"Packets" - Regulatory Updates for the
WIRELESS INDUSTRY UPDATES:
is now ACB
We have a new name! - AmericanTCB, a
leader in Telecommunication Certifications is now American
Certification Body, Inc. (ACB). ACB is expanding to serve
the widening needs of our clients in North America, Asia and
Europe. We have changed our name but haven't changed our
focus on providing the finest and most comprehensive
Industry Canada (IC) now requires company number for applicant, manufacturer,
agent and Canadian representative. New Company Numbers
and/or changes to existing company information will now be
electronically processed through the use of the following
1) Log in with your user name and password (If you do not
have one you will need to create one)
2) Select "Manage Company Information"
3) Choose either from (Obtain new company number or Edit
At this point, you would continue by following the step
by step instructions. Once IC has approved the request, you
will receive an email notifying you that your request has
been successfully completed.
In this issue...
The coming EN 60950-1: 2006 +
routers and access points
IC SAR Testing Requirements to Bystanders
for Laptop Type Computers
Q1. What is the correct distance attenuation
factor which should be applied to a low frequency Part 18
Q2. What extrapolation factor is acceptable
for a Part 18 device for radiated emissions below 30 MHz
when it is not tested at the limit distance? more
Q3. We manufacture a small (10cmx6cmx2.5cm)
Hotspot CDMA 2000 at 800/1900MHz and WCDMA 3GPP and HSUPA at
850/900/1900MHz Wireless Wide-Area-Network (WWAN) device.
According to IEEE 1528, OET Bulletin 65 C, specification and
the FCC’s Knowledge Database, it does not appear that there
is a specified standard or procedure to determine SAR
spacing requirement for our product. Hence, we are going to
do SAR (Specific Absorption Rate) measurements, as a mobile
device, is this correct? more
Q4. Referring to the published DTS and FHSS
procedures, when making average measurements with a 10 Hz
video bandwidth for spurious radiated measurements above 1
GHz for digital modulated and frequency hopping devices in
15.247, what is meant by continuous operation? more
Q5. What are the validation requirements for a radiated
emission test site above 1 GHz? Can a test site that
uses Radio Frequency (RF) absorbers on top of the ground
plane be used to make radiated emission measurements above 1
Q6. Do Tri-band and Single-band cell and PCS phones need
separate FCC Identifiers (FCC ID)? more
Q7. May I ask the process (Verification or Certification)
for the BPL products? Please advise if the regulation of
ICES-006 is appropriate. more
Q8. If a module has complied with R&TTE requirement,
when it is built into another host (ex. TV) how do you think
if it is necessary to re-test in system? My question is
based on the request for opinion letter. If I don’t request
for opinion letter, I think re-test or not is determined by
manufactory as CE is voluntary. Is my thought correct?
Q9. Is it a MUST that CE DoC has to be printed out and put
into the package of the product? Is it a requirement of a
few EU countries or all the EU countries? more
The coming EN 60950-1: 2006 + A11: 2009:
Regarding electrical safety of information technology equipment to
the R&TTE Directive and Safety Directive...
For R&TTE and other electronic equipment, the information
technology equipment safety standard EN 60950-1: 2001 will expire as
a harmonised standard on 1 December 2010.
EN 60950-1: 2006 is presently a harmonised standard and has been
an option for some time. However, from 1 December 2010
it will be the only harmonised safety standard for information
In August 2010, a new Official Journal was released for the R&TTE
Directive which lists an amendment to EN 60950-1: 2006.
The amendment is A11: 2009. (This amendment has been on
the Safety Directive Official Journal since March 2010).
Therefore, from 1 December 2010, the harmonised standard for
electrical safety requirements of information technology equipment
will be: EN 60950-1: 2006 + A11: 2009.
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Battery powered routers and access points
Please note that as of June this year, any battery powered access
point, router or hub under 802.11, unless it can be proven to be a
mobile device, must have the appropriate PORTABLE RF exposure
Regardless of when the device was submitted, no grant can be issued
on these devices without PORTABLE RF exposure being done. The
exception would only be for those devices than can prove they are
only capable of mobile installation configurations.
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IC SAR Testing Requirements to Bystanders for Laptop Type Computers
Unless the side(s)/edge(s) of the laptop type computer (laptop
mode/tablet mode) containing built-in antenna(s) was already tested
against the flat phantom to account for the user requirements (e.g.
antenna in the laptop base), Industry Canada requires SAR
measurements to be performed with the side(s)/edge(s) of the display
screen containing the built-in antenna(s) pointing towards the flat
phantom. The separation distance shall not exceed 25 mm between the
device and the flat phantom to show compliance for bystanders.
Additional configurations regarding SAR testing for laptop type
computer (laptop mode/tablet mode) are not required if the
separation distance of 25 mm for bystanders represents the
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What is the correct distance attenuation factor which should be
applied to a low frequency Part 18 measurement?
Section 18.305(note 2) states that if a sufficient number of
measurements are made at varying distances from the Equipment Under
Test (EUT), so that the actual distance attenuation may be
calculated, then that calculated factor may be applied to the level
of the emission measured at a distance closer, than the specified
for the limit.
Multiple measurements have the advantage of using a factor which
could be 50 and 60 dB per decade (at 23 kHz) rather than 20 db per
decade for a single measurement. Obviously, if the emission is
compliant, assuming 20 dB per decade, then only the single 10 m
measurement needs to be made, and the results extrapolated to the
Note: Measurements at these low frequencies do not require an
approved site to be used. You may make measurements at distances
greater than 10 m even if: (1) there is no ground screen, (2) site
attenuation is not measured at these greater distances and (3) the
area is clear of obstructions.
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What extrapolation factor is acceptable for a Part 18 device for
radiated emissions below 30 MHz when it is not tested at the limit
The rules and test procedures are unambiguous:
For part 15 devices:
15.31 (f) (2) for frequencies below 30 MHz for measurements close
than the specified distance the extrapolation factor can be (1)
determined or (2) use 40dB / decade.
For part 18 - 18.305 Note (2) requires an adjusted attenuation
factor of 1/d, or you can determine the actual factor as discussed
in publication 62960.
The extrapolation factor 1/d for a Part 18 device for radiated
emissions below (and above) 30 MHz when it is only measured at a
fixed limit distance is 20 dB / decade.
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We manufacture a small (10cmx6cmx2.5cm) Hotspot CDMA 2000 at
800/1900MHz and WCDMA 3GPP and HSUPA at 850/900/1900MHz Wireless
Wide-Area-Network (WWAN) device. According to IEEE 1528, OET
Bulletin 65 specification and the FCC’s Knowledge Database, it does
not appear that there is a specified standard or procedure to
determine SAR spacing requirement for our product. Hence, we
are going to do SAR (Specific Absorption Rate) measurements, as a
mobile device, is this correct?
Body-worn accessory SAR test information contained in IEEE
Standard 1528-2003, OET Bulletin 65 Supplement C-0101 is based on
products like cell phones. Cell phones have evolved
substantially in form, factor, and capabilities over the last few
years and industry practices for providing accessories have changed.
As a result the FCC no longer considers devices such as Wireless
Wide-Area-Network Hotspots as mobile devices for SAR measurements.
In general, SAR compliance should be tested using a conservative
separation distance representative of the way end users will use the
device. The device you described is very small, and as such, the
tendency for some end users to put it inside their shirt pocket or
very close to their bodies is real.
A test distance of 1.0 cm has generally been applied for these
types of devices; however, it is the manufacturer's responsibility
to determine the appropriate body-worn test separation distance to
ensure SAR compliance for its products. If testing is done at
a separation distance greater than 1.0cm, there has to be a
reasonable justification to support this claim, including a
demonstration of how the distance will be maintained under normal
use. It should be noted that the FCC does not accept a simple
caution statement as proper justification for greater than 1cm
separation distance. The separation must be controlled by the
grantee and supported by device characteristics and use.
Please note the recent FCC’s guidance procedure to be used to
address SAR compliance for battery-operated Hotspot/router devices
in portable exposure conditions states the following below:
1. A test separation equal to 1.0 cm may be used to test for SAR
2. SAR should be tested for the highest output power channel, for each
surface and edge closest to the antenna(s) for each operating mode
and band. For example, if a WWAN antenna is near the top
surface and on the right side of the device, SAR should be tested
with the required separation distance from the top surface and then
the right edge of the device. Similar procedures should be applied
with respect to the WLAN antenna location(s).
3. Simultaneous transmission SAR requirements should be determined
according to the handset SAR procedures in KDB 648474 for test
exclusion with respect to the sum of 1-g SAR or SAR-to-peak location
ratio. When simultaneous transmission SAR evaluation is
required, a volume-scan is required.
4. User instructions and if necessary, any labeling requirements, and
grant conditions will be determined according to the measurement
Regardles of the answer given above, it is important to send an
inquiry to the FCC about the required test configurations and
procedures for your device. The size of your device, technology, and
operating frequency bands will determine the FCC’s response.
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Referring to the published DTS and FHSS procedures, when making
average measurements with a 10 Hz video bandwidth for spurious
radiated measurements above 1 GHz for digital modulated and
frequency hopping devices in 15.247, what is meant by continuous
When making average measurements with a 10Hz video bandwidth, the
carrier must be continuous? i.e., the signal must have 100% duty
factor. The signal should include modulation (e.g., FM, BPSK, QPSK,
QAM) except for modulation methods that turn the carrier on and off.
In addition, frequency hopping must be disabled.
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What are the validation requirements for a radiated emission test
site above 1 GHz? Can a test site that uses Radio Frequency
(RF) absorbers on top of the ground plane be used to make radiated
emission measurements above 1 GHz?
The measurement procedures and site validation requirements for
compliance testing of unlicensed unintentional and intentional
radiators have been updated and published as C63.4-2009 .
Pending future rulemaking, the procedures in either C63.4-2003 or
C63.4-2009 may be used to demonstrate compliance with the site
validation requirements for radiated emission measurements .
Validation of the acceptability criterion shall be confirmed no
less than once every three years.
C63.4-2009 provides two options for test facilities used to make
radiated emission measurements above 1 GHz, and clarifies that the
use of RF absorbers on the top of the ground plane is permitted .
Facilities suitable for measurements in the frequency range 30 MHz
to 1000 MHz are considered suitable for the frequency range 1 GHz to
40 GHz with RF absorbing material covering the ground plane such
a) the site validation criterion
called out in CISPR 16-1-4:2007 is met;
b) or a minimum area of the ground plane is covered,
i.e., 2.4 m by 2.4 m (for a 3 m test distance), between the antenna
and the Equipment Under Test (EUT) using RF absorbing material with
a minimum-rated attenuation of 20 dB (for normal incidence) up to 18
C63.4-2003 does not have site validation requirements for test
facilities used to make radiated emissions above 1 GHz. However, it
does state that facilities that are suitable for measurements in the
frequency range 30 MHz to 1000 MHz are considered suitable for the
frequency range 1 GHz to 40 GHz, including the presence of the
reference ground plane .
 See Public Notice DA 09-2478. The Commission indicated
therein that pending a future rulemaking to update the rules, it
will accept test data for radiated emissions and normalized site
attenuation (NSA) performed using the procedures in ANSI C63.4-2009.
 See 47 C.F.R. Section 2.948(b)(8) regarding the site
attenuation validation requirements. The FCC rules were updated to
reference C63.4-2003 under ET Docket No. 03-201 (FCC 04-165). The
continued reference to ANSI C63.4-2001 in Section 2.948(b)(8) was an
oversight when the rules were updated and the correct reference is
 See ANSI C63.4-2009, clause 5.5 for the specific requirements
for test facilities used to perform radiated emission measurements
above 1 GHz.
 See ANSI C63.4-2003, clause 5.5.
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Do Tri-band and Single-band cell and PCS phones need separate FCC
Identifiers (FCC ID)?
Cell phones and PCS telephones are certified under Parts 22 and
24 of the FCC Rules. The procedures for filing an application for
Certification are contained in Section 2.1033-2.1057. If tri-band
and single band handsets have the identical electrical components
for tri-band operation but single band operation is accomplished by
software, both handsets can have the same FCC ID. However, if the
single band version of the handset is accomplished by leaving off
components from the tri-band device, a different single-band
(depopulated) version of the original tri-band cell/PCS phone
exists. Section 2.907 (b) of the FCC Rules states that Certification
applies to all devices that are identical. As defined in Section
2.908 of the Rules, identical means within the variation that can be
expected to arise as a result of quantity production techniques.
Leaving components off a device to limit its capabilities does not
meet this definition. These devices have different capabilities, are
considered different products, and must be approved under separate
Each version must therefore, have its own application and test
report, though for most of the single band tests, the tri-band data
that applies to the single band version may be submitted. However,
spurious radiated emission tests and SAR tests must be conducted for
each version of a handset. There may be instances where the removal
of components affect spurious radiated emissions. For SAR, such
changes have a definite, unpredictable impact on near-field
radiation, which is the cause of RF radiation exposure.
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May I ask the process (Verification or Certification) for the BPL
products in Canada? Please advise if the regulation of ICES-006 is
For Industry Canada, BPL equipment needs to comply with ICES-006.
No certification is required, testing must be done on the device and
test results must be kept for at least 5 years.
Care should be taken however when speaking of BPL in relation to
the FCC. For example, Access BPL are certified while carrier current
systems under 15.113 are verified.
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If a module has complied with R&TTE requirement, when it is built
into another host (ex. TV) how do you think if it is necessary to
re-test in system? My question is based on the request for opinion
letter. If I don’t request for opinion letter, I think re-test or
not is determined by manufactory as CE is voluntary. Is this
It’s a tricky question; hopefully I can make it clear.
Be careful when you say “CE is voluntary”. Basically, putting the
CE Mark on and complying with all the requirements is not voluntary,
that is mandatory. So, if you fully test the end product to
harmonised standards, then the use of a Notified Body is not
mandatory. You could say that using a Notified Body is voluntary, if
you tested the device to harmonised standards. However, if you do
not fully test the device to harmonised standards, then you must use
a Notified Body and get their ‘Opinion’.
From your question...
If they fully test the TV to the requirements of the R&TTE
Directive, using all harmonised standards, then they can put their
own CE Mark on. If they want to do some partial re-testing (and
trust some original results from the module), then they should
create a Technical Construction File (TCF) to show how the end
product (TV set) will comply with the Directives.
As regards to what testing must be done... that must be decided
on a case-by-case basis, depending on the module and host.
Of course, in the example you have given (of a television set),
the television itself may be a broadcast receiver and therefore
exempt from the R&TTE Directive. However, this answer relates to the
question of a device which hosts a radio module.
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Is it a MUST that CE DoC has to be printed out and put into the
package of the product? It is a requirement of a few EU countries or
all the EU countries?
The requirement is that each device must be provided with the CE
DoC, or a statement that the device complies with the Directive and
some access to the DoC. So, some manufacturers do
provide the full DoC document with every device.
Alternatively, each device could have a statement which says:
“This device complies with the essential requirements of the R&TTE
Directive 1999/5/EC”, for example. If you provide this
statement, you should provide it in every language.
If you just provide the statement (not the full DoC), then you
should make the full DoC available to anyone. For
example, some people provide the statement of compliance and then a
web-link to the full DoC document.
The full DoC document must be available in any European language.
Most people provide an English version and then make sure that they
are able to obtain one in any language, if they are asked.
For example, you have been asked to provide one in Polish, so you
will need to provide one.
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Don’t know how to start with the FCC application?
The below link may help you.
Be sure to use the newest version of any app
KDB996369 D01 Module Equipment Authorization Guide v01
-- Transmitter Module Equipment Authorization
178919 D01 Permissive Change Policy v04r04 (8/6/2009)
-- Permissive Change Policies
Where to find KDBs?
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