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.
FCC freezes certification
on Part 74 devices in the frequency range 698-806 MHz.
From the FCC:
“Effective Wednesday, August 20,
2008, as announced in Notice of Proposed Rulemaking and Order
FCC 08-188 and the associated press release, the FCC imposes a
freeze on granting any equipment authorization requests for low
power auxiliary station devices that would operate in any of the
700 MHz Band frequencies. This freeze applies to Part 74 devices
in the frequency range 698-806 MHz. Applications for these
devices may be filed with the FCC but will not be acted upon
until the conclusion of the proceeding.”
FCC 08-188 may be found online at:
FCC PROPOSES THE PROHIBITION OF LOW POWER AUXILIARY STATIONS IN
THE 700 MHz BAND AFTER THE DIGITAL TELEVISION TRANSITION
Questions and Answers:
Can you apply the FCC and IC modular approval routes to WiMax
products, or must they certified as end products only? And for
the FCC, are there different requirements for the frequency
bands 2.6GHz, 3.5GHz and 5.8GHz.
ANSWER: The specific
frequencies mentioned in the question are in the licensed rule
parts. Licensed Modular Transmitters are not subject to DA001407
commonly known as the FCC Modular Approval Route. However, in
the bands listed, A WiMax can be certified as a modular
transmitter for FCC. If the WiMAx is certified under part 15,
then the modular approval route for unlicensed devices can be
done. For FCC there are specific wordings that apply to the host
device which have to be observed. However for FCC, all WiMax
devices are on the permit but ask list. As to the particular
frequency bands, you have to determine which rule part is
involved and file accordingly. Some bands are in part 27, some
in part 90 and some in part 15. If the device operated in all of
the bands, it would be a composite where each band requires that
appropriate testing and certification process to the particular
rule part would apply.
Industry Canada seems to take a
similar approach as the FCC in that their Modular approval
stated in RSSGEN applies to license exempt devices and not
licensed devices. It is incorrect to use the term “Certified”
for any EU transmitter under the RTTED. An Apparatus, which may
be a modular transmitter, can be CE marked for the EU. Care
should be taken here however so that any and all
Country-specific restrictions are addressed. back to
Does a Part15D DECT phone need to consider SAR?
ANSWER: Part 2.1093
mandates that Unlicensed PCS (DECT phones) SAR testing
regardless of power under 15D. A DECT can operate under part 15
as long as the frequency of operation is correct.
If mobile phone is not sold in the the USA but uses roaming
service in the USA, does it still require FCC certification? If
yes, what is the related rule or requirement?
ANSWER: The short answer
is no - if a phone is purchased overseas and then brought into
USA as "personal property", then there is no requirement for
applying FCC ID. The equipment authorization system only applies
to devices which are distributed or sold in America.
Are there conditions or restrictions under which a WLAN device
with an external antenna connector is certified?
ANSWER: All antenna
connections and highest gain antenna of each type must be tested
with a part 15 transmitter. The only way you can leave the
antenna connection is to disable it some how or show how it
would never be used. If there is any possibility that the
connector could or would be used, then it must be tested.
Testing would necessarily include the expected cable lengh and
highest gain antenna to be used. The external antenna connector
must also follow the requirements for Part 15.203 for antenna(s).
For the EU, How is conformity shown for a device that has
multiple sources for Critical Components? E.g. RF parts such as
the PA have different manufacturers but they use the same
encapsulation? What kind of product change for CE needs to
involve an NB?
ANSWER: There isn’t a rule
or strict requirement on this for Europe as there are no
filings, no regulatory certifications, no permissive change, etc
The manufacturer needs to look at
the changes he has made and make a decision regarding how
confident he is in the continued compliance of the device. If he
has just changed the manufacturer of some small component that
will not affect the performance of the device, then his decision
maybe to do nothing.
However, if the component is
critical, such as a filter or PA part of a radio, then he may
need to get confidence in the device compliance from other
means. If he does not and his product is found to be failing,
then he will be asked to show proof of compliance. At some point
with critical component changes, he has to decide if the device
he is now selling is no longer the device he had tested and
If he performs some measurements
on the device and finds the profile looks similar then he may
decide to keep the results of his investigations on file (in
case someone requests evidence) and continue selling the device.
However, if a critical component has changed and he feels he has
changed the device’s performance thus he no longer has the
confidence to make a decision on compliance, then a safe
recommendation would always be to have some tests performed and
get a new opinion from a Notified Body. The important thing to
remember in any CE Marking of products placed on the EU market
is the decision of compliance is always 100% up to the
manufacturer or his designated agent.” It is also the
responsibility of the manufacturer or his designated agent to
keep such information in the Technical Construction File for
reference when needed.
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.