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MultiPoint Newsletter - April 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/TCB Approval For Part 90 LMRs

Question: We manufacture a Part 90 Land Mobile Radio (LMR) capable of both voice and data; it is not a handheld device, it operates in the 450-470 MHz band, it produces less than 2 watts of radio frequency power and its authorized bandwidth is 12.5 kHz. Our EMC laboratory is telling us that our TCB cannot review and approve our certification application, but instead we must submit our application to the FCC for their review and approval. Is this correct?

Answer: Your EMC laboratory is correct. FCC 628591 D01 TCB Exclusion List v12r02 identifies equipment that is excluded from certification via the TCB process and must instead be reviewed and approved by the FCC. Section (1.i) of the TCB exclusion list precludes any TCB from certifying and issuing a grant for an LMR operating under the following section of FCC Part 90 rules:

“Transmitters operating under the provisions of with channel bandwidths of greater than or equal to 12.5 kHz operating in either multi-bandwidth modes or under the special provisions of spectrum efficiency standards specified in , or operating under the provisions of one way paging channel standards of .”

Your LMR falls under these criteria and is therefore excluded from TCB review and approval, and instead will require the FCC to review and approve it.

Furthermore, the FCC currently permits use of 12.5 kHz analog authorized bandwidth if your device is a dual mode device which consists of both analog and digital transmission capability. In this instance, you must have one 6.25 kHz digital mode. If your device is not dual mode capable, you must meet the spectrum efficiency standard of . Please note that your device could also have a 25 kHz authorized bandwidth, if it meets the minimum spectrum efficiency standard data rate of 4 x 4800 bits per second. A letter is required stating compliance to the minimum spectrum efficiency standard data rate. We recommend that you contact the FCC via the FCC Knowledge Database (KDB) at to obtain further guidance on this issue; your inquiry should be supported by the operational description, the LMR specification, spectrum plots, drawings (block diagrams and schematics), user’s manual, etc.

FCC Part 18 ISM Devices

Question: We manufacture an Industrial Scientific Medical (ISM) device that sanitizes water using a magnetic field operating below 100 Hz, and the device is small enough to be used by the average consumer at home. Is such a device exempt from FCC rules and regulations?

Answer: Since your device operates below 9 kHz, it is exempt from FCC rules and regulations, however an ISM device that uses a radio frequency magnetic field energy above 9 kHz to perform work such as sanitizing or purifying water would be regulated under Part 18, Industrial Scientific Medical (ISM) Equipment.

Devices that operate from 9 kHz and above must be tested, appropriately labeled and documented before they can be marketed, in accordance with the equipment authorization procedures specified under .

If your device contains an integrated digital interface with clock speeds 9 kHz or greater, it will also be subject to , as an unintentional radiator。 Since it could be used in a home, it would be subject to the Declaration of Conformity (DoC) or Certification equipment authorization procedure。

Please note that a device that is subject to 47CFR§18 and 47CFR§15 regulations will be tested for compliance to the different regulations by disabling the Part 18 transmitter function, to determine if the device meets the Part 15 requirements.

Test reports and documentation of compliance must be clearly segmented to identify the procedure used to determine compliance to both rule parts. Labeling requirements will depend on the combination of equipment authorization procedures. If both are subject to Verification or Declaration of Conformity (DoC), then the labeling requirements for a Part 15 device are applicable. If one is subject to Verification and the other is subject to DoC, then the DoC label is applicable. For a Certification procedure, the Certification FCC Identifier (FCC ID:) or Identifiers (for separate Certifications) must be on the device, in addition to any applicable DoC label.

FCC Approval For TETRA Equipment

Question: We manufacture Terrestrial Trunked Radio (TETRA) equipment and would like to know which FCC rules and regulations are applicable to our equipment.

Answer: TETRA equipment is digitally trunked radio technology that operates with Time Division Multiple Access (TDMA) in four-slot channels with a 25 kHz bandwidth and uses spectral efficient digital technology that provides invaluable benefits to land mobile radio users.

Based on the benefits of this technology, the TETRA Association submitted a request to the FCC for the waiver of 47CFR§90 occupied bandwidth limit and emission masks to allow TETRA equipment to operate in the U.S.

斗地主达人In particular, limits land mobile radio authorized bandwidth to 20 kHz and designates the use of particular emission masks; TETRA equipment exceeds both, in part because the ETSI standard does not set occupied bandwidth limits. Instead, it sets standards for adjacent channel power and for unwanted emissions at different frequency offsets.  This results in operation with a bandwidth of up to 22 kHz, and excursions of up to 5 dB from the Part 90 emission masks.

The FCC granted NPRM and Order FCC 11-63 waiver that allows TETRA equipment to operate using a 25 kHz authorized bandwidth and higher power emission masks。

The FCC also added a new section 47CFR§90.221, Adjacent Channel Power Limits, to its rules and regulations in support of TETRA equipment. Click the link FCC-1163A1 for more information on the FCC’s TETRA equipment waiver and the FCC’s TCB guidance for approving TETRA devices under Part 90.

FCC’s Equipment Housing Permissive Change Policy

Question: We manufacture a portable 2.4 GHz wireless router and recently changed its housing, the printed circuit board and its components remain the same. We do not believe this change has any impact on the router’s emission profile or radio frequency (RF) hazard exposure. Can you provide some guidance on our assumption?

Answer: If you change the housing of your wireless router you should perform due diligence to determine if the emission and RF hazard profiles have changed, and if a Class I or Class II permissive change is required. To do so, you should perform radiated emissions testing and Specific Absorption Rate (SAR) evaluation testing.

If your emissions profile and RF exposure hazard profile have not changed from the previously certified results, a Class I permissive change would apply。 If the profiles have degraded, a Class II permissive change would be required。

It should be noted that SAR results are primarily dependent on the near fields and RF current distributions on a device; therefore minor and simple metallic changes may cause relatively large changes in the SAR results so SAR evaluation testing is necessary if you have changed the housing. For further guidance on this issue check 178919 D01 Permissive Change Policy v05r02.

A router, or other device, with Modular Approval, allows more flexibility for housing changes, though the basic functioning circuitry (transmitter and digital interface) should not change.

Standards Updates


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

  • - (3/19/2012) - Specification for portable electrical apparatus designed to measure combustion flue gas parameters of heating appliances - Part 1: General requirements and test methods
  • - (3/21/2012) - Low-voltage switchgear and controlgear - Part 3: Switches, disconnectors, switch-disconnectors and fuse-combination units
  • - (3/27/2012) - Electroacoustics - Hearing aids - Part 15: Methods for characterising signal processing in hearing aids with a speech-like signal
  • - (3/28/2012) - Commissioning of electrical, instrumentation and control systems in the process industry - Specific phases and milestones
  • - (3/28/2012) - Automation systems in the process industry - Factory acceptance test (FAT), site acceptance test (SAT) and site integration test (SIT)

See CENELEC for additional information.


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

  • - (March 2012) - Electromagnetic compatibility and Radio spectrum Matters (ERM); Short Range Devices; Road Transport and Traffic Telematics (RTTT); Short range radar equipment operating in the 24 GHz range; Part 1: Technical requirements and methods of measurement
  • - (March 2012) - Electromagnetic compatibility and Radio spectrum Matters (ERM); Short Range Devices; Road Transport and Traffic Telematics (RTTT); Short range radar equipment operating in the 24 GHz range; Part 2: Harmonized EN covering the essential requirements of article 3.2 of the R&TTE Directive
  • - (March 2012) - Electromagnetic compatibility and Radio spectrum Matters (ERM); System Reference Document; Short Range Devices (SRD); Radar sensors for non-automotive; ground based vehicular applications in the 76 GHz to 77 GHz frequency range
  • - (March 2012) - Electromagnetic compatibility and Radio spectrum Matters (ERM); Short-Range Devices (SRD) for operation in the 13,56 MHz band; System Reference Document for Radio Frequency Identification (RFID) equipment
  • - (March 2012) - Electromagnetic compatibility and Radio spectrum Matters (ERM); Using the EN 301 489 series of EMC standards
  • - (April 2012) - Electromagnetic compatibility and Radio spectrum Matters (ERM); Digital Mobile Radio (DMR) Systems; Part 1: DMR Air Interface (AI) protocol
  • - (April 2012) - Electromagnetic compatibility and Radio spectrum Matters (ERM); Digital Mobile Radio (DMR) Systems; Part 2: DMR voice and generic services and facilities

See ETSI website for additional information.


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

  • - (3/19/2012) - Conformity assessment -- Requirements and recommendations for content of a third-party audit report on management systems
  • - (3/22/2012) - Corrigendum 1 - Electromagnetic compatibility of multimedia equipment - Emission requirements
  • - (3/26/2012) - Household and similar electrical appliances - Safety - Part 2-17: Particular requirements for blankets, pads, clothing and similar flexible heating appliances
  • - (3/26/2012) - Household and similar electrical appliances - Safety - Part 2-23: Particular requirements for appliances for skin or hair care
  • - (3/26/2012) - Household and similar electrical appliances - Safety - Part 2-7: Particular requirements for washing machines
  • - (3/29/2012) - Household and similar electrical appliances - Safety - Part 2-72: Particular requirements for floor treatment machines with or without traction drive, for commercial use
  • - (4/4/2012) - Household and similar electrical appliances - Safety - Part 2-39: Particular requirements for commercial electric multi-purpose cooking pans
  • - (4/4/2012) - Safety requirements for electrical equipment for measurement, control, and laboratory use - Part 2-033: Particular requirements for hand-held multimeters and other meters, for domestic and professional use, capable of measuring mains voltage
  • - (4/5/2012) - Safety of machinery - Electro-sensitive protective equipment - Part 1: General requirements and tests

See for additional information.

FCC – Amendment of Rules for Level Probing Radars

On March 27, 2012, the FCC released ET Docket No. 10-23: proposed rules for “level probing radars” (LPRs) in three bands: 5.925-7.250 GHz, 24.05-29 GHz, and 75-85 GHz.  LPRs are radars pointed downward which are used to determine levels of materials at industrial installations and have many applications.

斗地主达人Several years ago, the FCC proposed rules to allow in tank radars in the 77-81 GHz band and subsequently granted a waiver pending the rulemaking.   The current set of proposed rules adds outdoor LPRs, more frequency ranges, and also allows adequate power for a wide variety of applications.   In order to minimize interference from LPRs, the FCC proposed more stringent limits on the radio frequency emissions from the sides and top of the devices.  The FCC has requested comment and feedback on the proposed rules over the next 60 days.  

FCC – Guidance for Compliance Measurements on DTS

The FCC has recently published a draft version of .  At this time, the FCC is encouraging industry review and comments before the April 21, 2012 deadline.  The final release of this Guidance is expected in May 2012.

FCC – New Rules to Promote Interoperability in the Lower 700 MHz Band

On March 21, 2012, the FCC issued a Notice of Proposed Rulemaking (NPRM) to promote interoperability and encourage the efficient use of spectrum in the commercial Lower 700 MHz band (698-746 MHz).  The rulemaking is designed primarily to examine the interference concerns should the Lower 700 MHz band utilize a single band class for devices operating across the Lower 700 MHz A, B, and C Blocks.  The NPRM also explores possible next steps that the FCC should take to promote interoperability in the lower 700 MHz band should it find that there is limited or no harmful interference or such interference can be reasonably mitigated through industry and/or regulatory measures.  The FCC considers various options to help achieve the ultimate goal of interoperability.

FCC – Proposal for Additional 40 MHz of Additional Spectrum for Mobile Broadband

On March 21, 2012, the FCC released a Notice of Proposed Rulemaking with the goal of increasing the nation’s supply of spectrum for mobile broadband by removing unnecessary barriers to flexible use of 40 MHz of additional spectrum (currently assigned to the Mobile Satellite Service (MSS) in the 2 GHz band)。

This proposal would carry out a recommendation in the National Broadband Plan that the FCC enable the provision of stand-alone terrestrial services in this spectrum。 The proposed rules are designed to provide for flexible use of this spectrum, to encourage innovation and investment in mobile broadband, and to provide a stable regulatory environment in which broadband deployment can develop in the 2 GHz band。 The notice directly follows on last year’s 2 GHz Band Co-Allocation Order, in which the FCC laid the predicate for full terrestrial use of this band。   The FCC seeks comment on potential ways to free up additional valuable spectrum to address the increased demand for mobile broadband spectrum。  

Canada – Release of Technical Document for 700 MHz & 2500 MHz Bands

On March 14, 2012, Industry Canada released , which sets out Industry Canada’s general policy decisions for both the band 698-806 MHz (known as the 700 MHz band) and the band 2500-2690 MHz (known as the 2500 MHz band), specific decisions for the 700 MHz and 2500 MHz bands; and Industry Canada’s determination with respect to auction timing for both of the bands.

This document is the result of the consultation processes undertaken in Canada Gazette notice , and Canada Gazette notice .

Israel – WiFi Certificate No Longer Required for 802.11n Products

Recently, Israel’s Ministry of Communications (MoC) mandatory requirement of a Wi-Fi alliance certificate for 802.11n products has been removed from the Israeli regulation.  Previously, Israel’s MoC required Wi-Fi alliance certificates in addition to ETSI or FCC test reports for 802.11n devices.   Now, all WiFi devices can be granted MoC approval by submittal of the ETSI or FCC test reports only.

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