Newsletter "Packets" - Wireless News and Regulatory Updates

Issue 12

ACB 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.

In this issue...

Questions & Answers

  1. How many channels can be used for a WLAN device per FCC rules?

  2. Wireless keyboard & mouse RF warning statements

  3. Do we need two FCC IDs for a system with two transmit frequencies?

  4. Could you tell me how to apply FCC Part 68 SDOC (Supplier Declaration of Conformity)?

  5. I forgot my FCC FRN password. How can I get a new password?

  6. Which FCC standard is applicable to RF devices operating at 150KHz?

  7. We have an FCC-Certified GSM Cellphone; do we add GPRS/EDGE with a PC III?

  8. Are 802.11 b/g devices harmonized within the EU? Or is notification necessary?

  9. What is 802.11n? If countries in EU accept 802.11 b/g, do they accept 802.11n?

  10. If a device incorporates a transmitter with full modular approval, does the host device require a PCII change?

  11. If a lab is approved and certified as an ANTENNA and SAR probe calibration body, can they calibrate their own SAR probe?

  12. If our lab has some test facilities but does not have FCC 2.948 test site, which test parameters have to be tested in the listed site and which test parameters can be tested in a non-listed site with our facilities?

  13. Is an analog fixed telephone still subject to FCC Part 15?

  14. Some Power Amplifier (PA) transistors are being changed in our transmitter device. What we should do to update an IC certificate?

  15. Can you provide some information about the FCC, IC certification for TD-SCDMA base station operating in the frequency range of 2010-2025MHz?

  16. If a product is tested for SAR and is issued under an FCC report, could the SAR report be used for IC certification?

  17. What are the FCC/CE requirements for test reports of MIMO and DFS test cases?

  18. WiFI and DFS Questions for WiFi Access Point

  19. Is LED lighting subject to Part 15 or Part 18 approval?

  20. We have a Walkie-Talkie held-to-face device operating in 450MHz frequency band. Which EN rule part can be used to determine if this device requires SAR evaluation?


Labs must follow accepted test procedures

In the TCBC training recently the FCC made one thing very clear. They are not happy with the TCBs and Labs that do not follow accepted test procedures. In an FCC review of many certification reports, there has been a lack of detail on the accepted test procedure that were used to claim compliance.

Please note that reference to the rule part IS NOT a test procedure. In order for a TCB to certify a device the report must clearly and unambiguously state what test method (test procedure) was used.  

All test reports must be adequately reviewed and the labs need to be required to make clear and unambiguous reference to proper accepted FCC test procedures. back to top...


FCC Annual Surveillance Report

In adopting rules to streamline the Equipment Authorization Process and establish Telecommunications Bodies (TCBs) to grant Certification in lieu of the Commission, as adopted on December 17, 1998 (See Report and Order, GEN Docket No. 98-68, FCC No. 98-338 released December 23, 1998), the Commission placed certain responsibilities on TCBs. The Commission stated, in the Report and Order that in accordance with ISO/IEC Guide 65, TCBs were to perform surveillance on products that they had approved. Currently we have established (see KDB publication 610077) that a TCB should conduct surveillance of 2% of the total number of products approved by them for a given year. As we discussed in the October 2007 TCB Workshop in Maryland, the Commission is considering raising this percentage of required surveillance sample testing for calendar year 2008. We will inform you of the revised requirements for 2008 soon.

In order for the Commission to evaluate the TCB surveillance program, we ask that TCBs report to the Commission by December 15, 2007, on post grant testing that has been conducted and surveillance data that they have compiled since the inception of the TCB program. The report should include the number of approvals per scope, the number actually audited and the numbers passing or failing. Also, you should report the same numbers for surveillance testing of EUTs that had an RF Exposure evaluation and corresponding surveillance data.

As of December 18, 2007 the FCC has raised the required audit sample testing requirements from 2% to 5%. This is an increase of 2.5 times previous requirements. The FCC has also stated that this increase will affect all TCBs both foreign and domestic. A clarification of this new requirement will be provided by the FCC in the next few weeks. back to top...


ACB announces opening of UK Office, Michael Derby to Head Effort in European Union

ACB is pleased to announce the opening of its first European Office with the hiring of Michael Derby. The office, which will serve as the central nexus for servicing the European Union Market, commenced operation on November 1, 2007. This step expands ATCB’s coverage for Certification and Wireless Engineering support to the EU. Adding to offices across the US, Taiwan, Shenzhen, Shanghai and Beijing, ATCB is prepared to serve international markets in all time zones.

Michael has direct experience performing radio measurements, supporting standards activities and managing teams of test engineers in a laboratory setting. He most recently was manager of the Radio Performance Group at RFI Global Services in the UK, managing product approvals for telecommunications clients. His foundation in EMC, Radio, Microwave and Site Survey work brings a critical set of tools to ATCB’s clients.

Michael has spent much time developing standards for ETSI (The European Telecommunications Standards Institute), supporting the work of the BRAN and TG committees. This direct lab and standards-basis set of skills will provide invaluable support for TCB as well as Notified Body work.

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Use characters for IC application

Industry Canada has indicated that if the use of the same character in succession such as
"- - -" or “XXX” in a model name is not used for the purpose of identifying multiple models, it would be acceptable to IC. This applies only to model numbers and not to IC identifiers. back to top...


Permissive Change Policy

The FCC has released the latest Permissive Change guidance document, the document in PDF form can be found here (Permissive Change Guidance).
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Authorized Individual Policy (Form 731)

The “authorized” individual, when referred to in relation to both an FCC and TCB Form 731 Application for Equipment Authorization, is identified as either the applicant / grantee contact of record in the Grantee Code data base, or the agent authorized by the applicant / grantee. Only an authorized individual may “sign” the Form 731, and only an authorized individual may request confidentiality – i.e. the confidentiality letter must be signed by an authorized individual and uploaded into the Cover Letters exhibit folder.

This document can be found in PDF format here.
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Questions and Answers:

QUESTION: Our client is designing a WLAN device; can they allow any channel to be selected by the user? For example, the device has 1-14 Channels available for WLAN operation. During the installation, the user can choose the region, then the software selects any channel from 1 to 13. Is this acceptable?
ANSWER: No. This is not acceptable by FCC. For 802.11b/g WLAN device, FCC only allows channels 1 to 11 to be used. Usually the applicant will be asked to provide an attestation letter to state this device can not be selected to operate in 12, 13, and 14 channel by end user. back to top...

QUESTION: Why doesn’t my wireless keyboard or mouse need to affix the RF warning statement for FCC?
ANSWER: Simply stated, the power is below the threshold. From the TCB Exclusion List dated July 2002, any device below the "Low Threshold" [60mW/f(GHz)] is not required to do any SAR testing. However, it is still necessary to consider co-location issues if adjacent to another transmitter. And, if you look at the footnotes in the Exclusion List, devices with an RF Pout (radiated AND/OR conducted) below 5mW are not at risk of co-location problems. Therefore low power items such as Bluetooth do not have to deal with RF Exposure concerns. (The TCB Exclusion List provides essential information, however, the FCC's Knowledge Database is considered to be the most up-to-date information on compliance issues.)

Please note that while a device may have a very low power level and is categorically excluded, all devices still must abide by RF exposure and need a RF warning statement. The way these low power devices deal with this is by being categorically excluded (categorically excluded does not mean exempt). back to top...

QUESTION: Our system operates at two different frequencies: 433MHz and 2.4GHz. Can a single FCC ID be used for the system?
ANSWER: If the two transmitters are assembled together in the same product, one FCC ID is used for the product.
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QUESTION: Could you tell me how to apply for FCC Part 68 SDOC(Supplier Declaration of Conformity)?
ANSWER: Login in at submit your files and remit appropriate fees. back to top...

QUESTION: I forgot my FCC FRN password, how can I find it and how can I update my FRN info?
ANSWER: Use for these questions. You should expect to get complete instructions on how to reset the password and a host of other information from this group at FCC. You will need to prepare a formal letter indicating the new contact person, address, phone, and email associated with your Grantee Code. This letter should be on your corporate letterhead. And please keep the Grantee Code password in a safe place for any future changes to the Grantee code database, which can be made after logging into the system. back to top...

QUESTION: Which FCC standard is applicable to the RF device operating at 150KHz?
ANSWER: Most RF devices are Certified under 15.209. But be careful - do not allow any carriers emissions within the restricted bands of 15.205, and make sure that the spurious emissions are less than the fundamental. back to top...

QUESTION: We have a mobile phone that already been certified for FCC ID. Now we are going to change the software part to add the function of GPRS/EDGE, and all the other hardware, circuit board, RF will remain the same. If the software upgraded model can be subject to permissive change and use the original ID number. Is this subject to PC III?
ANSWER: If you already have a GSM phone but are adding GPRS functionality with absolutely zero changes in hardware, a PCII may be appropriate (still must have same output power). But if they are changing from another modulation format like CDMA to GSM/GPRS then a new ID is required.

Note that Class III PC is applicable only to 'software defined radios' and can only be approved by FCC.
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QUESTION: Are 802.11 b/g devices harmonized within EU? Or is notification necessary?
ANSWER: France has yet to fully harmonize the band that is normally used for 802.11 b/g devices.

802.11b/g is acceptable over the full frequency band (2400 MHz to 2483.5 MHz) and at the full EIRP level (100mW) in all EEA (European Economic Area) Countries except for France.

In France, the band is only acceptable from 2400 MHz to 2454 MHz at 100 mW. You can continue to use the devices in France from 2454 MHz to 2483.5 MHz but must drop the EIRP down to 10 mW or must insist on indoor use only.

Most manufacturers do not want to reduce the output power 10 mW and don't want to have a separate device just for France, so most manufacturers make their European model operate from 2400 MHz to 2454 MHz at 100 mW. When testing, most manufacturers test their USA (FCC) devices using WiFi channels 1 to 13, then test their European devices using only channels 1 to 11.

Although the device is Class 2 (because the band is not harmonised), the countries do not require Notification as long as the rules of use are included in the user manual (must not use channels 12 and 13 outdoors in France).

The bands used by 802.11a in Europe are now harmonised and therefore all countries will accept them.

However, they can be a little confusing.
The bands of use are: 5150 MHz to 5350 MHz and 5470 MHz to 5725 MHz.
A summary of the limitations are:
5150 MHz to 5250 MHz: 200 mW EIRP, indoor use only.
5250 MHz to 5350 MHz: 200 mW EIRP, indoor use only, DFS test required.
5470 MHz to 5725 MHz: 1 W EIRP, DFS test required.

The bands are harmonized and therefore Country Notifications are not required; the device is still considered a Class 2, because the indoor use requirement means it can't be used "anywhere".

The EU may be rewriting the DFS section of the standard to deal with weather radar in the 5600-5650MHz range. The existing DFS test requirements do not adequately test DFS for this type radar and the EU is finding some cases of interference. This would be a case where, while there is a harmonized standard, that harmonized standard is not adequate enough to give a presumption of compliance.
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QUESTION: What is 802.11n? If countries in EU accept 802.11 b/g, do they accept 802.11n?
ANSWER: The suffix "n" after the 802.11 name means that it allows a multiple input/multiple output antenna system to be used. This is often known as “MIMO”.

MIMO operation is allowed for both 802.11b/g and 802.11a). These standards, including the MIMO tests, are harmonised (accepted).

Therefore, the addition of "n" should not change anything with regard to acceptance in Europe. If a country accepted 802.11b/g and 802.11a, then there would be no problem with adding 802.11n. back to top...

QUESTION: If a device incorporates a transmitter with full module approval, does the host device require a PCII change or just affix “Contains FCC ID:XXXXXXX”?
ANSWER: Please See FCC rule 15.212 and attached FCC modular approval document. Neither DA001407 nor 15.212 say or even suggest that a PC is needed if a full modular (single modular) approval is done. You do not have to do a PC for a full modular approval if you follow the grant notes. You only need do a PC when a LIMITED Modular Approval is involved or when you are not following the full modular approval grant notes or when collocation is involved. Again full modular approvals do not require a PC simply to put it in a host. back to top...

QUESTION: If a lab is approved and certified as an ANTENNA and SAR probe calibration body, can they calibrate their own SAR probe? Or msut labs return equipment back to the original factory for the SAR probe and dipole antenna calibration?
ANSWER: There is nothing that prevents a capable lab from calibrating their own probes and dipoles as long as they come within the allowed tolerance in the standard. Of course the calibration would have to meet the US requirement (not EU requirements for US use, i.e.). They would still have to provide the actual calibration data and certificate and justify the calibration as being traceable to the acceptable standards organization. back to top...

While there may be no requirement from the FCC on who calibrates SAR probes, there will be requirements from the labs accreditor to use an accredited calibration source for their equipment or to have an acceptable calibration method included in their QA system. If the lab is not accredited then the TCB must be confident in the source of equipment calibration as well as the testing capabilities of the lab doing the SAR. back to top...

QUESTION: If our lab has some test facilities but does not have FCC 2.948 test site, which test parameters have to be tested in the listed site and which test parameters can be tested it in a non-listed site with our facilities? Or must every test parameter be completed in listed site?
ANSWER: As long as the 15.209/15.207 testing requirements are met at a listed site, it is does not matter where the "bench tests" or RF conducted tests are performed. So the Part 15 AC conducted test and Part 15 radiated test must be performed on a listed site. But bench tests on the RF conducted parameters can be done anywhere. back to top...

QUESTION: Regarding an analog fixed telephone subjected to FCC Part 68. What is required?
ANSWER: While 15B for computers and computer peripheral devices are DoC or Certifications, most digital devices are is still required to meet the FCC rules. Digital devices under part 15 are Class A and Class B. Consequently, any digital device must comply with the rules but digital devices used as computers or computer peripheral devices require either DoC or certification. A loop start analog POTS phone without any AC power required and NO digital circuitry would require Part 68 only. If the phone device is a computer peripheral, it will require both Part 68 and Part 15B. back to top...

QUESTION: Some Power Amplifier (PA) transistors are being changed in our transmitter device; the power output and frequency are still the same as before. Meanwhile several resistances, inductances and capacitances in the PA circuit are also changed accordingly. Except for the above change, no other change happened. What we should do accordingly for the IC certificate?
ANSWER: One must be very careful about changes in the PA circuitry in a device. The new component must be verified that it is electrically identical and a pin-for-pin replacement. A new ID is usually required if new RF amplifier or frequency determining components are changed. back to top...

QUESTION: Can your provide some information about the FCC, IC certification for TD-SCDMA base station operating in the frequency range of 2010-2025MHz?
ANSWER: In North America, 2010-2025MHz band is not allowed. The closest frequencies are the Part 24 bands of 1850-1910MHz (subscriber) and 1930-1990MHz (base) or Part 27 (2100MHz and above). For Part 27 you may be at a disadvantage because of advances in WiMax-related technologies which will allow very high data transmission rates, more than TS-SCDMA may allow. Currently, 2000-2020MHz is a Part 25 (satellite services) frequency band; under this allocation, both ATC (Ancillary Terrestrial Components) mobile devices and base stations can operate in this band. back to top...

QUESTION: If a product is tested for SAR and is issued under an FCC report, could the SAR report be used for IC certification?
ANSWER: While IC does not require a SAR report to be uploaded to their site, they do require annexes A and B of RSS102 to be uploaded. These annexes are the attestation to SAR compliance and the highest SAR data from the SAR report. IC and FCC SAR requirements are very similar so you can use your FCC-SAR test data to fill out the RSS102 annexes and provide this with the IC application. back to top...

QUESTION: What are the FCC/CE requirements for the test reports of MIMO and DFS test cases?
ANSWER: MIMO testing is straightforward. The only real differences have to do with how Pout is tested because, in essence, you have two transmitters working in parallel with a lot of signal processing. TCBs can handle all MIMO certifications for the 2.4GHz band with no problem.

DFS is trickier. In general "full" DFS approval for a "master" station must be performed by FCC and a sample submitted directly to them. However, if you have a "client-only" DFS project with no "ad-hoc" capabilities (such as for notebook PC) then the TCB route is available to you.

Also, be mindful of RF Exposure requirements. For 2.4GHz work SAR testing may be required for all RF category "portable" equipment if the power is above 60mW/f(GHz) if the user can contact the antenna or 120mW/f(GHz) if the antenna is 2.5cm away from the user. But according to our radio law, all 5GHz 802.11a "portable" devices under 15.407 must have SAR testing regardless of Pout.

There is nothing new for the process within Europe; the same standards and processes for applying the CE Mark for MIMO devices. For testing procedures, MIMO (“smart antenna”) issues are addressed in the latest versions of both the standards, EN 300 328 (for 2.4 GHz) and EN 301 893 (for 5 GHz) devices.

Both standards explain how the antenna ports should be configured for the power and emissions measurements. EN 301 893 explains how the receiver antenna paths should be configured for DFS. Basically, there are just one or two extra lines of text in the standards, to address the MIMO and 802.11n issues. back to top...

QUESTION: For a Wi-Fi access point:

1) Should the application be sent to FCC directly for DFS test and approval, or can 2.948 listed site perform DFS test for it and go TCB route?
2) Does 802.11a/802.11n laptop or Wi-Fi card need to do SAR test?
3) Do 802.11a/802.11n AP need SAR testing?
1) An 802.11a/g access point with DFS detection capabilities will need to be tested at a Part 15 listed laboratory which has DFS testing capabilities. Please review FCC Rule 15.407 for complete details of the requirements and bands and their limits for DFS test. The FCC will do testing only after they receive the application and complete all appropriate reviews. DFS capable devices have a 100% pre-Grant sample test program.

2) If your 802.11n WiFi card has DFS detection capabilities, then it will need to be handled just like an access point. But if it has no DFS detection and no ad-hoc mode it can be approved as a "client only" device with just a minimal amount of extra DFS testing , TCBs can do these approvals. But Generally by almost by definition an Access Point would be a master device.
3) SAR testing is a separate subject. If the antennas of the device are within 20cm of a user, it is classified by law as an RF category "Portable" device and SAR testing would be a requirement for 5GHz 802.11a. If 2.4GHz only, it will be subject to either 60mW/f(GHz) or 120mW/f(GHz) to determine if SAR testing is needed. back to top...

QUESTION: We have a LED lighting with external AC/DC switching mode power adapter and would like to know whether this product should be tested as RF lighting according to FCC Part 18 or Digital device according to FCC Part 15B? Is it subject to DoC or certification?
ANSWER: Over the years many of these types of devices ask the FCC and many times the FCC has a reason beyond the scope of the rules which it should be under. However, the FCC has seen beyond this in several cases and asks for something more or different. For instance in some cases they have said the device is more like a power supply under 15. While other times they have said that even though it is more like a power supply, because it drives a light it should be under 18.

Generally based on experience is that this should be 15, since the output is DC and NOT an AC RF waveform. However given the number of times I have seen them answer from the FCC be the opposite of expected (relative to RF lighting question) - the safest route would be to do a KDB on this.

Note that even Part 18 has a DoC - but labeling and other issues differ.

For instance:
Section 18.203(a) basically means all Consumer based (home use) equipment approved under Part 18 must be approved by either a DoC or Certification authorization. If the lighting device is strictly intended for industrial (non-consumer) use, it may be subject to Verification.

Note that manufacturer and/or lab may choose which to use (DoC or Certification) for consumer RF lighting devices. Each route will required different labeling, but the route to compliance may be decided by the manufacturer. Note if the device only requires Verification, then particular labeling requirements for this must be followed and not the DoC or Certification requirements.

Radiated tests may be omitted when the operational frequencies of the RF lighting device are less than 1.705 MHz, based on table 18.309. This is due to the fact that RF lighting devices only require radiated measurements > 30 MHz, and the table 18.309 does not require measurements of Radiated if the frequencies are < 1.705 MHz.

Note that a DoC means a lab that is allowed to do DoC's under Part 2 of the FCC rules (meeting both accreditation and MRA for foreign labs). back to top...

QUESTION: We have a Walkie-Talkie held-to-face device operating in 450MHz frequency band and want to know which EN rule part can be used to judge if this device requires doing SAR test.
ANSWER: The RF exposure for devices not covered by a specific RF exposure standard are not exempt from showing RF exposure compliance. For example, low power devices have a standard that mentions a 20 mw power level at which to begin considering RF exposure. RF exposure for these devices could possibly be made without the involvement of a notified body. Some types of devices, such as Cell phones etc, also have specific RF safety standards to refer to and the involvement of a notified body is not needed. Some device such as the 450MHz PMR/PAMR device in this question do not have appropriate harmonized standards for RF exposure and consequently Annex II or III may not be appropriate as assumption of conformity to harmonized standards is not possible. In the case where there are no Harmonized Standards, a notified body under annex IV of the RTTED would be a method to determine compliance to the essential requirements of the RTTED. The lab and/or manufacturer would need to provide evidence that RF exposure has been addressed for these devices and that the appropriate levels were met. RF exposure concerns and selection of an appropriate RF safety standard to use should be done in consult with the notified body prior to testing. If no such evidence is provided, the NB would probably give a negative opinion as the RF safety requirements would not be met in relation to article 3 of the RTTED. back to top...

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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.