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MultiPoint Newsletter - September 2011 Issue

Dear Colleague,

We have provided typical questions and answers that represent in most cases technical opinions with justification in FCC, IC and CE requirements. The particulars of the product for certification must be considered with respect to the applicability of these questions and answers. We hope you find our update valuable and welcome your feedback if you have any special needs or questions. Call us at 703.689.0368 for your testing requirements. You can view archived issues of MultiPoint at our website.


FCC Requirements for a USB Dongle

Question: We manufacture USB transmitter dongle devices and have long assumed the following:

  1. Our transmitter does not require Part 15 Class B computer peripheral device certification or FCC Declaration of Conformity (DoC) procedure for home use since the USB port on our device is only used for charging our transmitter.
  2. The USB port on our device is only used for upgrading our dongle transmitter’s firmware; there is no data transfer. The dongle device would still require FCC Part 15 certification or the FCC’s DoC procedure.

Can you confirm if our assumptions are correct?

Answer: Your transmitter is not subject to FCC 47CFR 2.906 Declaration of Conformity (DoC) if the USB port is only used to charge its battery, and no data, or status, is transferred or received, nor are control signals changed. However, if while charging through its USB port it does transfer or receive data, status or control signals, then it is subject to FCC 47CFR 2.906 DoC rule. If the transmitter that is being charged has digital components, then it is considered a digital device and would be subject to for unintentional radiators. If the USB port on your device is only used for upgrading software, it is subject to the FCC DoC procedure.


FCC Guidelines for a UNII Device

Question: We have a UNII device that we wish to certify with the FCC. Our device has upgradeable firmware and the transmitter is enclosed in a NEMA weatherproof enclosure. What should we be aware of, and has the FCC revised KDB 594280 D01 Software Configuration Control?

Answer: The FCC revised KDB 594280 in June by publishing 594280 D01 Software Configuration Control v01r01. This revision adds clarification for applications for equipment authorization for non-Software Defined Radio transmitters that contain upgradeable firmware. The FCC has discovered ongoing interference issues with UNII devices and Terminal Doppler Weather Radars (TDWR) that use the 5600-5650 MHz frequency band. The interference issues are a direct result of these devices being operated illegally in this band. If your device is firmware upgradeable, it must not be capable of being modified or updated by software to operate in the TDWR band. If you are applying for a UNII FCC certification as an indoor device, enclosing the transmitter in a NEMA housing would be seen by the FCC/TCB as a red flag indicating that the intended use of the device is in outdoor environments, not indoor use. Hence certification would be impossible under such a configuration.

The FCC/TCB is now paying very close attention to the use of enclosures and antennas, user manuals with extended frequency guidance that can be upgraded via software, conducted power back-off and operational descriptions. A manufacturer’s attestation would no longer be sufficient to justify the aforementioned items to satisfy the FCC/TCB’s conditions for certifying these devices.


FCC Acceptance of CISPR 22 Data

Question: We manufacture wireless devices abroad for the European market. It is our understanding that the FCC accepts CISPR 22 measurement data for unintentional unlicensed Part 15 devices. Is this correct?

Answer: The FCC accepts measurement data for unintentional unlicensed Part 15 devices using ANSI C63.4 standard and CISPR 22 1997 standard limits below 1GHz. However, most manufacturers and some test laboratories believe that the FCC accepts measurement data based on any CISPR 22 standard limits, regardless of the year. In fact, 47CFR 15.38(a) lists only the third edition of the International Special Committee on Radio Interference (CISPR), Pub. 22, “Information Technology Equipment—Radio Disturbance Characteristics—Limits and Methods of Measurement,” 1997, IBR approved for §15.109. The FCC accepts data based only on §15.109 and limits of this CISPR edition. For the limits of any other edition or year to be acceptable, it would have to be included in the list in , or included in a policy from the FCC, as described here in FCC 47CFR 15.38(a) “Incorporation by reference” rule: “The materials listed in this section are incorporated by reference in this part. These incorporations by reference were approved by the Director of the Federal Register in accordance with 5 U.S.C. 552(a) and 1 CFR part 51. These materials are incorporated as they exist on the date of the approval, and notice of any change in these materials will be published in the Federal Register."

We have no knowledge of FCC dismissals as a result of using the limits from other CISPR 22 standard versions and dates; nonetheless, FCC 47CFR15.38(a) lists CISPR 22 1997 standard limits as the only alternative limits for Part 15 device measurement data.

Note: This article was updated on 02/07/2012 as suggested by Mr. Harry Hodes of Acme Testing Company. MultiPoint would like to thank Mr. Hodes for his correction.


FCC Rules for the Importation of RF Devices

Question: What are the FCC requirements for importation of radio frequency devices into the United States?

Answer: The FCC regulates the marketing, sale and importation of radio frequency devices. When importing a radio frequency (RF) device, the importer or ultimate consignee, or his designated broker, may be required to declare that the radio frequency device meets the FCC importation conditions under Section 2.1204 Title 47 of the Code of Federal Regulations (CFR).

斗地主达人A radio frequency device is any device capable of emitting radio frequency energy (see Section 2.801). This includes radio transmitters, and any electrical device that uses internal electrical signals and/or electrical pulses that may create radio frequency energy, etc. Digital cameras and other digital electronic devices are examples of RF devices that may unintentionally radiate radio frequency energy and cause interference.

斗地主达人Technical standards for devices that are required to comply with the FCC requirements are specified in the applicable sections of the rules. Many of these devices are required to be labeled, tested and have their performance documented under the FCC’s equipment authorization procedures. Certain exclusions and/or specific conditions may modify or eliminate this requirement (discussed below, see FCC Form 740 Declarations, or Sections 2.1202 and 2.1203 of the rules).

When importing an RF device, the designated broker or importer of record must declare the appropriate entry conditions on the FCC Form 740, either electronically or by attaching a Form 740 to the U.S. Customs entry papers. To assist Customs in identifying when a declaration is necessary, the Schedule of FCC 740 requirements by Harmonized Tariff Schedule (HTS) indicates the following:

  1. when an FCC Declaration may be needed (referred to electronically as FC3 code), or
  2. when a declaration is required (referred to as FC4 code).

When imported goods are identified that FCC Declaration may be needed (FC3 code), the following guidance applies:

    1. The importer may disclaim the Declaration and not submit the Form 740, if the goods are not RF devices.
    2. The importer may disclaim the Declaration and not submit the Form 740, if the goods are RF devices but meet the following specific exclusion conditions:
      • An RF device that is exempt from the equipment authorization procedure (Section 15.103);
      • An RF device that does not meet the definition of a device requiring equipment authorization, or is considered an incidental radiator device and does not require equipment authorization (Section 15.101);
      • An RF device that is excluded from the import conditions (Section 2.1202). See note 1 below.

Note that instead of disclaiming the declaration, the importing party may elect to submit a Form 740 to facilitate the entry of goods.

  1. The goods require an equipment authorization. A declaration must be done either electronically or hardcopy using Form 740.

When imported goods are identified as “FCC Declaration required” (FC4 code), Form 740 must be submitted either electronically or hardcopy.

FCC Form 740 Declarations:

Just Part I of Form 740 is for product data information and manufacturer, importer or consignee information entry。 In the case of devices as described in Part II of Form 740, Item 1 requires an FCC ID; enter “X” in this box, the rest of the other boxes are not applicable。

For Part II there are eight categories that require declaration:

  1. The FCC issues a Grant of Equipment Authorization with the FCC ID listed.
  2. An FCC Grant of Equipment Authorization, or an FCC ID is required, but the equipment complies with FCC technical requirements (equipment that is granted under the Verification or Declaration of Conformity authorization procedures, no FCC ID is required).

    However, if the device meets specific exclusion conditions and the Form 740 harmonization schedule indicates required (FC4 code), or the importer elects to make a Form 740 declaration (under the FC3 or as a no code option), then item 2 may be used to declare:

    • An RF device that is exempt from the equipment authorization procedure (Section 15.103);
    • An RF device that does not meet the definition of a device requiring equipment authorization; or considered an incidental radiator device and does not require equipment authorization (Section 15.101);
    • An RF device that is excluded from the import conditions (Section 2.1202). See note 1 below;
    • A non-RF device that is categorized as required (FC4).
  3. The described equipment is being imported in limited quantities for testing and evaluation for compliance with technical requirements or marketing suitability. The equipment will not be offered for sale or otherwise marketed.
  4. The described equipment is being imported in limited quantities for demonstration at industry trade shows and will not be offered for sale or otherwise marketed.
  5. The described equipment is being imported solely for export. It will not be offered for sale or otherwise marketed in the U.S.
    • The described equipment is a non-U.S. standard cellular phone that can only function outside of the U.S.
  6. The described equipment is being imported for use exclusively by the U.S. Government.
  7. Three or fewer radio receivers, computers, or other unintentional radiators as defined in Part 15 of the FCC Rules, are being imported for an individual’s personal use and are not intended for sale.
  8. The described equipment is being imported for repair and will not be offered for sale or otherwise marketed.

Note 1: 47 CFR 2.1202(a) excludes some items from the importation process; however, this does not exclude these items from the equipment authorization process. Exclusion for equipment authorization is defined in 15.103. If the harmonization schedule identifies the goods as “FCC declaration may be needed” (FC3), the importer has the option to decline the declaration. If the harmonization schedule identifies the goods as “FCC declaration required” (FC4), the importer must complete the declaration.

The items excluded from the importation declaration process are: cameras, musical greeting cards, quartz watches and clocks, modules of quartz watches and clocks, hand-held calculators and electronic games, and other similar unintentional radiators which use low level battery power and which do not contain provisions for operation while connected to AC power lines.

Web Access:

Direct links to rules cited in this publication:

  • : Radio frequency (RF) device defined
  • : Radio frequency (RF) device defined and Marketing of radio frequency devices prior to equipment authorization.
  • Importation of Devices Capable of Causing Harmful Interference ()
  • : Purpose Importation of Devices Capable Of Causing Harmful Interference
  • : Exclusions
  • : General requirements for entry into the USA
  • : Import Conditions
  • : Filling of required declaration
  • : Examination of imported equipment
  • : Definitions
  • : Unintentional Radiators
  • : Exempted devices - devices that are exempt from Part 15 specific technical standards
  • Form 740

Harmonization Code 740 Schedule: 97198 D01 HTS Declaration Form 740 v01


Standards Updates

EU: NEW CENELEC STANDARDS RECENTLY RELEASED

This is a shortened list of the CENELEC standards published during the past month:

  • - (8/26/2011) - Sound system equipment - Part 16: Objective rating of speech intelligibility by speech transmission index
  • - (8/26/2011) - Secondary cells and batteries containing alkaline or other non-acid electrolytes - Secondary lithium cells and batteries for portable applications
  • - (8/26/2011) - Electric toys - Safety
  • - (8/26/2011) - Terrestrial digital multimedia broadcasting (T-DMB) receivers - Part 2: Interactive data services using BIFS
  • - (8/26/2011) - Radio data system (RDS) - Receiver products and characteristics - Methods of measurement
  • - (9/16/2011) - Electrical apparatus for the detection and measurement of toxic and combustible gases in car parks and tunnels - Part 1: General performance requirements and test methods for the detection and measurement of carbon monoxide and nitrogen oxides
  • - (9/16/2011) - Lightning protection system components (LPSC) - Part 6: Requirements for lightning strike counters (LSC)
  • - (9/2/2011) - Lamp caps and holders together with gauges for the control of interchangeability and safety - Part 1: Lamp caps
  • - (9/2/2011) - Lamp caps and holders together with gauges for the control of interchangeability and safety - Part 1: Lamp caps
  • - (9/2/2011) - Radio-frequency connectors - Part 35: Sectional specification for 2,92 series RF connectors
  • - (9/2/2011) - Liquid crystal display devices - Part 6-3: Measuring methods for liquid crystal display modules - Motion artifact measurement of active matrix liquid crystal display modules
  • - (9/2/2011) - Communication networks and systems for power utility automation - Part 8-1: Specific communication service mapping (SCSM) - Mappings to MMS (ISO 9506-1 and ISO 9506-2) and to ISO/IEC 8802-3
  • - (9/2/2011) - Battery charge controllers for photovoltaic systems - Performance and functioning
  • - (9/9/2011) - Semiconductor devices - Mechanical and climatic test methods - Part 7: Internal moisture content measurement and the analysis of other residual gases

See CENELEC for additional information.

EU: NEW IEC STANDARDS RECENTLY RELEASED

This is a shortened list of the new IEC standards published during the past month:

  • - (8/26/2011) - Amendment 14 - Lamp caps and holders together with gauges for the control of interchangeability and safety - Part 4: Guidelines and general information
  • - (9/13/2011) - Amendment 2 - Household and similar electrical appliances - Safety - Part 2-16: Particular requirements for food waste disposers
  • - (8/30/2011) - Amendment 2 - Household and similar electrical appliances - Safety - Part 2-45: Particular requirements for portable heating tools and similar appliances
  • - (9/13/2011) - Amendment 2 - Household and similar electrical appliances - Safety - Part 2-51: Particular requirements for stationary circulation pumps for heating and service water installations
  • - (9/13/2011) - Corrigendum 1 - Uninterruptible power systems (UPS) - Part 3: Method of specifying the performance and test requirements
  • - (9/13/2011) - Electromagnetic compatibility (EMC) - Part 3-15: Limits - Assessment of low frequency electromagnetic immunity and emission requirements for dispersed generation systems in LV network
  • - (9/7/2011) - Environmental testing - Part 2-83: Tests - Test Tf: Solderability testing of electronic components for surface mounting devices (SMD) by the wetting balance method using solder paste
  • - (8/25/2011) - Fire hazard testing - Part 6-2: Smoke obscuration - Summary and relevance of test methods
  • - (8/30/2011) - Fire hazard testing - Part 7-2: Toxicity of fire effluent - Summary and relevance of test methods
  • - (9/13/2011) - Household and similar electrical appliances - Safety - Part 2-95: Particular requirements for drives for vertically moving garage doors for residential use
  • - (8/26/2011) - Information technology -- Radio frequency identification (RFID) for item management -- Application protocol: encoding and processing rules for sensors and batteries
  • - (8/25/2011) - Mechanical structures for electronic equipment - Tests for IEC 60917 and 60297 - Part 2: Seismic tests for cabinets and racks
  • - (8/31/2011) - Nuclear power plants - Instrumentation and control important to safety - Electrical equipment condition monitoring methods - Part 1: General
  • - (8/31/2011) - Nuclear power plants - Instrumentation and control important to safety - Electrical equipment condition monitoring methods - Part 2: Indenter modulus
  • - (8/25/2011) - Nuclear power plants - Instrumentation and control important to safety - General requirements for systems
  • - (9/13/2011) - Semiconductor devices - Micro-electromechanical devices - Part 12: Bending fatigue testing method of thin film materials using resonant vibration of MEMS structures

See for additional information.

EU: NEW ETSI STANDARDS RECENTLY RELEASED

This is a shortened list of the new ETSI standards published during the past month:

  • - (August 2011) - Universal Mobile Telecommunications System (UMTS); Terminal conformance specification; Radio transmission and reception (TDD) (3GPP TS 34.122 version 9.5.0 Release 9)
  • - (August 2011) - PowerLine Telecommunications (PLT); MIMO PLT; Part 2: Measurement Methods and Statistical Results of MIMO PLT EMI
  • - (September 2011) - Ground-based VHF hand-held, mobile and fixed radio transmitters, receivers and transceivers for the VHF aeronautical mobile service using amplitude modulation; Part 2: Harmonized EN covering essential requirements of article 3.2 of the R&TTE Directive
  • - (September 2011) - LTE; Evolved Universal Terrestrial Radio Access (E-UTRA); User Equipment (UE) conformance specification; Radio transmission and reception; Part 1: Conformance testing (3GPP TS 36.521-1 version 9.5.0 Release 9)
  • - (September 2011) - Emergency Communications (EMTEL); Basis of requirements for communication of individuals with authorities/organizations in case of distress (Emergency call handling)
  • - (September 2011) - Digital Video Broadcasting (DVB); System Specifications for Satellite services to Handheld devices (SH) below 3 GHz
  • - (September 2011) - Electromagnetic compatibility and Radio spectrum Matters (ERM); System Reference document (SRdoc): Spectrum Requirements for Short Range Device, Metropolitan Mesh Machine Networks (M3N) and Smart Metering (SM) applications
  • - (September 2011) - IMT cellular networks; Harmonized EN covering the essential requirements of article 3.2 of the R&TTE Directive; Part 4: CDMA Multi-Carrier (cdma2000) User Equipment (UE)
  • - (September 2011) - IMT cellular networks; Harmonized EN covering the essential requirements of article 3.2 of the R&TTE Directive; Part 5: CDMA Multi-Carrier (cdma2000) Base Stations (BS)
  • - (September 2011) - IMT cellular networks; Harmonized EN covering the essential requirements of article 3.2 of the R&TTE Directive; Part 19: OFDMA TDD WMAN (Mobile WiMAX) TDD User Equipment (UE)
  • - (September 2011) - IMT cellular networks; Harmonized EN covering the essential requirements of article 3.2 of the R&TTE Directive; Part 20: OFDMA TDD WMAN (Mobile WiMAX) TDD Base Stations (BS)
  • - (September 2011) - IMT cellular networks; Harmonized EN covering the essential requirements of article 3.2 of the R&TTE Directive; Part 21: OFDMA TDD WMAN (Mobile WiMAX) FDD User Equipment (UE)
  • - (September 2011) - IMT cellular networks; Harmonized EN covering the essential requirements of article 3.2 of the R&TTE Directive; Part 22: OFDMA TDD WMAN (Mobile WiMAX) FDD Base Stations (BS)

See ETSI website for additional information.

FCC – September Meeting Agenda

FCC Chairman Julius Genachowski announced the following tentative agenda for the next open meeting scheduled Thursday, September 22, 2011:

  • Framework for Next Generation 911 Deployment, Notice of Proposed Rulemaking. A Notice of Proposed Rulemaking to accelerate the development and deployment of Next Generation 911 (NG911) technology to improve public safety by enabling the public to send text, photos, videos, and data communications to 911 Public Safety Answering Points (PSAPs) and enhancing the information available to PSAPs and first responders for assessing and responding to emergencies.
  • Deployable Aerial Communications Architecture White Paper. The Public Safety and Homeland Security Bureau will present a white paper on the use of deployable aerial communications architecture to facilitate the ability of first responders to communicate with each other and consumers to reach first responders in the wake of natural and manmade disasters, even in situations where there is severe damage to terrestrial communications infrastructure. The report will make recommendations regarding next steps the FCC should consider to promote the development and use of deployable aerial communications architecture.

Please find the reference link .

FCC – SAR Listing on Grants

On August 17, 2011, The FCC published a draft KDB entitled “SAR Listings on Equipment Authorization Grants.”   The draft KDB provides guidance for Telecommunication Certification Bodies (TCBs) for uniform listings of specific absorption rate (SAR) numbers on grants of equipment authorization.   Comments on the draft must be posted by September 16, 2011.  .

Brazil – ANATEL Updates to LTE and HSPA+

On September 9th, 2011,  ANATEL added LTE test requirements to:

  • Category I products: cellphones and terminal access stations (ETAs)
  • Category II products: radio base station transceivers

As a result, these products now must be tested locally as part of the ANATEL Approval process, in most cases.

Additionally, ANATEL added HSPA+ test requirements to Category I products - cellphones and terminal access stations (ETAs).  As a result, these products now must be tested locally as part of the ANATEL Approval, in most cases.

The ANATEL test requirements for LTE are as follows:

  • For Category I products, cellphones and terminal access stations (ETAs), the ANATEL test requirements follow 3GPP TS 36.521-1 V9.5.0 (2011-06) 3rd Generation Partnership Project; Technical Specification Group Radio Access Network; Evolved Universal Terrestrial Radio Access (E-UTRA); User Equipment (UE) conformance specification Radio transmission and reception Part 1: Conformance Testing; (Release 9).
  • For Category II products, radio base station transceivers, the ANATEL test requirements follow 3GPP TS 36.141 V9.8.0 (2011-06) 3rd Generation Partnership Project; Technical Specification Group Radio Access Network; Evolved Universal Terrestrial Radio Access (EUTRA); Base Station (BS) conformance testing (Release 9).

斗地主达人The ANATEL test requirements for HSPA+ Test Requirements  for Category I products, cellphones and terminal access stations (ETAs), ETSI TS 134 121-1 V9.4.0 (2011-03) Universal Mobile Telecommunications System (UMTS); User Equipment (UE) conformance specification; Radio transmission and reception (FDD); Part 1: Conformance specification (3GPP TS 34.121-1 version 9.4.0 Release 9).

EU – New List of Harmonized Standards for LVD

On September 1, 2011, the R&TTE Compliance Association published an updated list of standards harmonized for the purposes of the LVD Directive.  

EU – R&TTE CA Published Guidance on Acoustic Safety

On September 1, 2011, the R&TTE Compliance Association published TGN 14 Rev 2 - Guidance on Acoustic Safety。  The purpose of the document is to provide guidance to Notified Bodies that are requested to give an opinion on the acoustic safety of telephone handsets and headsets (wired, cordless or mobile) or other R&TTE devices that can connect to a handset or headset。  The link to TGN 14 Rev 2 can be found 。

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