"Packets" - Regulatory Updates for the Wireless Industry	Issue 18

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 technology equipment.

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 evaluation performed.

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 worst-case configuration.

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QUESTION 1:

What is the correct distance attenuation factor which should be applied to a low frequency Part 18 measurement?

ANSWER :

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 limit distance.

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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QUESTION 2:

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?

ANSWER :

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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QUESTION 3:

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?

ANSWER:

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 compliance.

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 results”

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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QUESTION 4:

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?

ANSWER:

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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QUESTION 5:  

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?

ANSWER:

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 [1].  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 [2].  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 [3].  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 that either:

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 GHz.

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 [4].

[1] 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.

[2] 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 C63.4-2003.

[3] See ANSI C63.4-2009, clause 5.5 for the specific requirements for test facilities used to perform radiated emission measurements above 1 GHz.

[4] See ANSI C63.4-2003, clause 5.5.

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QUESTION 6:

Do Tri-band and Single-band cell and PCS phones need separate FCC Identifiers (FCC ID)?

ANSWER:

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 FCC IDs.

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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QUESTION 7:

May I ask the process (Verification or Certification) for the BPL products in Canada? Please advise if the regulation of ICES-006 is appropriate.

ANSWER:

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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QUESTION 8:

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 correct?

ANSWER:

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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QUESTION 9:

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?

ANSWER:

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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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.