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MultiPoint Newsletter - March 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.

CE RLAN Band-Edge Measurement Procedure

Question: We manufacture Radio Local Area Network (RLAN) devices and would like to know which ETSI standard includes the procedure for measuring spurious emissions of 5 GHz band radios in restricted bands, similar to the FCC Marker-Delta Method for band-edge measurement procedure in the American National Standards Institute (ANSI) C63®.10-2009 “Standard for Testing Unlicensed Wireless Devices.”

Answer: The European Telecommunications Standards Institute (ETSI) standard EN 301 893 V1.5.1 is the current harmonized standard with a 5 GHz equipment-related scope. However, there is no specific clause or sub-clause titled “Marker-Delta Method for band-edge measurements”, “band-edge measurements” or “band-edge requirement”, and in fact band-edge measurement is fairly well hidden within the standard; the term appears only once. Following Figure 1 of the Transmit spectral power mask on page 14 is a note on page 15 that states:

“NOTE: The mask is only applicable within the band of operation. Beyond the band edges, the requirements of clause 4.5.1 apply.

Clause 4.5.1, “Transmitter unwanted emissions outside the 5 GHz RLAN bands”, defines the band-edge requirements. The limits are shown on page 14, “Table 3: Transmitter unwanted emission limits outside the 5 GHz RLAN bands”, and include the limits at or for the band-edges of the 5 GHz band(s) with defined Resolution Bandwidth (RBW) settings.

Clause, “Conformance”, refers to the test measurement method defined in clause 5.3.5, “Transmitter unwanted emissions outside the 5 GHz RLAN bands”.

Essentially, in accordance with EN 301 893 V1.5.1, band-edge measurements are radiated spurious emission measurements that include the band-edges of the 5 GHz bands. Though it cannot be referred to as the “Marker-Delta Method”, measurements in accordance with clause 5.3.5 of EN 301 893 V1.5.1, are band-edge measurements.

Specifically, the test measurement methods in clause 5.3.5 include the following:

  1. Test conditions
  2. Detailed step-by-step instructions on how to carry out the measurement (including spectrum analyzer settings)
  3. Instructions on how to perform a pre-scan and how to interpret the test measurement results

It should be noted here that V1.6.1 of EN 301 893 is on ETSI’s standards website with a targeted Official Journal (OJ) citation date of February 7th, 2012 in accordance with the Program Report Schedule of EN 301 893 V1.6.1, however the European Commission (EC) has not yet published V1.6.1.

A final draft of 斗地主达人V1.7.0 of EN 301 893 is also on ETSI’s standards website. Please note that both V1.6.1 and draft V1.7.0 are non-harmonized standards, and therefore may require notified body opinion if they are used for testing.

In reviewing V1.6.1 and draft V1.7.0, we noticed that the Power Density measurement procedure in V1.6.1 clause was split into two clauses in V1.7.0, clause – Option 1 and clause – Option 2.

The specific measurement procedures are defined as follows:

  • Clause - Option 1: For equipment with continuous transmission capability or for equipment operating (or with the capability to operate) with a constant duty cycle (e.g. Frame Based equipment).
  • Clause - Option 2: For equipment without continuous transmission capability and without the capability to transmit with a constant duty cycle.

Clause - Option 2 measurement procedure now includes setting the start and stop frequency of the spectrum analyzer to the lower and upper band-edge of the applicable sub-band. Technically, this can be viewed as a band-edge measurement, though it is not the primary purpose of this measurement. Since the measurement is performed from within the channel and not outside of the channel, it is very possible that non-compliances could be detected within the channels at the band-edges using this measurement method. Going forward, it appears that the newer versions of EN 301 893 will include defined band-edge measurement procedures when cited in the OJ.

IC WLAN Alternative

Question: We manufacture 2.4 GHz WLAN Digital Transmission Systems (DTS) products for the North American market. We were recently informed that we can only use measurement methods specified in Industry Canada (IC) standard RSS-210 Annex 8 and Annex 9 to test our products. However, we are wondering whether we can use the FCC’s WLAN Knowledge Database (KDB) guidance measurement methods for both the FCC and IC.

Answer: Yes, you can now use the FCC’s WLAN KDB guidance measurement methods when testing your WLAN products for both FCC and IC. IC recently issued a policy allowing the use of measurement methods in the FCC’s KDB 558074 D01 DTS Meas Guidance v01 “DTS Measurement for Digital Transmission Systems (DTS) operating under 47CFR §15.247” as an acceptable alternative measurement method when determining compliance to the applicable requirements set out in its current version of standard RSS-210 Annex 8. Furthermore, IC is also allowing the use of the measurement methods in FCC’s KDB 789033 D01 UNII General Test Procedures v01r01 for U-NII devices in as an alternative method for determining compliance to the applicable requirements stated in the current version of standard RSS-210 Annex 9.

FCC’s Policy On Safety Critical Use Of 47CFR§15.231 Transmitter

Question: We are a manufacturer of a 47CFR§15.231 wireless transmitter designed to determine the pressure and temperature within highly pressurized tanks used in a hot industrial environment. The pressurized tanks are used in a mechanical configuration that provides pressurized air to other equipment. Maintaining the health and safety of the pressurized tanks is achieved through polling the pressurized air and its temperature inside the tank. At predefined regular intervals, the transmitter within each pressurized tank reports the conditions. If the increase or decrease in pressurized air or temperature varies too greatly from a predetermined safety value, the transmitter rate increases to 15 minutes, which will cause the transmitter to exceed the FCC’s 2 second per hour limit. Our questions are as follows:

  1. Would the FCC consider the use of our wireless transmitter “safety critical”?
  2. Is our polling as explained above in line with the FCC’s definition of polling?
  3. Is it acceptable for our transmit rate to increase by 15 minutes when we experience what may constitute an emergency (please note that the transmit rate reduces once the emergency has passed)?

Answer: Based upon our understanding of the FCC rules and our experience, we believe the following:

  1. The FCC would consider the use of your wireless transmitter to be “safety critical”, providing a safety of life function, and would allow it, if the transmitter follows the rule : Intentional radiators, which are employed for radio control purposes during emergencies involving fire, security, and safety of life, when activated to signal an alarm, may operate during the pendency of the alarm condition.
  2. The polling you describe, sending tank pressure and temperature data, does not meet the FCC’s definition of polling. For the FCC, polling is only valid for the radio system integrity check as described in the rule 47CFR§15.231(a)(3): Periodic transmissions at regular predetermined intervals are not permitted. However, polling or supervision transmissions, including data, to determine system integrity of transmitters used in security or safety applications are allowed if the total duration of transmissions does not exceed more than two seconds per hour for each transmitter. There is no limit on the number of individual transmissions, provided the total transmission time does not exceed two seconds per hour.
  3. Since your polling does not meet the intent of 47CFR§15.231(a)(3), the FCC would not accept your increase in transmit rate.

Please note that the FCC is the final arbiter of its rules, regulations and policies. For a definitive response we encourage you to send your question to the FCC at labhelp@fcc.gov.

FCC’s Policy On Notebook Computers Sold As Components

Question: We manufacture integrated notebook motherboards and notebook enclosures. We typically separately test the notebook’s motherboards, power supply and enclosure, and then authorize each separately with either a Declaration of Conformity (DoC) or a Grant of Certification under Section 47CFR§15.101(c)(3). Has the FCC changed its rules, regulations or policies allowing separately authorized notebook computers to be sold as components?

Answer: does not specifically address notebook computers; the FCC has not updated its rules and regulations to include “notebook computers”, neither has it altered its policy and KDB guideline published October 1, 2008 allowing notebook computers to be authorized separately and sold separately as components “Test procedures for Notebook Computers Based on Assembly Using Separately Authorized Motherboard, Enclosures, Power Supplies and Other Devices”, 657217 D01 Notebook CPU Brds and Pwr Suply v01r01斗地主达人. This guideline provides additional clarification of test procedures specifically for notebook motherboards, power supplies and enclosures.

Specifically, to reiterate the FCC’s policy on notebook computers, the following is true:

  1. A notebook computer enclosure, unlike a desktop computer enclosure, contains active circuitry typically integrated with a video display unit, keyboard, touchpad and other possible components that must also be separately treated as a peripheral device, and authorized as such. Separately authorizing all the individual devices, including the notebook computer enclosure, under the Declaration of Conformity or Certification procedure, allows a party to market and sell a complete notebook computer, assembled without further testing, under the provisions of 47CFR§15.102.
  2. Manufacturers or responsible parties marketing separately authorized parts must document, for the party marketing an assembled notebook computer, the complete installation procedures that must be followed to ensure compliance.

The marketing individual, or the seller, of an assembled notebook computer must ensure the following:

  • Each device used in the system, including the notebook enclosure combination, has been authorized under the Declaration of Conformity or Certification procedure;
  • The original label and identification on each piece of equipment remain unchanged;
  • Each responsible party's instructions to ensure compliance (including, if necessary, the use of shielded cables or other accessories or modifications) are followed when the system is assembled;
  • The final notebook computer is authorized under a DoC in accordance with ; contains a compliance information statement as described in ; conforms with the labeling requirements in ("Assembled from tested components Complete system not tested"); and conforms with the required information to end users described in , and .

Standards Updates


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

  • - (2/17/2012) - Connectors for electronic equipment - Tests and measurements - Part 9-2: Endurance tests - Test 9b: Electrical load and temperature
  • - (2/17/2012) - Medical devices - Quality management systems - Requirements for regulatory purposes
  • - (2/23/2012) - Household and similar electrical appliances - Safety - Part 2-40: Particular requirements for electrical heat pumps, air-conditioners and dehumidifiers
  • - (3/16/2012)Lamp caps and holders together with gauges for the control of interchangeability and safety - Part 1: Lamp caps
  • - (3/16/2012) - Luminaires - Part 2: Particular requirements - Section 18: Luminaires for swimming pools and similar applications
  • - (3/16/2012) - Mechanical structures for electronic equipment - Tests for IEC 60917 and IEC 60297 series - Part 1: Environmental requirements, test set-up and safety aspects for cabinets, racks, subracks and chassis under indoor conditions
  • - (3/16/2012) - Lightning Protection System Components (LPSC) - Part 7: Requirements for earthing enhancing compounds
  • - (3/2/2012) - Cable networks for television signals, sound signals and interactive services - Part 2: Electromagnetic compatibility for equipment
  • - (3/2/2012) - Product standard to demonstrate the compliance of mobile phones with the basic restrictions related to human exposure to electromagnetic fields (300 MHz - 3 GHz)
  • - (3/2/2012) - Household and similar electrical appliances - Safety - Part 2-16: Particular requirements for food waste disposers
  • - (3/2/2012) - Household and similar electrical appliances - Safety - Part 2-44: Particular requirements for ironers
  • - (3/2/2012) -Lamp controlgear - Part 2-2: Particular requirements for d.c. or a.c. supplied electronic step-down convertors for filament lamps
  • - (3/2/2012) - Lamp controlgear - Part 2-7: Particular requirements for battery supplied electronic controlgear for emergency lighting (self-contained)
  • - (3/2/2012) - Adjustable speed electrical power drive systems - Part 3: EMC requirements and specific test methods
  • - (3/7/2012) - Conformity assessment - General criteria for the operation of various types of bodies performing inspection (ISO/IEC/FDIS 17020:2011)
  • - (3/9/2012) - General requirements for Home and Building Electronic Systems (HBES) and Building Automation and Control Systems (BACS) - Part 4-1: General functional safety requirements for products intended to be integrated in Building Electronic Systems (HBES) and Building Automation and Control Systems (BACS)

See CENELEC斗地主达人 for additional information.


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

  • - (February 2012) - Broadband 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
  • - (February 2012) - Electromagnetic compatibility and Radio spectrum Matters (ERM); System Reference document (SRdoc); Medical Body Area Network Systems (MBANSs) in the 1 785 MHz to 2 500 MHz range
  • - (March 2012) - Electromagnetic compatibility and Radio spectrum Matters (ERM); Digital cellular telecommunications system (Phase 2+); Radio access network equipment specification; GSM onboard aircraft; Methodology for showing conformance with operational requirements

See ETSI website for additional information.


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

  • - (2/16/2012) - Fuel cell technologies - Part 3-100: Stationary fuel cell power systems - Safety
  • - (2/20/2012) - Medical electrical equipment - Part 2-60: Particular requirements for the basic safety and essential performance of dental equipment
  • - (2/21/2012) - Household and similar electrical appliances - Safety - Part 2-107: Particular requirements for robotic battery powered electrical lawnmowers
  • - (2/22/2012) - Automation systems in the process industry - Factory acceptance test (FAT), site acceptance test (SAT), and site integration test (SIT)
  • - (2/22/2012) - Connectors for electronic equipment - Tests and measurements - Part 1-100: General - Applicable publications
  • - (2/22/2012) - Household and similar electrical appliances - Safety - Part 2-69: Particular requirements for wet and dry vacuum cleaners, including power brush, for commercial use
  • - (2/24/2012) - Corrigendum 1 - Fire hazard testing - Part 2-13: Glowing/hot-wire based test methods - Glow-wire ignition temperature (GWIT) test method for materials
  • - (2/27/2012) - Conformity assessment -- Requirements for the operation of various types of bodies performing inspection
  • - (2/28/2012) - Household and similar electrical appliances - Safety - Part 2-79: Particular requirements for high pressure cleaners and steam cleaners
  • - (2/29/2012) - Corrigendum 1 - Medical electrical equipment - Part 2-19: Particular requirements for the basic safety and essential performance of infant incubators
  • - (2/29/2012) - Corrigendum 1 - Medical electrical equipment - Part 2-20: Particular requirements for the basic safety and essential performance of infant transport incubators
  • - (3/15/2012) - Household and similar electrical appliances - Safety - Part 2-3: Particular requirements for electric irons
  • - (3/5/2012) - Corrigendum 1 - Electromagnetic compatibility (EMC) - Part 4-15: Testing and measurement techniques - Flickermeter - Functional and design specifications
  • - (3/5/2012) - Corrigendum 1 - Medical electrical equipment - Part 2-33: Particular requirements for the basic safety and essential performance of magnetic resonance equipment for medical diagnosis
  • - (3/5/2012) - Corrigendum 1 - Medical electrical equipment - Part 2-35: Particular requirements for the basic safety and essential performance of heating devices usign blankets, pads or mattresses and intended for heating in medical use
  • - (3/8/2012) - Adjustable speed electrical power drive systems - Part 3: EMC requirements and specific test methods
  • - (3/8/2012) - Amendment 1 - Electromagnetic compatibility (EMC) - Part 4-25: Testing and measurement techniques - HEMP immunity test methods for equipment and systems
  • - (3/8/2012) - Medical electrical equipment - Part 2-16: Particular requirements for basic safety and essential performance of haemodialysis, haemodiafiltration and haemofiltration equipment

See for additional information。

US – California to Regulate Battery Chargers

On January 13, 2012, the California Energy Commission approved a to regulate battery chargers. This standard will require battery chargers to consume less energy while performing the same service.  Dates of compliance with corresponding equipment are as follows:

  • 2/1/2013 – consumer chargers used in products such as cell phones, personal care devices and power tools
  • 1/1/2014 – industrial charger compliance, e.g. forklifts
  • 1/1/2017 - small chargers such as walkie-talkies for emergency personnel, portable bar code scanners, etc

Additional several states in the Northwest are considering similar regulations。 The U。S。 Department of Energy is also working on setting national standards for battery chargers。  This particular mandate is specifically for battery chargers but it is possible that it will be expanded in the near future to include most common everyday household appliances。

EU – Battery Capacity Label required by May 31, 2012

The existing EU Batteries and Accumulators Directive 2006/66/EC斗地主达人 requires manufacturers to display a battery capacity label on their batteries prior to placing on the market.  The original date of compliance for this labeling requirement was September 26, 2009; however that date was moved forward to a fast approaching date –  May 31, 2012.  Producers of rechargeable portable batteries and automotive batteries must display a capacity marking by May 31,2012.  Batteries placed on the market prior to this date do not have to be removed from sale and single use portable batteries are not included within the scope of this requirement.  European regulation number 1103/2010 was published on November 29, 2010 and covers producer requirements, exemptions, standards for measuring capacity, what information should be contained on the label and its minimum size and location.

EU – New List of Harmonised Standards under the Machinery Directive

On February 29, 2012, a new consolidated list of references of harmonised standards under the Machinery Directive 2006/42/EC was published in the Official Journal C 61 of 29.  This list also contains new harmonised standards for agricultural and forestry machinery, for plastic and rubber machines and for all terrain vehicles (ATVs – Quads). These European standards provide solutions for compliance and presumption of conformity with the essential health and safety requirements of the Machinery Directive that they cover.    However, the use of harmonised standards remains voluntary and manufacturers can choose whether or not to follow a harmonised standard to manufacture their products. Manufacturers may thus use other technical solutions providing for an equivalent level of safety. In that case, they must be able to prove that their products are in conformity with the mandatory essential health and safety requirements, taking due account of the state of the art.  

EU – New Consolidated List of Harmonised Standards under the LVD

On February 29, 2012, a new consolidated list of references of harmonised standards, under the low voltage directive 2006/95/EC, was published in the Official Journal C 61。  

South Africa – ICASA Public Consultation on 800 MHz and 2.6 GHz Bands

In late December 2011, the Independent Communications Authority of South Africa (ICASA) initiated a public consultation on the draft Spectrum Assignment Plan for the following frequency ranges: 790 MHz – 862 MHz and 2,500 MHz to 2,690 MHz (2。6 GHz)。   The mail goals of the proposed plan are as follows:

  • Set terms and use conditions for the bands
  • Set applicant qualification criteria
  • Set procedures and timeframe for assignment and licensing
  • Appointment of the bands for International Mobile Telecommunications
  • Detailed frequency channeling arrangements
  • Set licensing approach

ICASA has proposed that the 800 MHz band should be in line with ECC/DEC/(09)03 and 2.6 GHz should be in line with ITU-R Recommendation M.1036-3.  

Saudi Arabia – Ban on 127V Products

Beginning June 1st, 2012, the Saudi Ministry of Commerce & Industry (MoCI) will enforce a ban on all electronic products with an operating voltage of 127V.   All spare parts for products with an operating voltage of 127V will be banned beginning November 10, 2025.    All products with dual voltage 127/220 volts will be banned beginning February 28, 2016. Only products rated 220V or 230V will be allowed into the country after this period.

This measure is related to the use of both major international standards – 110 and 220 volts – in the construction industry.  Plugging an electrical appliance that runs on less than 220 volts into a 220-volt socket constitutes a fire hazard, although plugging a 220-volt appliance into a 110-volt socket represents no danger. In many homes, however, the electrical sockets nearest to air conditioners, refrigerators and other high-powered home appliances are 220-volt outlets, whereas the remainder are 110-volt. Accidentally plugging a 110-volt appliance into a 220-volt socket may cause the wire or socket to overheat and burst into flames.

Croatia – Acceptance of R&TTE Directive without Additional Type Approval Requirements

As of March 1, 2012, products meeting the requirements of the R&TTE Directive in Europe can be sold in Croatia without any further Type Approval requirements.   Prior to this new Ordinance (OG 25/2012) which brings it fully in line with Directive 1999/5/EC, the Croatian Authority, HAKOM, required additional Type Approval and filing.   At this time, no further Type Approvals will be issued by HAKOM, and all existing applications for Type Approval have now been cancelled.

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