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MultiPoint Newsletter - Oct 2010 Issue

RF/EMC Regulatory Update

for the United States, Canada & European Union

Dear Colleague,


We have provided typical questions and answers that represent in most cases technical opinions with justification in FCC 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 .

FCC Guidance on Combination Devices under Multiple Rule Parts

QUESTION: We are a manufacturer of mixed module wireless devices。 What is the FCC's guidance on combination devices operating under multiple rule parts?

ANSWER: Section 47CFR §15.31(k) defines a composite system as a "system that incorporates different devices contained either in a single enclosure or in separate enclosures connected by wire or cable. If the individual devices in a composite system are subject to different technical standards, each such device must comply with its specific standards." Composite devices have one FCC ID. Multiple applications with the same FCC ID are required if there are multiple Equipment Classes.

There are no specific restrictions for transmitter devices in combination with unlicensed FCC Part 15 rules. However, all combination devices must meet RF exposure requirements and additional requirements, or restrictions that may be enforced by the Wireless Telecommunications Bureau (WTB). Questions about specific combinations may be submitted to; use the link "Submit an Inquiry" to access the form and submit a question.

See link: 

R&TTE SAR Requirements

QUESTION: We are manufacturing a tablet PC and want to obtain the CE Mark. In IEC62209-2, a tablet form factor portable computer test configuration is described in Figure 7(b), for which SAR should be separately assessed with the following:

  1. each surface.
  2. the separation distances positioned against the flat phantom that corresponds to the intended use as specified by the manufacturer。

If the intended use is not specified in the user instructions, the device shall be tested directly against the flat phantom in all usable orientations。 If we add an instruction in the user manual that warns the user to keep the tablet at least 15mm from his body when using it, can SAR be measured based on this 15mm separation distance to flat phantom?

ANSWER: Your question is very interesting, especially when the Specific Absorption Rate (SAR) measurement for R&TTE CE Mark Declaration of Conformity (DoC) is compared to the requirements of the FCC. The difference between the CE Mark requirement and the FCC is that the FCC creates rules, regulations, and policies by which devices such as tablets are certified. Provided your company complies with the existing FCC rules, regulations and policies with respect to SAR measurements, you have met the intent of the rules. However, with R&TTE DoC, it is the manufacturer's responsibility to determine the use of the device, and to identify and apply the appropriate SAR standard that is necessary to assure full SAR compliance.

We recommend performing the SAR testing at 0mm for head and body SAR at 2.0 W/Kg. If the device passes, you have met the SAR IEC62209-2 compliance requirement. If the device fails, the following should be considered:

  1. Redesign the transmitting antenna so that the measured power density of the radiating antenna is redirected in such a way that it will comply at the measured distance.
  2. Reduce the power until the tablet passes, then
  3. Determine compliance at 5mm, 10mm, and 15mm.

As the manufacturer, you have to determine what is reasonable. The head and body SAR limit is 2.0 W/kg, and the limb SAR limit is 4 W/kg. Tablets are typically placed on one's lap, or in one's arms when used, with only clothing between the tablet and one's limb, but are generally not flat on the body or on the head when in transmit mode. If SAR testing is performed at 0mm, and it passes 2.0 W/kg head and body SAR, then there is no need for further limb SAR testing.

If, on the other hand, the tablet does not comply at 2。0 W/Kg head and body, it is then important to know at what distance the tablet will pass head and body SAR。 After this distance is determined, say 5mm, you will then proceed to limb SAR testing。 With limb SAR, it is important for the tablet to pass the 4 W/kg limb SAR limit at 0mm tablet-to-limb spacing because of the method of use expressed above。 If the device passes 4 W/Kg at 0mm tablet-to-limb spacing but must be placed at 5mm to pass 2 W/kg head and body SAR, this may be reasonable to you as the manufacturer。

You and your SAR laboratory may have to perform a pass/fail distance research analysis in order to determine appropriate compliant passing configurations in order to justify that your device is safe from an exposure to RF.

FCC's Position on ERP Measurements

QUESTION: We are a manufacturer of licensed devices and use an EMC lab that performs substitution ERP measurements per TIA-603-C with pre-calibrated field data. What is the FCC's current position on using this methodology?

ANSWER: The FCC's current policy is to accept the signal/antenna substitution method in accordance with TIA-603-C only。 Though you may find certification reports in the FCC's database that contain the pre-calibrated signal/antenna substitution method, the FCC does not recognize this method。 To summarize the pre-calibrated field method, it is performed using a signal generator to radiate a signal swept over a particular frequency range of interest。 The signal is then recorded at a single point in space at a distance corresponding to the measurement distance required for compliance testing。 A table of data collected from the site "pre-calibration" is then to be used to replace specific substitution procedures as described in TIA-603-C, Sections 2。2。12(j) through (l) and/or 2。2。17(c) and (d)。 The signal/antenna substitution method is required under the following conditions:

  1. FCC 47CFR §2.1055 requires spurious radiated emissions to be measured from a device's control circuits, RF circuitries including IFs and voltage control oscillators, power cables, and cabinets under normal operating conditions.
  2. Licensed device(s) require measurement to determine the maximum transmitter output power and conducted spurious noise; when such device(s) are designed with integral antennas, the signal/antenna substitution method is used to measure the aforementioned parameters.

The FCC has said in many of its publications that if and when the Accredited Standards Committee C63® -Electromagnetic Compatibility, industry, and/or recognized standards organizations present an alternative to the TIA-603 method, it will consider alternatives.

FCC's Most Recent Permit But Ask List

QUESTION: We are a manufacturer of Long Term Evolution technology. What does the latest FCC Permit But Ask List (PBA) show?

ANSWER: The new FCC PBA list was released on October 15th, 2010. This list allows TCBs to certify numerous types of equipment. However, the FCC retains oversight of certifications for certain types of equipment for which the FCC has not established specific guidelines, or when the FCC feels guidance is required. The FCC provides this guidance through its PBA review process on a case-by-case basis before authorization is given to the TCB to grant equipment authorization. The PBA list includes among other items:

  1. Device(s) authorization requests for devices for which acceptable test equipment or test procedures are required but that have not yet been established to determine compliance for EMC or radio parameter measurements.
  2. SAR Evaluation for LTE, 802.16e-WIMAX, 802.20-iBurst HC-SDMA, mobile/portable devices, etc.
  3. Special circumstance radio devices including Software Defined Radios.

See link for most recent PBA: 

STANDARDS UPDATE

EU: NEW CENELEC STANDARDS RECENTLY RELEASED This is a shortened list of the CENELEC standards published during the past month:

  • EN 60335-2-25:2002/A11:2010 (10/15/2010) Household and similar electrical appliances - Safety -- Part 2-25: Particular requirements for microwave ovens, including combination microwave ovens
  • EN 55016-1-1:2010/A1:2010 (10/15/2010) Specification for radio disturbance and immunity measuring apparatus and methods -- Part 1-1: Radio disturbance and immunity measuring apparatus - Measuring apparatus
  • EN 55016-2-3:2010/A1:2010 (10/15/2010) Specification for radio disturbance and immunity measuring apparatus and methods -- Part 2-3: Methods of measurement of disturbances and immunity - Radiated disturbance measurements
  • EN 60079-25:2010 (10/15/2010) Explosive atmospheres -- Part 25: Intrinsically safe electrical systems
  • EN 60730-2-7:2010 (10/15/2010) Automatic electrical controls for household and similar use -- Part 2-7: Particular requirements for timers and time switches
  • EN 61010-2-030:2010 (10/15/2010) Safety requirements for electrical equipment for measurement, control, and laboratory use -- Part 2-030: Particular requirements for testing and measuring circuits
  • EN 61010-1:2010 (10/15/2010) Safety requirements for electrical equipment for measurement, control, and laboratory use -- Part 1: General requirements
  • EN 50272-1:2010 (10/22/2010) Safety requirements for secondary batteries and battery installations -- Part 1: General safety information
  • EN 60745-1:2009/A11:2010 (10/8/2010) Hand-held motor-operated electric tools - Safety -- Part 1: General requirements
  • EN 60065:2002/A2:2010 (10/8/2010) Audio, video and similar electronic apparatus - Safety requirements

EU: NEW IEC STANDARDS RECENTLY RELEASED This is a shortened list of the new IEC standards published during the past month:

  • IEC 62475 (9/29/2010) High-current test techniques - Definitions and requirements for test currents and measuring systems
  • IEC 60252-1 (9/29/2010) AC motor capacitors - Part 1: General - Performance, testing and rating - Safety requirements - Guidance for installation and operation
  • IEC 62257-7-1 (9/29/2010) Recommendations for small renewable energy and hybrid systems for rural electrification - Part 7-1: Generators - Photovoltaic generators
  • IEC 61347-2-12-am1 (9/29/2010) Amendment 1 - Lamp controlgear - Part 2-12: Particular requirements for d.c. or a.c. supplied electronic ballasts for discharge lamps (excluding fluorescent lamps)
  • IEC 62433-2-1 (10/5/2010) EMC IC modelling - Part 2-1: Theory of black box modelling for conducted emission
  • IEC 60335-2-103-am1 (10/7/2010) Amendement 1 - Household and similar electrical appliances - Safety - Part 2-103: Particular requirements for drives for gates, doors and windows
  • IEC 62642-5-3 (10/7/2010) Alarm systems - Intrusion and hold-up systems - Part 5-3: Interconnections - Requirements for equipment using radio frequency techniques
  • IEC GUIDE 117 (10/13/2010) Electrotechnical equipment - Temperatures of touchable hot surfaces
  • IEC 61400-1-am1 (10/13/2010) Amendment 1 - Wind turbines - Part 1: Design requirements

EU: NEW ETSI STANDARDS RECENTLY RELEASED This is a shortened list of the new ETSI standards published during the past month:

  •  (October 2010) Electromagnetic compatibility and Radio spectrum Matters (ERM); ElectroMagnetic Compatibility (EMC) standard for radio equipment and services; Part 24:Specific conditions for IMT-2000 CDMA Direct Spread (UTRA and E-UTRA) for Mobile and portable (UE) radio and ancillary equipment
  •  (October 2010) Electromagnetic compatibility and Radio spectrum Matters (ERM); Short Range Devices (SRD) using Ultra WideBand (UWB) technology; Location Tracking equipment operating in the frequency range from 6 GHz to 9 GHz; Part 1: Technical characteristics and methods of measurement
  •  (October 2010) Electromagnetic compatibility and Radio spectrum Matters (ERM); Short Range Devices (SRD) using Ultra WideBand (UWB) technology; Location Tracking equipment operating in the frequency range from 6 GHz to 9 GHz; Part 2: Harmonized EN covering the essential requirements of article 3.2 of the R&TTE Directive
  •  (October 2010) Digital cellular telecommunications system (Phase 2+); Base Station System (BSS) equipment specification; Radio aspects (3GPP TS 51。021 version 8。8。0 Release 8)
  •  (October 2010) Digital cellular telecommunications system (Phase 2+); Base Station System (BSS) equipment specification; Radio aspects (3GPP TS 51。021 version 9。3。0 Release 9)
  •  (October 2010) Electromagnetic compatibility and Radio spectrum Matters (ERM); Telecommunication network equipment; ElectroMagnetic Compatibility (EMC) requirements
  • 1 (October 2010) Electromagnetic compatibility and Radio spectrum Matters (ERM); ElectroMagnetic Compatibility (EMC) standard for radio equipment and services; Part 23: Specific conditions for IMT-2000 CDMA, Direct Spread (UTRA and E-UTRA) Base Station (BS) radio, repeater and ancillary equipment
  •  (October 2010) Advanced Surface Movement Guidance and Control System (A-SMGCS); Part 2: Community Specification for application under the Single European Sky Interoperability Regulation EC 552/2004 for A-SMGCS Level 2 including external interfaces

FCC: ADOPTION OF SECOND MO&O, ET DOCKET 02-380 On September 23, 2010, the FCC adopted 。 This Second Memorandum Opinion and Order (Second MO&O) resolves numerous legal and technical issues。 Notably, the Order eliminates the requirement that TV bands devices that incorporate geo-location and database access must also include sensing technology to detect the signals of TV stations and low-power auxiliary service stations (wireless microphones)。 It also requires wireless microphone users who seek to register in the TV bands databases to certify that they will use all available channels from 7 through 51 prior to requesting registration。 Requests to register in the database will be public, thus allowing interested parties to weigh in on any given request。

The FCC is also taking steps to ensure that incumbent services are protected from interference from the use of white spaces in various ways. In particular, the Order reserves two vacant UHF channels for wireless microphones and other low power auxiliary service devices in all areas of the country. It also maintains a reasonable separation distance between TV White Space device and wireless microphone usage permitted to be registered in the database

EU: RELEASE OF TGN 15, REV 1 In late June 2010, the R&TTE Compliance Association released . The document provides guidance on Annex II of the R&TTE Directive which requires a manufacturer to establish technical documentation. The technical documentation, known as the Technical Construction File (TCF), forms the basis of a Notified Body opinion under Annex IV of the Directive. TGN 15, Rev 1 describes the content of a TCF expected by a Notified Body when an opinion is requested.

CANADA: RELEASE OF SMSE-011-10 - CB-02, ISSUE 5 On October 16, 2010, Industry Canada released , Recognition Criteria, and Administrative and Operational Requirements Applicable to Certification Bodies for the Certification of Radio Apparatus to Industry Canada's Standards and Specifications.

Changes in the new issue include:

  • introduction of of accreditation for radio equipment (Section 5。2);
  • update to the audit requirements for Certification Bodies (CBs) to include, as a minimum, five (5) percent of the total number of products certified by the CB in a given year. At least one (1) percent of the products subject to radio frequency (RF) exposure requirements and certified by the CB shall be included in the total number of samples audited (Section 6.2.2);
  • clarification of the information that can be included on certificates issued by CBs (Section 6.3);
  • inclusion of the RF exposure test report in the technical brief submitted to Industry Canada Certification and Engineering Bureau (CEB) for every certification performed on equipment subject to RF exposure requirements (Section 6。1。1); and
  • clarification of the certification process for radio equipment with terminal interface (Section 6。4。2)。

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