This newsletter provides key updates on regulatory and certification developments from the FCC, TCB Council, and ISED. It includes details on the TCB Council’s Best Practices Guidance for Covered List compliance, recent FCC regulatory changes and investigations, updates on spectrum usage rules, and new ISED guidelines for RSS-248 module certification. Additionally, it highlights recent FCC Knowledge Database (KDB) updates regarding compliance testing and equipment authorization.
Newsletter Topics Below:
TCB Council Releases Best Practices for Covered List Compliance
The TCB Council has published a Covered List Best Practices Guidance Document to assist manufacturers, labs, and TCBs in meeting compliance standards. This document is now available on the TCB Council website.
TCB委员会创建了一份最佳的Covered list实践文件，以指导制造商、实验室和TCB在确
定符合这些要求方面的合理尽职调查。
Federal Register Announcements
The following items of interest have been published in the Federal Register:
- FCC Chairman Carr Launches Massive Deregulation Initiative: FCC Chairman Brendan Carr announced a new, large-scale deregulatory initiative aimed at reducing regulatory burdens. Document: OMR. DOC-410147A1.pdf
- Carr Announces Sweeping New Investigation into CCP-Aligned Entities: The FCC is launching an investigation into Covered List entities posing security risks in U.S. operations. Document: OMR OCHBC. DOC-410318A1.pdf
- Order Granting Extension of Time: The Public Safety and Homeland Security Bureau has granted an extension of time for the U.S. Cyber Trust Mark Lead Administrator. (Dkt No. 23-239 | DA No. 25-190 | Document: PSHSB. DA-25-190A1.pdf
- Spectrum and Band Usage Updates:
- Unlicensed Use of the 6 GHz Band – Expanding mid-band spectrum usage (3.7–24 GHz). [11373–11388 | 2025–02962 | PDF]
- Advanced Air Mobility Regulations – Supporting new air mobility technologies. [12243–12272 | 2025–03602 | PDF]
- 896–901/935–940 MHz Band Rule Review – Revising rules for spectrum use in these bands. [12272–12286 | 2025–04008 | PDF]
- 5.850–5.925 GHz Band Corrections – Updates and corrections for spectrum use. [13293 | 2025–04132 | PDF]
以下项目已经公布在Federal Register
FCC Seeks Input on Deregulation
The FCC has released Public Notice DA-25-219 on March 12, 2025, seeking public comments on reducing regulatory burdens in line with Executive Orders promoting economic growth. This initiative aims to identify and eliminate outdated FCC rules that may hinder technological innovation, competition, and infrastructure development.
Key Details:
- Docket No.: 25-133
- IN RE: DELETE, DELETE, DELETE
- Objective: Streamline regulations to encourage investment and modernization in communications technology.
Comment Deadlines:
- Initial Comments: April 11, 2025
- Reply Comments: April 28, 2025
For details, view the full notice here.
来自FCC文件编号DA-25-219 的公告。
ISED Guidelines for Module Certification Under RSS-248
In response to inquiries regarding module certification under RSS-248 compliance, ISED has issued the following guidelines:
1. Limited Modular Approval (LMA) Classification
- Any module certified under RSS-248 is automatically classified as LMA under section 4.8.7 of RSS-248 Issue 3.
- Full Modular Approval (MA) is not permitted for any RSS-248 modules.
- Exception: Indoor subordinate devices cannot be certified as modules under any circumstances (neither MA nor LMA).
2. Precedence of RSS-248 Over RSP-100 Form D
- Even if a module meets RSP-100 Form D requirements (which allow MA), RSS-248 takes precedence, requiring LMA instead.
- Indoor subordinate devices remain ineligible for modular certification.
3. Status Change from MA to LMA
- No need to submit applications solely for changing a previously certified module’s status from MA to LMA.
- ISED will directly modify the status in Spectra.
4. Integration of Certified Modules into Hosts
- No C4PC application required for modules integrated into hosts that were introduced before RSS-248 Issue 3.
- Manufacturers are responsible for ensuring hosts with RSS-248 modules meet all designated class requirements.
5. Newly Integrated Modules in Hosts
- C4PC applications are required for RSS-248 modules integrated into new hosts (not yet on the market) to demonstrate compliance with RSS-248.
6. C4PC Applications for Multiple Hosts
- A C4PC application may be used to cover a specific RSS-248 class instead of a single host, provided that:
- The CB certificate lists certification conditions and class-specific requirements.
- Installation instructions specify that the module must only be used in designated hosts.
- If a module is to be integrated into a second class of hosts, a separate C4PC application is required.
- If RF exposure compliance must be separately assessed for each module/host combination, then individual C4PC applications are required.
Additional Resources
ISED has published accompanying Questions & Answers related to RSS-248 modules. These can be accessed on the Common Questions and Answers page by clicking the “RSS-248” button.
RSS-248 模块认证的指南
FCC KDB Updates
Question: What measurement procedures should be used to demonstrate compliance for millimeter wave (mmW) devices?
Answer: The FCC provides guidance for testing mmW devices under Part 30 rules, referencing ANSI C63.10-2013 (Clause 9) for general measurement procedures. Specific RF detector requirements apply to certain bands (Sections 15.253, 15.255, 15.257, and 90.103). Recent updates include:
- Clarifications on 60 GHz device compliance
- Testing considerations for harmonic mixers
- Correction to Equation (23) in ANSI C63.10-2013
- New limits for the 23.6-24 GHz range, effective January 13, 2025
Full details: FCC KDB 240776
Question: What is the FCC’s policy on referencing test data from another equipment authorization application?
Answer: The FCC allows test data from a previous equipment authorization application to be referenced in a new submission, following the guidelines in Attachment 484596 D01 Referencing Test Data v03.
Key points:
- New v03 process: Removes the requirement for an ECR KDB Inquiry; the TCB fully evaluates the data referencing proposal.
- Transition period until April 30, 2025: Older v02r03 procedures are still permitted but must be followed in full.
- No mixing of old and new procedures is allowed within a single application.
Full details: FCC KDB 219679
近期FCC KDB更新
