities. Please review FCC Rule 15.407 for
complete details of the requirements and bands and their limits
for DFS test. The FCC will do testing only after they receive
the application and complete all appropriate reviews. DFS
capable devices have a 100% pre-Grant sample test program.
2) If your 802.11n WiFi card has DFS detection capabilities,
then it will need to be handled just like an access point. But
if it has no DFS detection and no ad-hoc mode it can be approved
as a "client only" device with just a minimal amount of extra
DFS testing , TCBs can do these approvals. But Generally by
almost by definition an Access Point would be a master device.
3) SAR testing is a separate subject. If the antennas of the
device are within 20cm of a user, it is classified by law as an
RF category "Portable" device and SAR testing would be a
requirement for 5GHz 802.11a. If 2.4GHz only, it will be subject
to either 60mW/f(GHz) or 120mW/f(GHz) to determine if SAR
testing is needed. back to
QUESTION: We have a LED lighting with
external AC/DC switching mode power adapter and would like to
know whether this product should be tested as RF lighting
according to FCC Part 18 or Digital device according to FCC Part
15B? Is it subject to DoC or certification?
ANSWER: Over the years many of these types of devices ask
the FCC and many times the FCC has a reason beyond the scope of
the rules which it should be under. However, the FCC has seen
beyond this in several cases and asks for something more or
different. For instance in some cases they have said the device
is more like a power supply under 15. While other times they
have said that even though it is more like a power supply,
because it drives a light it should be under 18.
Generally based on experience is that this should be 15, since
the output is DC and NOT an AC RF waveform. However given the
number of times I have seen them answer from the FCC be the
opposite of expected (relative to RF lighting question) - the
safest route would be to do a KDB on this.
Note that even Part 18 has a DoC - but labeling and other issues
Section 18.203(a) basically means all Consumer based (home use)
equipment approved under Part 18 must be approved by either a
DoC or Certification authorization. If the lighting device is
strictly intended for industrial (non-consumer) use, it may be
subject to Verification.
Note that manufacturer and/or lab may choose which to use (DoC
or Certification) for consumer RF lighting devices. Each route
will required different labeling, but the route to compliance
may be decided by the manufacturer. Note if the device only
requires Verification, then particular labeling requirements for
this must be followed and not the DoC or Certification
Radiated tests may be omitted when the operational frequencies
of the RF lighting device are less than 1.705 MHz, based on
table 18.309. This is due to the fact that RF lighting devices
only require radiated measurements > 30 MHz, and the table
18.309 does not require measurements of Radiated if the
frequencies are < 1.705 MHz.
Note that a DoC means a lab that is allowed to do DoC's under
Part 2 of the FCC rules (meeting both accreditation and MRA for
foreign labs). back to
QUESTION: We have a Walkie-Talkie
held-to-face device operating in 450MHz frequency band and want
to know which EN rule part can be used to judge if this device
requires doing SAR test.
ANSWER: The RF exposure for devices not covered by a
specific RF exposure standard are not exempt from showing RF
exposure compliance. For example, low power devices have a
standard that mentions a 20 mw power level at which to begin
considering RF exposure. RF exposure for these devices could
possibly be made without the involvement of a notified body.
Some types of devices, such as Cell phones etc, also have
specific RF safety standards to refer to and the involvement of
a notified body is not needed. Some device such as the 450MHz
PMR/PAMR device in this question do not have appropriate
harmonized standards for RF exposure and consequently Annex II
or III may not be appropriate as assumption of conformity to
harmonized standards is not possible. In the case where there
are no Harmonized Standards, a notified body under annex IV of
the RTTED would be a method to determine compliance to the
essential requirements of the RTTED. The lab and/or manufacturer
would need to provide evidence that RF exposure has been
addressed for these devices and that the appropriate levels were
met. RF exposure concerns and selection of an appropriate RF
safety standard to use should be done in consult with the
notified body prior to testing. If no such evidence is provided,
the NB would probably give a negative opinion as the RF safety
requirements would not be met in relation to article 3 of the
RTTED. back to top...
Please note that the
above represents, in most cases, technical opinions with justification
in regulatory agency requirements, the particulars of the product must be considered.
Thus, we welcome a call or
email if you have any special needs or questions.