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.
Ask the FCC
KDB: A “How To” Guide
integrator cannot take responsibility for the
Questions about Part 95 72-76 MHz R/C
If our Taiwan labs
(designated by BSMI) is able to do FCC DOC testing,
can our China mainland lab implement FCC DOC testing
but issue report in the name of Taiwan lab?
view the answer...
We have a BT headset
and already applied FCC ID.
Now, the manufacturer wants to sell this BT headset
with a new power charger but the headset is
identical. Shall the client do permissive I or II
FCC Knowledge Data Base (KDB)
Please see attached procedure “Ask
The FCC KDB”
KDB 1: OEM and
An applicant is creating an international 802.11a/b/g DFS-capable
DTS + UNII mini-PCI card. The manufacturer has two questions.
1.) Can the applicant require the OEM integrator to be
responsible for ensuring this device meets the DTS channel 12-13
2.) Can the applicant require the OEM integrator to be
responsible for insuring that, when the module is used in a DFS-required
UNII band, a separate DFS equipment authorization is obtained?
The bottom line is: can the Applicant put the burden of
compliance on the OEM integrator? In both the above instances
drivers are available freely to OEM integrators and can be
easily downloaded into the device.
OEM’s cannot take responsibility for the end-use of a product.
The FCC ID Grantee is not permitted, except in an extremely
limited way, to place burden for compliance on OEM integrator.
I assume that an OEM is other companies that would integrate the
device as a module into a host and your question is can an
applicant apply for a modular grant under multiple rule parts 15
B (15.247) and 15 E (15.407) with the following conditions:
1) The module is capable of
operating world wide- on both US and non US frequencies.
2) The module only has partial capabilities for compliance
with 15 E DFS and TPC requirements.
3) The third party host system (OEM integrator) would need
to provide the missing controls for compliance.
4) The third party would down load US drivers commonly
available on the internet- and the third party would be
responsible for operating only on US frequencies without
For DFS and TPC, the third party
would obtain a new certification. Note: the question “can a
separate DFS equipment authorization be obtained for DFS” is not
relevant to the grant for the module since the OEM would have to
obtain a new authorization. The module, in this case would be an
uncertified sub-assembly and the OEM needs a new certification
for the ensemble (host and sub-assembly).
The answers may be different depending if the device is client
or a master.
A client module (as defined in 15.202 rule part and definitions
for a DFS Client device) may be possible. The device cannot
initiate any non compliant transmissions or 802.11 probes. All
transmissions must be under the control of a certified master.
As a master device a standalone module approval is not possible
since compliance is dependent on the host.
There may be other possibilities as a limited host-specific
module using bios protection and/or as a software defined radio,
with the grantee controlling the software and the security.
However, this grant would be tightly coupled with specific hosts
and the grantee would be responsible and must state how
control of the end product into which the module will be
installed will be maintained, such that full compliance of the
OEM’s end product is always ensured.
However, these conditions are definitely not in line with your
question: “Can the Applicant put the burden of compliance on the
OEM integrator”. The bottom line to your question is NO: the
applicant cannot put the burden of compliance on the OEM
KDB 2: RF
Crystal Change Restrictions
A Part 95 72-76 MHz R/C transmitter contains a single RF channel
module that appears to be user-installable. The label is on the
module and it is unclear if it should apply to the complete
product or just the module.
I seem to recall a prohibition for end-users to change out
crystals in R/C controllers. Does this same prohibition apply to
user-installed RF Modules?
The module contains a single crystal. It does not appear to be
permanently fixed within the device (soldered) and is accessible
when two small screws are removed. Is this permitted?
In general KDB Publication Number 587968 is applicable, but with
allowed provision as follows:
For Part 95 devices, EA Certification is not permitted for
devices that allow an end-user to change plug-in crystals. If
different plug-in crystals are installed only by an OEM, then
approval for multiple crystals and frequencies under one FCC
identifier is permitted, and must include test data for each
configuration. Permissive change to amend other crystals and
frequencies is permitted only if the added frequency(ies) are
within the range of the original grant; a new FCC ID is needed
for crystal frequencies outside the original range. FYI note
also requirements in Part 95.645(b).
Questions and Answers:
DOCs and Permissive Changes
If our Taiwan lab (designated by BSMI) is able to do FCC DOC
testing, can our China mainland lab implement FCC DOC testing
but issue report in the name of Taiwan labs?
Mainland China (PRC)
does not have an MRA with the US. Therefore absolutely NO
mainland China lab can perform testing for DoC to the FCC rules
regardless of who accredits them or what the ownership structure
might be. For example, there are many labs accredited by A2LA
and NVLAP in Mainland China, but NONE of them meet the FCC rules
for a qualified lab needed for DoC testing. So, while BSMI may,
for their regulations and purposes define a Mainland lab as
under control of a Taiwan home office and thus extend the
ability of that Mainland lab to do work for BSMI purposes, the
FCC is not bound by BSMI nor by Taiwan accreditation systems for
dealing with PRC labs. Since the FCC only has an MRA with Taiwan
and not Mainland, only those appropriately-approved Taiwan Labs
(i.e., located physically in Taiwan) are accepted for DoC.
The FCC under Part 2.948(e)
states “(e) The accreditation of a laboratory located outside of
the United States, or its possessions, will be acceptable only
under one of the following conditions: (1) If the accredited
laboratory has been designated by a foreign designating
authority and recognized by the Commission under the terms of a
government-to-government Mutual Recognition
Agreement/Arrangement; or (2) If the laboratory has been
recognized by the Commission as being accredited by an
organization that has entered into an arrangement between
accrediting organizations and the arrangement has been
recognized by the Commission.”
Under 2.948(e)(2) the FCC has not
recognized and does not intend on recognizing any agreement
between accrediting bodies where the accrediting body country
does not have an MRA with the US. So it does not matter if A2LA
or NVLAP as an agreement with other accrediting bodies or not.
The simple fact remains that the FCC has not recognized and will
not recognize any such agreement between accrediting bodies from
non-MRA partners. Consequently any DoC done by such a lab is in
violation of the rules and is not considered properly
authorized. The FCC enforcement bureau is also beginning to
address this issue and will at some time probably make an
example of offenders. This could be in the form of fines, denial
of grantee codes, blocks placed on FRNs etc.
QUESTION: We have a BT headset and
already applied FCC ID. Now, the manufacturer wants to sell this
BT headset with a new power charger but the headset is
identical. Shall the client do permissive I or II change?
transmitter will function when it is charging, you will need to
do a PCII. If the transmit is disabled while charging, a PCI (or
equivalent) will be satisfactory.
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.