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MultiPoint Newsletter - February 2012 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 Confidentiality Requests

Question: We manufacture Ultra Wide Band (UWB) sensor devices and have proprietary information that we would like withheld from the public when we apply for FCC certification. What is the procedure to make such a request?

Answer: The FCC has published four Knowledge Database (KDB) documents on equipment authorization confidentiality which include specific information about short-term and permanent confidentiality, and we encourage you to review them:

  1. 726920 D01 Exhibit Confidentiality Table v01
  2. 726920 D02 Confidentiality Procedures Detail v02
  3. 726920 D03 Confidentiality FCC Submitted Apps v02
  4. 726920 D04 Confidentiality TCB Submitted Apps v02

The following summarizes confidentiality for pending and granted applications:

  1. Confidentiality for Pending Application Exhibits
    • When you submit an application to the FCC or your Telecommunications Certification Body (TCB), all of the information pertaining to it while it is pending and under review is held confidential. During the application review process, only the applicant, the applicant’s agent (when applicable), the FCC, or the TCB, have access to the information, and the information can only be accessed using the FCC ID and the randomly generated FCC 731 Confirmation Number assigned when the 731 Form and application were submitted for review.
    • When the equipment application is approved and the FCC grant of authorization is issued, all exhibits will be publicly available via the FCC web site, unless confidentiality is requested for the eligible exhibit types in the manner described in the KDB documents.
    • If you filed your application with the FCC and requested a Deferral of the Grant of Authorization (see Records not routinely available for public inspection, ), your pending application information will not be made available to the public until your requested deferred grant date.
  2. Confidentiality for Granted Application Exhibits
    • When you apply for equipment authorization, there are two types of confidentiality, short-term and permanent, that you can request for certain exhibits within the application using 47CFR §0.457(d), which protects trade secrets and , which requests that materials or information submitted to the FCC be withheld from public inspection. Short-term confidentiality allows you to prepare the marketing of your device without disclosing your proprietary information to the public prior to the actual sale date; permanent confidentiality ensures that proprietary information is never disclosed. The above link, 726920 D01 Exhibit Confidentiality Table v01, contains a confidential exhibit table that describes document requests that are accepted by the FCC for both permanent and short-term confidentiality.
    • If your request for confidentiality is denied, exhibits are immediately viewable on the Office of Engineering and Technology (OET) equipment authorization web site as soon as the FCC grant is issued.

If you file your application directly with the FCC, only one confidentiality fee is assessed, regardless of the number of exhibits to be held confidential, or the length of time, i.e. short-term or permanent. If you file your application with a TCB and request confidentiality, there is no fee assessed.

Electric Vehicle Battery Chargers

Question: We are a manufacturer of electric vehicle battery chargers; we are currently designing a charger for an electric vehicle battery to be used while the vehicle is parked connected to the electric power utility in a residential or commercial space. What FCC rules and regulations would apply to our product?

Answer: Electric vehicle chargers that charge their batteries while parked in a residential or commercial space connected to the electric power utility are subject to conducted and radiated emissions testing.

斗地主达人When a vehicle is moving, the FCC considers the potential for interference to be low, however when a vehicle is stationary, parked in a residential garage or driveway and connected to the electric power utility, the FCC deems the potential for conducted or radiated emissions to be high。 Thus, your electric battery charger (switching power supply), including the associated electronics (digital electronics) of the electric vehicle’s onboard charger, must adhere to the FCC’s equipment authorization procedure under Class B limits or verification procedure under Class A limits (industrial) as an unintentional radiator。

Though states in part: “A digital device utilized exclusively in any transportation vehicle including motor vehicles and aircraft”, and suggests perhaps that electric vehicle chargers are exempt from the FCC’s rules and regulations, they are not. In this case, the exemption applies to on-board digital devices that operate only when the vehicle is mobile, that is, moving on a road or highway.

It should be noted that while 47CFR§15。103(a) provides exemption for some digital devices used in vehicles and aircraft, the exemption is only from the specific technical rule part that applies to the device。 , the General condition for operation, and , Inspection by the Commission, still applies for such exempted devices, and as such, the operator of the exempted device would be required to stop operation of the device if it were found that the device causes harmful interference。

Spread Spectrum Clocks

Question: We recently added a Spread Spectrum Clock (SSC) to one of our digital designs in order to reduce the amplitude of our fundamental clock and its harmonics. However, we see very little difference between the non-SSC mode and the SSC mode during radiated emissions testing. Can you give us your opinion?

Answer: If you configured the SSC properly, it should produce lower spectral peaks of the fundamental frequency and harmonics than the spectral peaks of the fundamental frequency and harmonics in the non-SSC mode when measured using a peak detector. The reduction in the level is dependent on the manufacturer of the SSC, the modulating waveform profile, the modulation rate used to modulate the fundamental clock frequency in the SSC mode, and the spreading rate style used (down-spreading, center-spreading or up-spreading).

When evaluating and configuring SSC in a design, it is important that you properly tailor the following timing parameters that are critical for your design to function properly and to see a reduction of your fundamental clock and its harmonics in the SSC mode:

  1. Peak-to Peak jitter: The total percentage of spreading divided by the fundamental frequency.
  2. Cycle-to cycle jitter: The variation in time per cycle, dependent on the waveform profile and modulated frequency.
  3. Set-up and hold times: Care must be taken when configuring the SSC so that its configuration can support the digital design. Designs that require tighter tolerances in their set and hold time margins typically tend to use down-spreading SSC.

If you’re not seeing the expected results, we suggest that you contact the SSC manufacturer and seek guidance for proper SSC parameters including application notes. In the meantime, the link here, Spread Spectrum Clock (SSC) on Commercially Available Off-The-Shelf (COTS) Products & MIL-STD-461F Testing, should provide further guidance on the topic of SSC.

FCC Requirement for Antenna Calibration

Question: We recently had discussions with our test laboratory about the FCC requirement for antenna calibration. What is the FCC’s requirement for antenna calibration?

Answer: The FCC accepts antennas calibrated in accordance with ANSI C63.5-2006, American National Standard Electromagnetic Compatibility-Radiated Emission Measurements in Electromagnetic Interference (EMI) Control-Calibration of Antennas (9 kHz to 40 GHz). All test laboratories performing radiated emission measurements and Normalized Site Attenuation (NSA) measurements required by the FCC’s rules and regulations should use this standard, notwithstanding the FCC’s cross-references to multiple standards in its rules, regulations and public policy documents, namely:

  • - General compliance procedure
  • - Site Attenuation data to be taken pursuant to procedures in ANSI C63.4-2001
  • DA 09-2478 - Public Notice Pending future rulemaking to update its rules, the Commission stated it will accept test data for radiated emissions and NSA performed using ANSI C63.4-2009

Please click the link, 822428 D01 Antenna Calibration Procedure v01 for further information on the use of ANSI C63.5-2006 for calibration of antennas used to perform radiated emission measurements and NSA.

Standards Updates


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

  • - (1/20/2012) - Electronics assembly technology - Part 3: Selection guidance of environmental and endurance test methods for solder joints
  • - (02/03/2012) - Connectors for electronic equipment - Tests and measurements - Part 7-2: Impact tests (free connectors) - Test 7b: Mechanical strength impact
  • - (02/03/2012) - Luminaires - Part 2-2: Particular requirements - Recessed luminaires
  • - (02/03/2012) - Industrial electroheating equipment - Test methods for direct arc furnaces
  • - (02/03/2012) - Safety of transformers, reactors, power supply units and combinations thereof - Part 2-15: Particular requirements and tests for isolating transformers for the supply of medical locations
  • - (02/10/2012) - Photovoltaic (PV) module safety qualification - Part 1: Requirements for construction
  • - (02/10/2012) - Mechanical structures for electronic equipment - Outdoor enclosures - Part 1: Design guidelines
  • - (02/10/2012) - Radiation protection instrumentation - Passive integrating dosimetry systems for environmental and personal monitoring - Part 1: General characteristics and performance requirements
  • - (02/10/2012) - Fibre optic active components and devices - Reliability standards - Part 3: Laser modules used for telecommunication
  • - (02/17/2012) - Medical devices - Quality management systems - Requirements for regulatory purposes
  • - (02/17/2012) - Connectors for electronic equipment - Tests and measurements - Part 9-2: Endurance tests - Test 9b: Electrical load and temperature
  • - (02/17/2012) - Non-cellulosic papers for electrical purposes - Part 1: Definitions and general requirements

See CENELEC for additional information.


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

  • - (January 2012) - Satellite Earth Stations and Systems (SES); Harmonized EN for Land Mobile Earth Stations (LMES) operating in the 1,5 GHz and 1,6 GHz bands providing voice and/or data communications covering essential requirements of article 3.2 of the R&TTE directive
  • - (January 2012) - Electromagnetic compatibility and Radio spectrum Matters (ERM); Digital Mobile Radio (DMR) Systems; Part 4: DMR trunking protocol
  • - (January 2012) - Digital cellular telecommunications system (Phase 2+); Universal Mobile Telecommunications System (UMTS); LTE; E-UTRA, UTRA and GSM/EDGE; Multi-Standard Radio (MSR) Base Station (BS) Electromagnetic Compatibility (EMC) (3GPP TS 37.113 version 10.4.0 Release 10)
  • - (February 2012) - roadband Wireless Access Systems (BWA) in the 3 400 MHz to 3 800 MHz frequency band; Base Stations; Harmonized EN covering the essential requirements of article 3.2 of the R&TTE Directive

See ETSI website for additional information.


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

  • - (01/27/2012) - Corrigendum 1 - Explosive atmospheres - Part 11: Equipment protection by intrinsic safety "i"
  • - (01/30/2012) - Electromagnetic compatibility of multimedia equipment - Emission requirements
  • - (01/18/2012) - Electrostatics - Part 4-4: Standard test methods for specific applications - Electrostatic classification of flexible intermediate bulk containers (FIBC)
  • - (02/16/2012) - Fuel cell technologies - Part 3-100: Stationary fuel cell power systems - Safety
  • - (01/30/2012) - Global maritime distress and safety system (GMDSS) - Part 6: Narrowband direct-printing telegraph equipment for the reception of navigational and meteorological warnings and urgent information to ships (NAVTEX)
  • - (01/30/2012) - Household and similar electrical appliances - Safety - Part 2-44: Particular requirements for ironers
  • - (01/30/2012) - Household and similar electrical appliances - Safety - Part 2-45: Particular requirements for portable heating tools and similar appliances
  • - (01/30/2012) - Household and similar electrical appliances - Safety - Part 2-51: Particular requirements for stationary circulation pumps for heating and service water installations
  • - (01/18/2012) - Household and similar electrical appliances - Safety - Part 2-66: Particular requirements for water-bed heaters
  • - (01/30/2012) - Household and similar electrical appliances - Safety - Part 2-81: Particular requirements for foot warmers and heating mats
  • - (01/30/2012) - Household ans similar electrical appliances - Safety - Part 2-16: Particular requirements for food waste disposers
  • - (02/10/2012) - Incandescent lamps - Safety specifications - Part 1: Tungsten filament lamps for domestic and similar general lighting purposes
  • - (01/19/2012) - Information technology -- Radio frequency identification device conformance test methods -- Part 2: Test methods for air interface communications below 135 kHz
  • - (02/09/2012) - Information technology -- Smart transducer interface for sensors and actuators -- Part 7: Transducer to radio frequency identification (RFID) systems communication protocols and Transducer Electronic Data Sheet (TEDS) formats
  • - (02/16/2012) - Medical electrical equipment - Part 2-47: Particular requirements for the basic safety and essential performance of ambulatory electrocardiographic systems
  • - (02/20/2012) - Medical electrical equipment - Part 2-60: Particular requirements for the basic safety and essential performance of dental equipment

斗地主达人See for additional information.

Canada – New Issues of RSS-111, RSS-182, and RSS-288

On January 13, 2012, Industry Canada release Gazette Notice No. SMSE-001-12 stating the following published standards are immediately in force:

  • Radio Standards Specification 111 (RSS-111), Issue 4:, which sets out the requirements for certification of radio transmitters and receivers in the band 4940-4990 MHz for public safety applications;
  • Radio Standards Specification 182 (RSS-182), Issue 5: , which sets out the requirements for certification of radio transmitters and receivers in the maritime service in the band 156-162.5 MHz; and
  • Radio Standards Specification 288 (RSS-288), Issue 1: , which sets out the requirements for certification of the ship borne radio communication equipment that meets the requirements of the GMDSS.

RSS-111 was updated to clarify the requirements for equipment with multiple transmitters. RSS-182 was updated to provide the new requirements regarding the Automatic Identification System (AIS SART). RSS-288 was renumbered from RSS-188 to reflect the numbering convention for licence-exempt equipment and to include the new requirements from international standards.

Additionally, the Gazette Notice stated that Radio Standards Specification 193 (RSS-193), Issue 1: Multipoint and Point-to-Point Communication Systems (MCS) in the Fixed Service Operating in the2150-2160 MHz, 2500-2596 MHz and 2686-2690 MHz Bands was being withdrawn and is no longer in force effective immediately. RSS-193 is being rescinded because MCS equipment is no longer allowed to operate in the frequency bands 2150-2160 MHz, 2500-2596 MHz and 2686-2690 MHz. It should be noted that the band 2150-2155 MHz has been assigned to the Advanced Wireless Services (AWS) and is covered under . Also, the band 2155-2160 MHz is being held in reserve. The band 2500-2690 MHz has been assigned to the Broadband Radio Service (BRS) and is covered under .  

IEEE – Free Access to Select IEEE C95 Standards

On February 15, 2012, the Institute of Electrical and Electronics Engineers (IEEE) announced that the IEEE Standards Association (IEEE-SA) has made some of its IEEE C95 safety standards for human exposure to electromagnetic fields available to the public, free of charge. The standards can be downloaded through the IEEE Get Program, made possible by funding from the U.S. Department of Defense, which sponsors their publication on the IEEE Get Program web site.

For more information about the IEEE C95 standards or to download the documents, visit the .

EU – New Website For Access to European Standards

On January 18, 2012, the European Committee for Standardization (CEN) and the European Committee for Electrotechnical Standardization (CENELEC) launched a new website – 。  This new joint website complements the existing websites of CEN and CENELEC by providing easy access to general information about European Standards。 It is intended to serve as a starting point for anyone who wants to learn about or participate in the European standardization system。  

Australia – ACMA to Replace C-Tick and A-Tick Mark

The Australian Communications and Media Authority (ACMA) has come to an agreement whereby the C-Tick (ITE & radio products) and A-Tick (telephony products) marks will be replaced with a single Regulatory Compliance Mark (RCM), effective July 1, 2012.  The RCM will cover telecommunications, radio communications, electromagnetic compatibility (EMC), and electromagnetic energy (EME).  The C-Tick and A-Tick will be phased out by 2015.

India –2012 SAR Requirements for Mobile Phones

On January 25, 2012, India’s Ministry of Communications and Department of Telecommunications published Memorandum No。 18-10/2OO8-IP stating that the Indian Government adopted International Commission on Non-Ionizing Radiation Protection (ICNIRP) Guidelines for mobile phones。    Additionally, India’s Inter-Ministerial Committee has additional concerns regarding the effect of EMF radiation from mobile phones and base stations。  Based on these concerns, India has adopted the following requirements for mobile phones or handsets:

  • SAR levels are limited to 1.6 Watt/kg, averaged over a mass of 1 gram of human tissue.
  • SAR levels must be listed on the device.
  • Compliance with relevant BIS standards is required.  Must be “hands free” devices.
  • SAR levels must be available to the consumer at the point of sale.  Additionally, SAR levels must be listed on the manufacturer’s website and also in the user manual.
  • Indian manufacturers must provide a Self Declaration with the SAR level.
  • Foreign manufacturers must provide a Self Declaration with the SAR level and this information must be verified by the appropriate authority to ensure strict compliance.
  • User’s manuals must contain some specific safety precautions regarding the use of the device.

The requirements as listed above are effective September 1, 2012.

Korea – New SAR Requirement

Beginning January 1, 2013, Korea’s Korea Communications Commission (KCC) will expand its existing SAR requirements (for mobile phones only) to include all radio equipment that is used within 20 cm from the human body。 This move harmonizes the Korean SAR requirements with FCC and other international standard requirements。 Low powered radio devices (below 20mW – such as WLAN, Bluetooth, Access Points, and 2。4 GHz devices) are exempt from this new requirement。

Currently, KCC’s draft SAR standard follows that of the FCC; however there is some possibility the new Korean standard will be modified to harmonize with the IEEE SAR standard rather than that of the FCC。

Dominican Republic – Acceptance of FCC Approved Devices

The Dominican Republic’s Institute of Telecommunications (INDOTEL) recently announced that Type Approval is not required for certain categories of products with existing FCC identifiers。  Products in the following categories and approved by the FCC are allowed to be imported and commercialized in the Dominican Republic without additional Type Approval requirements:

  • Products with Bluetooth and WLAN technologies
  • SRD (Short Range Devices) operating in the frequency bands 433.95MHz, 313MHz, 315MHz, 125kHz, 132kHz and 134kHz

However, it should be noted that products with RFID 13.56MHz, RFID 800/900MHz and cell phone technologies will still require INDOTEL license and Type Approval.  

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