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MultiPoint Newsletter - April 2016

Confidential Exhibits

Question:斗地主达人 Due to the nature of our device, we want all of the required, product-specific information we submit for our FCC certification application to be held confidential. Can our TCB approve this, or do we need to obtain FCC approval before we submit the application to our TCB?

Answer: TCBs can authorize Long-Term and/or Short-Term Confidentiality for most exhibits to which these options can be applied, provided the FCC application includes a proper Confidentiality Request Letter with the necessary information to justify the request per Equipment Authorization Confidentiality Request Procedures, 726920 D01 Confidentiality Request Procedures v01r02, published April 8, 2016.

Internal Photos and User Manuals have their own specific conditions to meet in order to be eligible for Long-Term Confidentiality, and these conditions determine if a TCB or the FCC will review and decide the issue.

A TCB may grant Long-Term Confidentiality for these two exhibits only if the following special conditions a) and b) are met, a sample NDA is provided, and justification is provided for points 1‑4 below。

  1. Internal Photos may be held confidential if 1) the circuit board or internal components are not accessible to users; e.g. the circuit board is enclosed in epoxy, or 2) if the device is inaccessible to the public, e.g. mounted on the top of a large tower or in a fenced enclosure such that it is only serviceable by professional designated technicians under a Non-Disclosure Agreement (NDA).  All sales for these devices must be under a NDA restricting the disclosure of the propriety information, including internal photos.  
  2. A User Manual may be held confidential only when the manual contains proprietary technical information intended for professional technicians obligated under a NDA.  All sales and distribution of the user manual must be under a NDA that restricts the disclosure of the information.
  1. Detailed description how the internal photos and user manual are controlled to prevent them from becoming public or disclosed to unauthorized persons;
  2. Description of how public access is restricted for products serviceable by professional designated technicians.
  3. Statement that all sales of the non-consumer device will be under a NDA to include third party sales and that the final user of the device is subject to the NDA.
  4. Key terms of the NDA, to ensure consistency between the Long‑Term Confidentiality Request Letter and the sample NDA submitted with the letter.

If all these requirements cannot be met, an exceptional circumstance now exists as it relates to Long-Term Confidentiality for Internal Photos and User Manuals, and now Pre-Approval Guidance (PAG) must be requested from the FCC per the instructions in Footnote 6 of the Confidentiality Request Procedures document hyperlinked above, and the updated April 8, 2016 Pre-Approval Guidance List 388624 D02 Pre-Approval Guidance List v16R02, Section II, C, 2(b). Decisions are made by the FCC on a case-by-case basis.

If the FCC approves the request for Long-Term Confidentiality for the Internal Photos and/or User Manual, your TCB must submit a separate TCB PAG referencing the initial inquiry, and the inquiry tracking number should be entered in the appropriate field on the Form 731。

Other exceptional circumstances that require FCC PAG may include, but are not limited to:

  1. Requesting Long-Term Confidentiality for exhibits not eligible for Long-Term Confidentiality (as in the example above)
  2. Making an exhibit(s) confidential that is currently publicly available but that qualifies for Long‑Term Confidentiality. 
  3. Reinstating Short-Term Confidentiality for a recently expired Short-Term Confidentiality exhibit, if the maximum 180 days has not been utilized 

Product Demonstration without FCC Certification

Question: We have designed a Part 15-compliant device that we would like to demonstrate at an upcoming industry trade show, though we have yet to obtain FCC certification. Will the FCC allow this?

Answer: The FCC will allow you to demonstrate your Part 15-compliant device at the trade show, provided that your company, and the device, comply with the rules and regulations in Marketing of radio frequency devices prior to equipment authorization, and Operation of radio frequency devices prior to equipment authorization.

Specifically 47CFR§2。803(c)(2)(iii)(A) requires a conspicuous notice be displayed with the device at the trade show that clearly states “This device has not been authorized as required by the rules of the Federal Communications Commission。 This device is not, and may not be, offered for sale or lease, or sold or leased, until authorization is obtained。” This language should also appear in any marketing materials。

Some additional rules and regulations from 47CFR§2.803 that seem most appropriate for your situation are copied below, however to ensure compliance of any and all activities that involve your uncertified device, we strongly encourage you to review the complete rules and regulations in both the marketing and operation sections of the FCC rules noted above.

(c) Exceptions. The following marketing activities are permitted prior to equipment authorization:

  1. Activities under product development and market trials conducted pursuant to subpart H of Part 5.
  2. Limited marketing is permitted, as described in the following text, for devices that could be authorized under the current rules; could be authorized under waivers of such rules that are in effect at the time of marketing; or could be authorized under rules that have been adopted by the Commission but that have not yet become effective.  These devices may not be operated unless permitted by 47CFR§2.805.
    1. Conditional sales contracts (including agreements to produce new devices manufactured in accordance with designated specifications) are permitted between manufacturers and wholesalers or retailers provided that delivery is made contingent upon compliance with the applicable equipment authorization and technical requirements.
    2. A radio frequency device that is in the conceptual, developmental, design or pre-production stage may be offered for sale solely to business, commercial, industrial, scientific or medical users (but not an offer for sale to other parties or to end users located in a residential environment) if the prospective buyer is advised in writing at the time of the offer for sale that the equipment is subject to the FCC rules and that the equipment will comply with the appropriate rules before delivery to the buyer or to centers of distribution.
    3. (A) A radio frequency device may be advertised or displayed, (e.g., at a trade show or exhibition) if accompanied by a conspicuous notice containing this language:

      "This device has not been authorized as required by the rules of the Federal Communications Commission. This device is not, and may not be, offered for sale or lease, or sold or leased, until authorization is obtained."

TCB Surveillance Program

Question: Please explain the purpose of the Telecommunication Certification Body (TCB) Surveillance Program.

Answer: Each accredited TCB is required to perform “post-market surveillance” on a minimum of 5% of the certifications it approves each year, including 1% of the certifications that required SAR testing. The post-market surveillance requires re-testing a marketed device to ensure it is compliant with the FCC rules and regulations, as demonstrated by the test sample(s) during the testing and certification process. Post-approval re-testing under the TCB surveillance program can only be conducted by the TCB that issued the initial certification, and no other TCB.

To obtain the post-approval testing samples, the TCB may:

  1. send a request to the named contact in the Grantee Code database for a random production unit, along with a detailed list of additional required items and/or information, and shipping information;
  2. send a representative to the grantee’s factory or warehouse to pick units for testing at random;
  3. require the grantee to supply a voucher that the TCB can use to purchase random retail unit(s) at no cost to the TCB.

The FCC permits a TCB to request post-market surveillance samples through its equipment authorization system. If a grantee refuses to provide a test sample for post-market surveillance testing, the TCB can inform the FCC of the grantee’s refusal, in which case the FCC may contact the grantee directly. If the grantee still does not provide a sample, the FCC can put the Grantee Code into deferred status, with corresponding repercussions.


FCC Request for Audit Sample

Question: If the FCC requests a test sample of our certified device for auditing purposes, what should we be prepared to provide?

Answer: An FCC request for a test sample for their audit program will be sent to the contact in the FCC Grantee Code database, and it will include a specific and detailed list of items to provide:

  1. Test sample(s) as described in the FCC request.
  2. All necessary software including any special software, keys, codes, or tools to configure the device in the appropriate test modes, including instructions for setting the equipment sample to transmit continuously. 
  3. Cables and instructions for testing conducted output power of all operating modes. 
  4. For battery-operated devices, each battery option and the charger(s) required to charge each one, and two batteries for devices with only one battery option. 
  5. For modules, a host device or test board with instructions. 
  6. For devices requiring RF Exposure evaluation, all related accessories for RF Exposure (SAR) compliance testing, including all types of body-worn accessories (i.e. holsters, belt clips), and any other relevant accessories. 

Standards Updates

EU: New CENELEC Standards Recently Released

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

  • - 4/1/2016 - Industrial, scientific and medical equipment - Radio-frequency disturbance characteristics - Limits and methods of measurement
  • - 4/1/2016 - Sound and television broadcast receivers and associated equipment - Radio disturbance characteristics - Limits and methods of measurement
  • - 4/8/2016 - Test methods for electrical materials, printed boards and other interconnection structures and assemblies - Part 3-719: Test methods for interconnection structures (printed boards) - Monitoring of single plated-through hole (PTH) resistance change during temperature cycling
  • - 4/8/2016 - Audio, video and information technology equipment - Routine electrical safety testing in production

See for additional information.

EU: New ETSI Standards Recently Released

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

  • - (April 2016) - Global System for Mobile communications (GSM); GSM Repeaters; Harmonised Standard covering the essential requirements of article 3.2 of the Directive 2014/53/EU
  • - (April 2016) - LTE; Evolved Universal Terrestrial Radio Access (E-UTRA); Electromagnetic compatibility (EMC) requirements for mobile terminals and ancillary equipment (3GPP TS 36.124 version 13.1.0 Release 13)

See for additional information。

EU: New IEC Standards Recently Released

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

  • - (3/30/2016) - Electric welding equipment - Assessment of restrictions related to human exposure to electromagnetic fields (0 Hz to 300 GHz) - Part 1: Product family standard
  • - (3/31/2016) - Specification for radio disturbance and immunity measuring apparatus and methods - Part 1-3: Radio disturbance and immunity measuring apparatus - Ancillary equipment - Disturbance power
  • - (3/31/2016) - Amendment 1 - Specification for radio disturbance and immunity measuring apparatus and methods - Part 1-3: Radio disturbance and immunity measuring apparatus - Ancillary equipment - Disturbance power
  • - (4/13/2016) - Corrigendum 1 - Passive filter units for electromagnetic interference suppression - Part 3: Passive filter units for which safety tests are appropriate
  • - (4/13/2016) - Electromagnetic compatibility (EMC) - Part 1-2: General - Methodology for the achievement of functional safety of electrical and electronic systems including equipment with regard to electromagnetic phenomena
  • - (4/8/2016) - Safety requirements for electrical equipment for measurement, control, and laboratory use - Part 2-011: Particular requirements for REFRIGERATING EQUIPMENT
  • - (4/20/2016) - Mechanical structures for electrical and electronic equipment - Thermal management for cabinets in accordance with IEC 60297 and IEC 60917 series - Part 5: Cooling performance evaluation for indoor cabinets

See for additional information.

FCC – New Guidance on Pre-Approval (PAG) Procedure

On April 8, 2016, the FCC published guidance documents on the FCC Pre-Approval Guidance (PAG) procedure, formerly known as the Permit But Ask (PBA) procedure. provides the current list of devices that are subject to the Pre-Approval Guidance procedure and provides the Pre-Approval Guidance procedures. The changes to the Pre-Approval Guidance List v16r02 are as follows:

  • Removed requirements to submit PAG samples for UWB devices
  • Clarified EMC simultaneous transmission requirements
  • Clarified confidentiality issues
  • Removed VoLTE HAC but kept VoWiFi
  • Removed signal boosters
  • Removed UNII-1 and Wi-Fi client peer-peer applications

FCC – Potential Adoption of ANSI C63.26-2015

The FCC has proposed to adopt by reference the requirements of addressing measurement procedures used in the testing of transmitters. In a Public Notice issued April 1, 2016, the FCC formally requested public comments on its decision to incorporate the requirements of ANSI C63.26-2015, “American National Standard for Compliance Testing of Transmitters Used in License Radio Services,” as part of its effort to update and modernize its rules and procedures for the authorization of radiofrequency devices.

EU - EMC Directive 2014/30/EU and Low Voltage Directive 2014/35/EU in Effect

As of April 20, 2016, the following 2014 versions of the EMC and Low Voltage Directives must be applied, and all Declarations of Conformity that reference these directives must be updated for placement of the products on the European Market.

  • http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32014L0030
  • http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex:32014L0035

EU – Blue Guide Published

The has been published.

The “Blue Guide” was originally published in 2000 and become one of the main reference documents explaining how to implement the legislation based on the New Approach, now covered by the New Legislative Framework (NLF)。 Much of the 2000 edition of the “Blue Guide” is still valid but it did require updating to cover new developments and to ensure the broadest possible common understanding on implementation of the NLF for the marketing of products。 This Guide is intended to contribute to a better understanding of EU product rules, and to their more uniform and coherent application across different sectors and throughout the single market。 It is addressed to the Member States and others who need to be informed of the provisions designed to ensure the free circulation of products, as well as a high level of protection throughout the Union (e。g。 trade and consumer associations, standardization bodies, manufacturers, importers, distributors, conformity assessment bodies and trade unions)。

Columbia – 900 MHz Band for UHF RFID Devices to be Reduced Later in 2016

Columbia’s National Spectrum Agency, Agencia nacional de espectro (ANE) recently held a public consultation requesting comments regarding the restriction of the 900 MHz band from 902-928 MHz to 915-928 MHz in Colombia. The ANE cites the cause of this band restriction as a need to limit interference caused to mobile phone services in Colombia.

ANE has advised that it is currently in the process of creating a resolution, due to be published in the upcoming months, confirming the restriction in the 900 MHz band, however a specific date for the formal implementation of the restriction is unknown。

All new Type Approvals in Colombia, particularly in the case of UHF RFID devices operating within the 902-928 MHz frequency band, will have to comply with the new frequency band restriction of 915-928 MHz.

Colombia – Expanding Scope of Devices that Require Type Approval

The Colombia Regulator, Comisión de Regulación de Comunicaciones斗地主达人 (CRC) has recently announced its intention to expand the scope of devices requiring Type Approval. With regard to mobile terminals (including cellular modules), currently voice-only cellular devices must obtain Type Approval, however, the CRC has plans to change this requirement later this year to enforce mandatory Type Approval for data-only cellular devices, however a specific date for the release of the updated regulation detailing this change is currently unknown. For data-only cellular devices which are already in the Colombian market, the updated regulation is not expected to be retroactive, and the import and sale of these devices can continue, however we are seeking clarification on this point. It is still to be confirmed whether the Type Approval procedure for data-only cellular devices will be the same as that of voice-only cellular devices.

Taiwan Bureau of Standards, Metrology and Inspection (BSMI) – New Marking Requirements for Information, Communication and Consumer Electronic Products with a Screen Display

On April 1, 2016, Taiwan BSMI announced new marking requirements concerning information, communication and consumer electronic products with a screen display, which will come into effect on September 1, 2016 for all new applications. No immediate action will be required for products already approved by BSMI, however it is yet to be confirmed by BSMI whether the renewal applications submitted after September 1, 2016 should comply with new requirements. The new requirement introduces bare minimum content of the “Warning” and “Notice” as listed below:

  • Warning content must include:
    Warning Message: 使用過度恐傷害視力.
  • Mark Location: product itself, user manual or outer packaging.
  • Mark Method: stamp, sticker, display automatically when powering on, etc.
  • Font Size: it is recommended to use font with length and width no less than 2mm; however, for products with a maximum surface area less than 80 square centimeters, the length and width can be less than 2mm.

  • Notice content must include:
    Attention Messages:
    使用30 分鐘請休息10 分鐘.
    未滿2 歲幼兒不看螢幕,2 歲以上每天看螢幕不要超過1 小時.
  • Mark Location: Use manual or outer packaging.
  • Mark Method: Stamp, sticker, display automatically when powering on, etc.
  • Font Size: it is recommended to use font with length and width no less than 2mm; however, for products with the maximum surface area less than 80 square centimeters, the length and width can be less than 2mm.

For information only, the translation of the above text is as follows:

  1. Warning Message: The excessive use of this product might damage vision.
  2. Attention Messages:
    Please take a 10 minute rest if using device for more than 30 minutes.
    Please avoid allowing use of device for children under 2 years old; for children who are older than 2 years, use should not exceed one hour.

Papua New Guinea – New Standards Released for Review

Papua New Guinea’s National Information & Communications Technology Authority (NICTA) has recently launched a public consultation on the following ICT technical standards and specifications:

  1. Technical Guideline for WiMax Technology;
  2. Technical Standards for Operation of V-SAT & Ancillary Equipment;
  3. Type Approval Standards for Wireless Broadband Access Equipment;
  4. Type Approval Standards for Wireless Local Area Network Equipment;
  5. EMC and Safety Requirement for ICT Equipment;
  6. Type Approval Specification for DVB-T2.

These are new standards and specifications, and do not replace any previous versions. The purpose of these technical standards and specifications is to clarify specific requirements for each technology’s type approval, frequency assignments, etc. The public consultation process has been ongoing since January 15, 2016 and a closure date has not yet been confirmed.

South Africa - SABS to Resume EMC Certifications

In May 2015, the South African Bureau of Standards (SABS) placed all EMC/EMI Approval applications on hold following an internal preliminary investigation on non‐compliance to processes and procedures. Following months of discussion on SABS potentially passing the responsibility of this certification to ICASA (The Independent Communications Authority of South Africa), ICASA has confirmed that an agreement has now been concluded with SABS regarding EMC/EMI certification. SABS will continue to administer the issuance of Certificates of Compliance (CoCs), but under a new regime. A joint media statement will be released soon to affirm the announcement and also to provide guidance on the new process.

Niger – Type Approvals Resumed

During April 2016, after a two-year suspension, the Regulatory Authority for Telecommunications and Post of Niger (ARPT) will resume the issuance of Type Approvals. Additionally, ARPT has implemented the following changes to its approval process:

  • Four approval request forms must completed by the manufacturer
  • Two samples must be submitted. The samples will be returned to the applicant at their own expense within a 6-month period following the date of the approval or the rejection.
  • The application license fee must be paid before the submission of the projects.
  • 2 months are needed for application processing.

Bhutan - New Type Approval Process

Bhutan’s regulatory authority, BICMA, recently implemented type approval certification of information and communications technology (ICT) equipment。 International applicants who intend to export their ICT equipment to Bhutan must obtain a type approval certificate for their equipment。 Type approved equipment should be affixed with a label as shown below:

斗地主达人Please note that a lot of ICT equipment, e。g。 mobile handsets, data modems, RTTE embedded in PC or laptop with output power less than 100mW, is exempted from the type approval certificate。

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