Newsletter "Packets" - Wireless News and Regulatory Updates

Issue 11

News for EMC engineers

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.


TCB Workshop summary

1. During TCBC council training given the week of October 8, 2007, the FCC reminds all parties that for certain licensed devices, approval from Wireless Telecommunications Bureau must be sought before a grant is issued. As of 9/19/07 the list included the following devices:

  • FRS/GMRS combination

  • Part 80 VHF (156-163 MHz)/FRS

  • Part 95G & Part 22/24/90

  • Amateur (Part 97); one exception is allowed for Part 97 (Amateur)/Part 87 (Aviation VHF 118-136.975 MHz)

       The following combinations have been rejected:

  • Part 15 and Part 101 at 92 - 95 GHz

  • MURS (Part 95J combinations)

  • Part 80 UHF (456 - 468 MHz) with FRS, GMRS, or FRS/GMRS

2. The FCC also had the following Miscellaneous Reminders and Updates:

  • Only Loop Antennas are allowed for radiated measurements below 30 MHz.

  • Cell Phones with computer port connectors (i.e. USB) must also be authorized as a computer peripheral.

  • After final transition date, all UNII devices imported or marketed need to comply with the rules. This applies also for replacement devices.  If a device is repaired and the repair does not require a new filing, then the device can be continued to operate under the existing approval.

  • Operation in an airplane is considered indoor use.

  • Section 2.1043 applies for updating a device to meet the EU RoHs directive.

3. New proposals were presented regarding changing policies for SAR requirements or when co-located SAR needs to be considered that will reduce certain PC laptop configurations

4. There was discussion on peak vs. average for power measurements of various licensed bands that utilize OFDM types of modulation (i.e. 90Y, 27, etc.).  FCC is currently still requiring peak power, although further discussion with industry will be continuing. A method for measuring average power is under development.

5. In the TCBC training, the FCC expressed concern with the TCBs and Labs that do not follow accepted test procedures.

From past experience what we see in a lot of reports is an EUT setup procedure, but very little on what accepted test procedure was actually used.  It should be understood that reference to the rule part IS NOT a test procedure; nor is the EUT setup a test procedure.  

According to FCC’s training guidance, a TCB should only certify a device where the report clearly and unambiguously state what test method (test procedure) was used. From now on we are strongly recommending to all test labs to make clear unambiguous reference to proper accepted FCC test procedures in the report.”  

6. Industry Canada requires that a DoC for terminal equipment be done at the same time as the transmitter.  If not, the DoC filing may be deleted or you would not be able to process the transmitter because it would not allow the model number.  Alternatively, the transmitter could be added under a reassessment.

7. IC requires that even if a licensed module was certified, when used in a final host the transmitter, would have to be recertified.

The FCC is working on collocation of transmitters and should have a method for TCBs to issue shortly. back to top...


Cooperative Agreements
in China ATCB 在中国

ATCB has signed cooperation agreements with China CESI, CTTL, and SRMTC (SRRC). ATCB和中国电子技术标准化研究所(CESI),中国泰尔实验室(CTTL),国家无线电频谱监测和检验中心(SRMTC)签署合作协议。

CESI, a state-run lab focusing on IT product testing for CCC in China, has signed the cooperation with ATCB on agreement of exchanging business sources, and will allow ATCB to promote and provide the agency service of China CCC testing/approval service in North America.


CTTL, a state-run lab focusing on providing Network Access Approval and RoHS testing in China, has signed the cooperation with ATCB on agreement of exchanging business sources, and will allow ATCB to promote and provide the agency service of China RoHS in North America.


SRMTC, a FCC-like branch of the Chinese, has signed a cooperation agreement with ATCB on exchanging business and technical resources and will allow ATCB to promote and provide agency service of China RF approval for North America.


1. ATCB held a public FCC, IC, CE certification seminar on 16 October 2007 in Beijing supported by CESI, CTTL, ITEM/ITC (Interference Technology China) and Many engineers from labs and manufacturers attended the seminar and expressed the appreciation for ATCB’s support on Northern China’s market.


2. ATCB supported China Quality Certification Center’s (CQC) internal training on 18 October 2007, providing information on FCC, IC, and CE approvals. CQC is the biggest Certification Body in China issuing the CCC mark, and the NCB of China. The training increases the ties and cooperation between CQC and ATCB.

ATCB参与了20071018日中国质量认证中心(CQC)内部举办的国际认证培训,ATCB做关于FCCICCE认证的讲习。CQC是中国最大的CCC认证机构,并作为中国的NCB参与CB scheme。此次培训增进了CQCATCB之间的合作与交流。

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Certification for New Technologies

We have received many inquiries on WiMAX, DFS, HSUDA and HSUPA. Here is a summary of the main issues brought to our attention:

WiMax and IEEE 802.16e devices:

  1. TCBs may approve devices under the “permit but ask” procedure, which requires FCC guidance prior to approval.

DFS Devices:

  1. DFS Master Devices: Applicant must go directly to FCC with the test sample

  2. DFS Client Devices: TCBs can authorize

  3. “Ad-hoc” or “Peer-to-Peer” Client DFS device: Applicant must go directly to FCC with the test sample (TCBs cannot approve “Ad-hoc” or “Peer-to-Peer” devices as they are considered to be the same as Master Devices)

View the information on DFS equipment authorization here (DFS Update) (Adobe .pdf format)

WCDMA and HSDPA Release 5:

  1. TCBs are allowed to approve 3GPP Release 5 of WCDMA & HSDPA device

  2. HSPA (HUDPA+HSUPA) Release 6 : Applicant must go directly to FCC

View the detailed test procedure for HSPA Release 6 here (HSDPA Procedure) (Adobe .pdf format)

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Editorial: Globalization of Standards

Nowadays, our worries—aside from the nine hundred pound gorilla squatting in Mesopotamia—are global. And to the extent that they are global, they are also shared. The extent that any one nation can do anything about them is constrained by a thorny dichotomy.  On one hand there’s the danger that we perceive (or, rather, the possibility of being bumped from our comfortable perch), but there’s the hope for a shared, improved destiny. Despite the official censorship in Communist countries and the influenced media in “free” states, the discussion of these problems is quite open. It’s reminiscent of the “threat from outer space” films in which the human race banded together, suspending silly squabbles until the aliens perished spectacularly. Read More… (MS Word .doc format)

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Questions and Answers:

QUESTION: Could you explain why a foreign-owned lab located in China cannot offer a DoC report to the FCC Rules? Can the accreditation be extended from abroad?

ANSWER: There are two requirements to allow a laboratory to offer FCC DoC reporting:

1. The Laboratory must be accredited under 17025 and

2. The country where the laboratory is located must have a Mutual Recognition Agreement (MRA) in-place with the USA Government

China does not have an MRA on telecommunications in-pace with the USA, so laboratories located in China may not provide a valid FCC DoC test report. Taiwan, Hong Kong and Singapore have MRA with the USA and laboratories located there can perform the testing and issue a valid DoC report. Note that there is a listing of laboratories on the FCC web site, which demonstrates that the laboratory has placed information on-file with the FCC and they can provide test data for Certification (not for DoC). Listing on the FCC site is not sufficient to issue a DoC Report. A listing of laboratories that have filed with the FCC for Certification can be found here:

To search for a firm that can offer a DoC report, select “Accredited” from “Test Firm Type” pull-down menu.

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QUESTION: Can TCB issue grant for DFS device with Ad hoc function?


ANSWER: Ad-hoc is considered the same as a master device and requires DFS testing as a master by FCC. This means full DFS testing and currently a 100% sampling at the FCC. TCBs cannot approve AD-HOC DFS devices. back to top...


QUESTION: What if a client-only 802.11a device supports ad-hoc only within the 5150-5250 and 5725-5825 MHz bands? What kind of documentation will the FCC require? Would it still need testing? Would a manufacturer's attestation be satisfactory?


ANSWER: Generally Yes...However if it is a Permissive Change (PC), then the attestation must clearly denote that all products since the deadline have been manufactured appropriately; the attestation should state that spurious emissions were considered and that the original test report still reflects the emissions from the device as appropriate for the channels still used even though DFS functionality has been removed. back to top...


QUESTION: What is the spacing in the body SAR test for a modem card when the cable is less than 20cm? Is merely back and front is OK? Or is it necessary to test all six sides?

ANSWER: When ATCB reviews the SAR test report, we review what test modes should be tested according to the possible position that this device might be used when end-user operates this device. For a modem card, the possible positions of this device might be:

If the front side or back side of this modem card may contact the body, measure SAR with 0cm space between modem card and body phantom on front and back side of your device.

If the device uses new technology (like 3.5G device), the FCC would request that testing be performed at 0cm spacing and 2.5cm spacing; the FCC has learned that the worst-case results are not always measured at 0cm spacing.

You should test all other sides of the cuboids, because the SAR test is measuring near-field electric field strength and the radiation pattern from antenna inside the device may be quite different when measured at different location. The purpose to test all other sides is to find out what location is the worst case. back to top...

QUESTION: For 3.5G devices, what spacing for SAR must be used for HSDPA and HSUPA modes? If the device supports GPRS/EGPRS, should 0cm and 2.5cm be applied to the test mode of WCDMA, GPRS/EGPRS?

ANSWER: The spacing is independent of the mode, whether it is GSM, GPRS, EGPRS, WCDMA or HSDPA. SAR testing with 0cm is necessary if the modem card can contact the body in the end use. For WCDMA, HSDPA and HSUPA, it is also necessary to test at 2.5cm space.

Please note that HSUPA and Rel 6 must be reviewed by FCC directly and devices that utilize these modes cannot be certified by TCBs. back to top...

QUESTION: If the device must be tested on all six sides, must every side be tested at 0cm spacing?

ANSWER: The test distance depends on the end use. If every side might contact the body, then SAR must be tested at 0cm. If this is not the case, then the SAR can be tested at other distances. SAR is tested very often with 2.5cm space when the minimum possible distance away body is greater than 2.5cm. back to top...

QUESTION: What is PermitButAsk Procedure?


ANSWER: This procedure is intended to further extend the types of devices that are acceptable for issuance of a grant by a Telecommunications Certification Body (TCB), but allowing the FCC to have oversight for those types of devices that are not sufficiently technically “mature” for TCB approval. TCBs may approve devices on the “permit but ask” list, but must obtain FCC guidance prior to approval.

Read more about Permit-But-Ask procedure … (Adobe PDF format)

QUESTION: Are TCBs authorized to review and issue FCC grant for WiMAX product operating in 3.4-3.7GHz frequency band under FCC part 101?


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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.