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MultiPoint Newsletter - May 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.


In our April 2012 MultiPoint, we incorrectly stated that since the January 1, 2011 deadline had passed, TCBs were not allowed to certify PTT radios with a 12.5 kHz channel bandwidth transmitter with one voice channel as the spectrum efficiency standard was not being met. However, we failed to check the Notice of Proposed Rule Making (NPRM) FCC 10-119斗地主达人 that waived the deadline for the 6.25 kHz per voice channel efficiency standard requirement and moved it to January 1, 2013.  As a result of the NPRM 10-119 waiver, TCBs are allowed to certify PTT radios with 12.5 kHz channel bandwidth transmitter with one voice channel between now and January 1, 2013.

Regulatory Authority Spectrum Refarming

Question: We manufacture mostly unlicensed wireless devices, but with regard to spectrum related matters, we have increasingly noticed the use of the word “refarming” by regulatory authorities. Will you please explain refarming as it relates to the spectrum?

Answer: When regulatory authorities use the word “refarming” in spectrum related matters, they are referring to a set of administrative, economic and technical actions aimed to recover certain frequency bands from existing users. The recovered frequency bands are then re-assigned either for new uses, for new emerging technologies, and/or for new spectrally efficient technologies. While refarming is an important tool used to optimize spectrum efficiency for different users or services, the process can also be extremely difficult if the bands are heavily deployed. As a result, regulatory authority management are well aware of both the advantages and the deployment challenges of spectrum refarming, including the cost to relocate current users in new bands or new channels.

In the Fixed Service sectors, refarming required vacating some of the occupied bands and obtaining new bands for development of new services. Fixed Services are fixed radio links that provide transmission paths between two or more fixed points for the provision of telecommunication services. These services may include voice, data or video transmission. Users of these fixed services include telecom operators (mobile network infrastructure, fixed/mobile network backbone links), corporate users (private data networks, connection of remote premises, etc.) and private users (access PSTN or other networks).

Refarming can sometimes include relocating military frequency bands for civil fixed service band use, and/or converting frequency bands from point-to-point to point-to-multipoint use. The most notable example of fixed service refarming in Europe was the recovery and reassignment of the bands around 2 GHz, historically used for Fixed Service communications but reallocated to mobile services in the early 1990’s. This action by the regulatory authority resulted in Fixed Services gaining wider access to higher bands that are better suited for such fixed links.

In the United States, an example of refarming is the migration to 12.5 kHz efficiency technology (once referred to as refarming by the FCC, but now referred to as narrowbanding) to allow the creation of additional channel capacity within the same radio spectrum, and support more users. Effective January 1, 2013, all public safety and business industrial land mobile radio systems operating in the 150-512 MHz radio bands must cease operating using 25 kHz efficiency technology, and begin operating using at least 12.5 kHz efficiency technology.

R&TTE Assessed Modules

Question: We manufacture wireless devices that incorporate radio frequency modules assessed under the R&TTE Directive and we would like to know if the modules would have to be re-assessed as part of our final product assessment.

Answer: The answer depends on how your final product incorporates the assessed module. If the final product integrating the assessed radio frequency module contains an integral antenna, or is supplied with a specific antenna and you have installed it in conformance with your radio module manufacturer’s installation instructions, the radio module should not require further evaluation under Article 3.2 of the R&TTE Directive, nor any action on the part of your Notified Body.

However, if the final product includes the assessed radio frequency module but there were deviations from the manufacturer’s installation instructions and/or the module’s intended purpose, the assessed radio module may have to be re-assessed。 If your final product is subject to the essential requirements of the R&TTE Directive Articles 3。1(a) and (b), Safety and EMC respectively, including any other relevant Article 3。3 requirements, the assessment may include technical analysis, design evaluation and testing of your final product that takes into consideration the module’s installation and intended purpose in accordance with Article 6 of 1995/5/EC。 Please note that in many instances, a meaningful assessment of the need to reassess the module by itself may not be practical, and a complete conformity assessment is often only possible after integrating the module in your final product。

Please click here to link to TGN 01 Rev 5, “Technical Guidance Note on Requirements for a Final Product that Integrates an R&TTE Directive Assessed Module”, issued on December 27, 2011 by the R&TTE Compliance Association.

FCC Pre-Grant/Post-Grant Sample Testing

Question: 斗地主达人We manufacture wireless devices and would like to know the procedure for shipping our equipment to the FCC for pre-grant and post-grant testing.

Answer: If the FCC requests that you provide an equipment sample to perform pre-grant certification testing or post-grant audit testing, you can either hand deliver the sample or ship the sample, following strict instructions.

First, all test samples submitted should include all of the applicable items below:

  1. All installation instructions, software, user’s manuals, and operating instructions necessary to configure and test the device.
  2. All cables and adapters required for configuring the sample and connecting it to all accessories.
  3. For battery-operated devices, chargers and each battery option should be submitted.
  4. For modules, a host device should be submitted.
  5. For body worn devices, each type of holster and belt clip should be submitted.

To hand deliver, you must obtain prior approval from the FCC。 Your sample must be labeled with identification tags listing the following items, in the order they appear, to ensure the sample will not be returned for lack of sufficient identification:

  1. The identical FCC ID shown on the application (Form 731) or grant (Form 731A).
  2. Name, address, and telephone number of the person to contact should the sample malfunction during testing, or if it is necessary to return the sample for repair.

If you prefer to ship the sample instead via the United States Postal Service (USPS), Freight/Air, or Courier Services, you must identify the sample with the information as described in #1 and 2 above, ship to the FCC’s address below:

Federal Communications Commission
7435 Oakland Mills Road, Gate A
Columbia, Maryland 21046
Attention: (enter FCC personnel name in the sample request letter received)
Telephone: (301) 362-3000

You should include all test samples, as well as a copy of the sample request letter and a completed Return Shipment Authorization form (see link later below)。

Foreign applicants with American subsidiaries or agents should ship the test samples to one of these parties, who can then forward to the FCC。 If there is no American subsidiary or agent to handle this, then arrangements must be made for clearance of the shipment through U。 S。 Customs, delivery of the test samples to the FCC laboratory, and the return shipment to the applicant。 The FCC does not make delivery arrangements, nor pay any charges associated with foreign shipments。

If you require notification of the date your test samples were delivered to the FCC, you should contact your shipper, not the FCC。

The 287378 D01 Equipment Shipping Instructions v01 provides the FCC’s equipment shipping instructions, including the shipping address and the Return Shipment Authorization form that must be completed, identifying all equipment submitted, and included with the shipment to the FCC.

Importing Uncertified, “Not For Sale in USA” Products

Question: We market wireless devices and would like to import a quantity of uncertified devices that far exceeds the limited quantities allowed by FCC 47CFR . Per 47CFR§2.1204(a)4, the uncertified devices are not for sale in the United States, and are imported for the purposes of either testing and evaluation, or suitability for marketing and/or for demonstration at an industry trade show.  Does the FCC have a guideline to request a waiver of the quantity rules?

Answer: Yes, the FCC has guidelines for requesting a waiver of the quantity rules. The request needs to be submitted via email to the FCC and provide specific details and appropriate justification for the waiver request. The request needs to be submitted well ahead of the date of importation to allow sufficient time for review, processing and approval.

Send the waiver request to eastech@fcc.gov. The following information is required in order for the waiver request to even be considered.

  1. Indicate who is importing the device, include contact information
  2. Indicate the specific rule in 2.1204 for which the waiver is being requested; provide sufficient justification for the waiver.
  3. Details about Imported Device
    • Provide a detailed description of the device and how it is identified (i.e. model #)
    • Provide the number of devices to be imported
  4. Provide the specific import period dates
  5. State the specific reason(s) the devices are being imported (i.e. testing or development, trade show, etc.), and why more devices are necessary than allowed by the existing FCC rules
  6. Indicate who is responsible for, and who will control, the devices during the importation period, include contact information
  7. Explain what will happen to the devices at the end of the importation period
  8. Explain if the devices will be exported or destroyed if they are not approved.  If approved/certified, will the devices be labeled, and are they identical to the imported version?

Standards Updates


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

  • - (4/27/2012) - Plugs, socket-outlets and couplers for industrial purposes - Part 2: Dimensional interchangeability requirements for pin and contact-tube accessories
  • - (4/27/2012) - Plugs, socket-outlets and couplers for industrial purposes - Part 4: Switched socket-outlets and connectors with or without interlock
  • E - (4/27/2012) - Fibre optic interconnecting devices and passive components - Basic test and measurement procedures - Part 3-28: Examinations and measurements - Transient loss

See CENELEC for additional information.


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

  • - (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
  • - (April 2012) - Electromagnetic compatibility and Radio spectrum Matters (ERM); Digital Private Mobile Radio (dPMR) using FDMA with a channel spacing of 6,25 kHz
  • - (May 2012) - Environmental Engineering (EE); Measurement method for energy consumption of Customer Premises Equipment (CPE)
  • - (May 2012) - Electromagnetic compatibility and Radio spectrum Matters (ERM); System Reference Document; Short Range Devices; Technical characteristics of wireless aids for hearing impaired people operating in the VHF and UHF frequency range

See ETSI website for additional information.


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

  • - (4/27/2012) - Medical electrical equipment - Part 2-6: Particular requirements for the basic safety and essential performance of microwave therapy equipment
  • - (4/30/2012) - Electromagnetic compatibility (EMC) - Part 4-4: Testing and measurement techniques - Electrical fast transient/burst immunity test
  • - (5/10/2012) - Information technology equipment - Safety - Part 1: General requirements
  • - (5/15/2012) - Electromagnetic compatibility (EMC) - Part 4-25: Testing and measurement techniques - HEMP immunity test methods for equipment and systems
  • - (5/15/2012) - Incandescent lamps - Safety specifications - Part 2: Tungsten halogen lamps for domestic and similar general lighting purposes
  • - (5/15/2012) - Metallic communication cable test methods - Part 4-14: Electromagnetic compatibility (EMC) - Coupling attenuation of cable assemblies (Field conditions) absorbing clamp method
  • - (5/16/2012) - Corrigendum 1 - Medical electrical equipment - Part 2-27: Particular requirements for the basic safety and essential performance of electrocardiographic monitoring equipment
  • - (5/9/2012) - Fire hazard testing - Part 4: Terminology concerning fire tests for electrotechnical products
  • - 4/20/2012) - Medical electrical equipment - Part 2-3: Particular requirements for the basic safety and essential performance of short-wave therapy equipment

See for additional information.

EU – Proposed Changes to Electric Toy Safety Regulations

Recently, CENELEC TC61 committee proposed the following amendment to EN 62115:2005+A2:2011 Electric Toys Safety:

  • Testing applicable to battery compartments unless the cover can only be removed with the aid of a tool or by two independent simultaneous movements
  • Evaluation of protective electronic circuits to ensure that the toy does not malfunction in such a way as to cause an unintended operation that may impair safety or present a dangerous malfunction due to electromagnetic phenomena
  • Reduction in allowable temperature limits for children under three and between three and eight years old
  • Uncoated metal surfaces for all age ranges
  • Instructions advising that the toy only be connected to Class II equipment or conductive parts shall not be accessible
  • For computer toys intended to be connected to a computer or similar device, creepage and clearance distances must be at least 1.5 mm between accessible and conductive parts.
  • Transformer toys must be labeled “Warning. Not suitable for children under 36 months”
  • Transformers for toys must comply with both EN 61558-2-7 and EN 61558-2-16 if they are Switch Mode type.

The proposed amendment is subject to a formal vote April 27, 2012 and if adopted, it will be harmonized under the Directive in May 2012。

Canada – New Issue of SRSP-308.2, SRSP-310.5 and SRSP-301

On May 1, 2012, Industry Canada released the following revised documents:

  • ;
  • ; and
  • .

Australia – ACMA considers 1.5 GHz for Broadband

On May 17, 2012, Australia’s Communications and Media Authority, ACMA, released 。 The publication, ACMA’s first consultation on the radiofrequency spectrum between 1427。9 and 1510。9 MHz (the 1。5 GHz mobile band), investigates the potential use of the 1。5 GHz mobile band for mobile broadband services。

Previously, this band was identified by the ACMA as one of a number of candidate bands for mobile broadband services in its previous consultation, .

provides the factors for reviewing the 1.5 GHz mobile band and some preliminary options for future arrangements. The main goal of the consultation is to obtain industry insight and thought in order to prepare for the next stage of the review when more detailed proposals will be developed.

Currently, the 1.5 GHz mobile band is heavily utilized in remote and regional areas and only lightly utilized in metropolitan areas where usage is dominated by one licensee. This relatively low usage of 1.5 GHz in the metropolitan areas, which have high demand for mobile broadband services and international movement to standardize the band for mobile broadband services, is the driving factor of ACMA’s consideration of band replanning options.

Australia – Delay of RCM Marking

The new Electrical Equipment Safety System (EESS) scheme incorporating the RCM marking will be delayed until at least March 1, 2013。

At the ERAC meeting last week, ERAC members agreed to an implementation date of March 1, 2013 for the (EESS)。 NSW confirmed at the meeting that it will not be implementing the EESS。 This brings into question the entire premise of the EESS, as it is being promoted on the ERAC website as a National Scheme。

ACMA is now forced to delay the implementation of consolidation of the existing ACMA regulatory compliance labels into a single consolidated mark, the RCM. The ACMA has not yet made an announcement as to when the RCM may be used in lieu of the C-Tick and A-Tick, however it is likely to coincide with the revised EESS implementation date.

Nepal – New Type Approval Regulation

Nepal’s Telecommunications Authority (NTA) recently implemented Type Approval regulations to ensure quality of equipment and mobile handsets that will control the import of the sub-standard mobile handsets in the country。

“The type approval is based on a test report and certificate of conformity issued by the manufacturers,” according to spokesperson Kailash Prasad Neupane. “The regulator will also have to approve equipment of those manufacturers approved by itself,” he said, adding that the equipment and mobile sets of the NTA-approved international standardization bodies or regulatory inspection and certifying bodies will also have to be approved again.

The new regulation will require registration of mobile handsets in a central database requiring the International Mobile Equipment Identity (IMEI) and Electronic Serial Number (ESN) number。 The new regulation has also made the telecom service providers responsible to provide the IMEI and ESN number of mobile handsets of their consumers, if the security agencies request it。 Another goal of this new regulation is to stop the importation of illegal equipment related to the telecom sector。

Pakistan – Type Approval Required for Bluetooth Devices with 2mW Output Power

Previously, the Pakistan Telecommunication Authority (PTA), did not actively enforce part of its regulation requiring Bluetooth devices to be Type Approved。 Because of this lack of enforcement, PTA considered Bluetooth devices exempt from Type Approval。

However, recently PTA has decided to enforce this regulation and all Bluetooth devices with an output power of more than 2mW EIRP are now required to have Type Approval. Bluetooth devices with less than 2mW EIRP output power remain exempt from Type Approval requirements.

Hong Kong – Change in Authority Name and New Label Format

As of April 1, 2012, Hong Kong’s regulatory authority, Telecommunications Authority (TA), has changes its official name to Communications Authority (CA). Additionally, the name of the executive arm changed from the Office of the Telecommunications Authority (OFTA) to the Office of the Communications Authority (OFCA).

Also, the new labeling format below comes into effect:

斗地主达人The certificate number reads as follows:

  • ZZZZZ : Certification Body code assigned by OFCA
  • YY : Year of issue
  • XXXXX : Serial number of certificate issued during that calendar year

Argentina – Changes to IRAM Safety Approval Procedure

Recently, the Argentine Institute of Standardization and Certification (IRAM) has advised changes to their FAST TRACK certification scheme. Under the current FAST TRACK scheme, test reports issued by UL under IEC standards or harmonized with IEC, or CBTR and CBTC (Test report and test certificates) issued under the CB Scheme and by UL (US) or UL (Demko) allow manufacturers to obtain IRAM Approval without the need for local testing.

Recent changes to the existing FAST TRACK scheme have added the requirement of a physical sample of the product for inspection purposes only。 These changes should come into effect in May 2012。

Croatia – Notification Requirements

斗地主达人In March 2012, we advised that products meeting the requirements of the R&TTE Directive in Europe can be placed on the market in Croatia without any further type approval activity. We have received the following additional information regarding products operating in non harmonized bands:

In the case of R&TTE equipment using frequency bands which are not European harmonized frequency bands for such R&TTE equipment, or which is not in accordance with the Ordinance on the radio-frequency spectrum allocation, the manufacturer or his authorized representative or the person responsible for placing such equipment on the market in the Republic of Croatia must submit official notification at least 30 days before placing the equipment on the market. If the R&TTE equipment listed in the notification is not in accordance with the Radio Frequency Allocation Table or there are other prescribed limitations of use of such equipment in the Republic of Croatia, HAKOM shall inform the person who submitted the notification about that within 30 days of the receipt of the notification.

Morocco – Change in Import / Type Approval Rules

Morocco’s ANRT (Agence Nationale de Réglementation des Télécommunications) recently updated their import regulations in March 2012。 Previously, any device (WLAN, BT, GSM, etc) containing a GPS receiver/transmitter could not follow a Type Approval route and was subject to follow the Import Authorization process。

Under the new March 2012 regulations, ANRT is now processing Approvals of WLAN/BT devices which contain a GPS receiver (receive-only). Devices exempt from Type Approval, and where Import Authorization is still required, are:

  • 2G/3G module containing a GPS receiver
  • GSM terminal
  • Answering machine
  • Fax
  • Telephone
  • Built-in laptop modem
  • GPS receiver (standalone)

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