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...
Ask the FCC KDB: A “How To” Guide
KDB: OEM integrator cannot take responsibility for the end usage
KDB: Questions about Part 95 72-76 MHz R/C transmitter.
If our Taiwan labs (designated by BSMI) is able to do FCC DOC testing, can our China mainland lab implement FCC DOC testing but issue report in the name of Taiwan lab?
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We have a BT headset and already applied FCC ID.
Now, the manufacturer wants to sell this BT headset with a new power charger but the headset is identical. Shall the client do permissive I or II change?
view the answer...
Ask the FCC Knowledge Data Base (KDB)
Please see attached procedure “Ask The FCC KDB”
KDB 1: OEM and Integrator Responsibilities
An applicant is creating an international 802.11a/b/g DFS-capable DTS + UNII mini-PCI card. The manufacturer has two questions.
1.) Can the applicant require the OEM integrator to be responsible for ensuring this device meets the DTS channel 12-13 prohibition?
2.) Can the applicant require the OEM integrator to be responsible for insuring that, when the module is used in a DFS-required UNII band, a separate DFS equipment authorization is obtained?
The bottom line is: can the Applicant put the burden of compliance on the OEM integrator? In both the above instances drivers are available freely to OEM integrators and can be easily downloaded into the device.
OEM’s cannot take responsibility for the end-use of a product. The FCC ID Grantee is not permitted, except in an extremely limited way, to place burden for compliance on OEM integrator.
I assume that an OEM is other companies that would integrate the device as a module into a host and your question is can an applicant apply for a modular grant under multiple rule parts 15 B (15.247) and 15 E (15.407) with the following conditions:
1) The module is capable of operating world wide- on both US and non US frequencies.
2) The module only has partial capabilities for compliance with 15 E DFS and TPC requirements.
3) The third party host system (OEM integrator) would need to provide the missing controls for compliance.
4) The third party would down load US drivers commonly available on the internet- and the third party would be responsible for operating only on US frequencies without further testing.
For DFS and TPC, the third party would obtain a new certification. Note: the question “can a separate DFS equipment authorization be obtained for DFS” is not relevant to the grant for the module since the OEM would have to obtain a new authorization. The module, in this case would be an uncertified sub-assembly and the OEM needs a new certification for the ensemble (host and sub-assembly).
The answers may be different depending if the device is client or a master.
A client module (as defined in 15.202 rule part and definitions for a DFS Client device) may be possible. The device cannot initiate any non compliant transmissions or 802.11 probes. All transmissions must be under the control of a certified master.
As a master device a standalone module approval is not possible since compliance is dependent on the host.
There may be other possibilities as a limited host-specific module using bios protection and/or as a software defined radio, with the grantee controlling the software and the security. However, this grant would be tightly coupled with specific hosts and the grantee would be responsible and must state how control of the end product into which the module will be installed will be maintained, such that full compliance of the OEM’s end product is always ensured.
However, these conditions are definitely not in line with your question: “Can the Applicant put the burden of compliance on the OEM integrator”. The bottom line to your question is NO: the applicant cannot put the burden of compliance on the OEM integrator.
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KDB 2: RF Crystal Change Restrictions
A Part 95 72-76 MHz R/C transmitter contains a single RF channel module that appears to be user-installable. The label is on the module and it is unclear if it should apply to the complete product or just the module.
I seem to recall a prohibition for end-users to change out crystals in R/C controllers. Does this same prohibition apply to user-installed RF Modules?
The module contains a single crystal. It does not appear to be permanently fixed within the device (soldered) and is accessible when two small screws are removed. Is this permitted?
In general KDB Publication Number 587968 is applicable, but with allowed provision as follows:
For Part 95 devices, EA Certification is not permitted for devices that allow an end-user to change plug-in crystals. If different plug-in crystals are installed only by an OEM, then approval for multiple crystals and frequencies under one FCC identifier is permitted, and must include test data for each configuration. Permissive change to amend other crystals and frequencies is permitted only if the added frequency(ies) are within the range of the original grant; a new FCC ID is needed for crystal frequencies outside the original range. FYI note also requirements in Part 95.645(b).
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Questions and Answers: DOCs and Permissive Changes
QUESTION: If our Taiwan lab (designated by BSMI) is able to do FCC DOC testing, can our China mainland lab implement FCC DOC testing but issue report in the name of Taiwan labs?
ANSWER: Mainland China (PRC) does not have an MRA with the US. Therefore absolutely NO mainland China lab can perform testing for DoC to the FCC rules regardless of who accredits them or what the ownership structure might be. For example, there are many labs accredited by A2LA and NVLAP in Mainland China, but NONE of them meet the FCC rules for a qualified lab needed for DoC testing. So, while BSMI may, for their regulations and purposes define a Mainland lab as under control of a Taiwan home office and thus extend the ability of that Mainland lab to do work for BSMI purposes, the FCC is not bound by BSMI nor by Taiwan accreditation systems for dealing with PRC labs. Since the FCC only has an MRA with Taiwan and not Mainland, only those appropriately-approved Taiwan Labs (i.e., located physically in Taiwan) are accepted for DoC.
The FCC under Part 2.948(e) states “(e) The accreditation of a laboratory located outside of the United States, or its possessions, will be acceptable only under one of the following conditions: (1) If the accredited laboratory has been designated by a foreign designating authority and recognized by the Commission under the terms of a government-to-government Mutual Recognition Agreement/Arrangement; or (2) If the laboratory has been recognized by the Commission as being accredited by an organization that has entered into an arrangement between accrediting organizations and the arrangement has been recognized by the Commission.”
Under 2.948(e)(2) the FCC has not recognized and does not intend on recognizing any agreement between accrediting bodies where the accrediting body country does not have an MRA with the US. So it does not matter if A2LA or NVLAP as an agreement with other accrediting bodies or not. The simple fact remains that the FCC has not recognized and will not recognize any such agreement between accrediting bodies from non-MRA partners. Consequently any DoC done by such a lab is in violation of the rules and is not considered properly authorized. The FCC enforcement bureau is also beginning to address this issue and will at some time probably make an example of offenders. This could be in the form of fines, denial of grantee codes, blocks placed on FRNs etc.
QUESTION: We have a BT headset and already applied FCC ID. Now, the manufacturer wants to sell this BT headset with a new power charger but the headset is identical. Shall the client do permissive I or II change?
ANSWER: Assuming the transmitter will function when it is charging, you will need to do a PCII. If the transmit is disabled while charging, a PCI (or equivalent) will be satisfactory.
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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.