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MultiPoint Newsletter - December 2014

Permissive Changes & Part 15 Certified Devices

Question: As a systems engineering firm we can integrate various wireless modules into end products fairly easily; what we find most challenging is interpreting the FCC rules and regulations to determine what constitutes a Class I or a Class II permissive change. When changes to certified devices are necessary, how can we make sure we are properly interpreting, and adhering to, FCC Part 15?

Answer: We recommend that you reference the FCC permissive change policy explained in 178919 D01 Permissive Change Policy v05r04. This document describes the modifications that may be made to an RF device without filing a new equipment authorization, defines the three different types of permissive changes, and identifies when a permissive change filing is required.

With few exceptions, a new FCC ID and a new equipment authorization application will be required in the event of changes to the basic frequency determining and stabilizing circuitry (including clock and data rates), frequency multiplication stages, basic modulator circuit, or maximum power or field strength ratings.


Marketing a Device under Multiple Listings

Question: What is meant by marketing a device under multiple listings?

Answer: In the context of FCC approvals, multiple listings allow the grantee to market a device under more than one trade name or model number. From a hardware perspective, all of the multiple listing devices must be identical to the FCC-approved device.

The multiple listing practice is commonly used by transmitter module manufacturers who market devices, under multiple model numbers or trade names, to third parties who do not require their own FCC ID.

FCC governs multiple listings:

“The grantee of an equipment authorization may market devices having different model/type numbers or trade names without additional authorization from the Commission, provided that such devices are electrically identical and the equipment bears an FCC Identifier validated by a grant of equipment authorization. A device will be considered to be electrically identical if no changes are made to the device authorized by the Commission, or if the changes made to the device would be treated as class I permissive changes within the scope of 47CFR§2.1043(b)(1)”.

Changes to the model number or trade name by anyone other than the grantee, or under the authorization of the grantee, shall be performed following the procedures in .


Test Requirements for Energy-Harvesting Bluetooth Transmitter

Question: We are designing a “battery-less” Bluetooth wireless transmitter that is powered by harvesting energy from the ambient. Will this product be exempt from the FCC rules and regulations?

Answer: Your Bluetooth wireless transmitter must still adhere to but since it is powered by energy harvested from the ambient, per , no conducted emissions test is required, however the unintentional radiator portion (digital circuitry) of your device must adhere to .

Per , the following products are exempt from digital emissions testing. It must be noted that equipment is not exempt unless all of the devices in the equipment meet the criteria for exemption.

  • A digital device utilized exclusively in any transportation vehicle including motor vehicles and aircraft
  • A digital device used exclusively as an electronic control or power system utilized by a public utility or in an industrial plant. The term public utility includes equipment only to the extent that it is in a dedicated building or large room owned or leased by the utility and does not extend to equipment installed in a subscriber's facility
  • A digital device used exclusively as industrial, commercial, or medical test equipment
  • A digital device utilized exclusively in an appliance, e.g., microwave oven, dishwasher, clothes dryer, air conditioner (central or window), etc.
  • Specialized medical digital devices (generally used at the direction of or under the supervision of a licensed health care practitioner) whether used in a patient's home or a health care facility. Non-specialized medical devices, i.e., devices marketed through retail channels for use by the general public, are not exempted. This exemption also does not apply to digital devices used for record keeping or any purpose not directly connected with medical treatment
  • Digital devices that have a power consumption not exceeding 6 nW
  • Joystick controllers or similar devices, such as a mouse, used with digital devices but which contain only non-digital circuitry or a simple circuit to convert the signal to the format required (e.g., an integrated circuit for analog to digital conversion) are viewed as passive add-on devices, not themselves directly subject to the technical standards or the equipment authorization requirements
  • Digital devices in which both the highest frequency generated and the highest frequency used are less than 1.705 MHz and which do not operate from the AC power lines or contain provisions for operation while connected to the AC power lines. Digital devices that include, or make provision for the use of, battery eliminators, AC adaptors or battery chargers which permit operation while charging or that connect to the AC power lines indirectly, obtaining their power through another device which is connected to the AC power lines, do not fall under this exemption
  • Responsible parties should note that equipment containing more than one device is not exempt from the technical standards in this part unless all of the devices in the equipment meet the criteria for exemption. If only one of the included devices qualifies for exemption, the remainder of the equipment must comply with any applicable regulations. If a device performs more than one function and all of those functions do not meet the criteria for exemption, the device does not qualify for inclusion under the exemptions

47CFR§15.103 does not include the following, however if your device falls within this group, it is exempt from equipment authorization:

  • Personal use home-built devices (not kit-constructed) that are assembled in quantities of five or less
  • Low-frequency devices that don’t generate timing signals or pulses at a rate in excess of 9,000 pulses (cycles) per second (i.e., 9 kHz)

 


In-situ Testing for Liquid Propane Gas Meter Transceivers

Question: We will be seeking a Part 15 certification for our liquid propane gas (LPG) meter transceiver used only in below-ground metal, concrete, and plastic-reinforced tanks. Can we test in a typical installation instead of on an Open Area Test Site (OATS)?

Answer:斗地主达人 For your device, the FCC does typically allow in-situ measurements.

When performing the compliance tests, the receiving antenna should be placed on a mast, not on a fixed-height tripod, to allow the antenna to be raised and lowered between 1 and 4 meters, to aid in determining the maximum signal。

斗地主达人Additionally, when performing radiated emissions tests, if a continuous azimuth search cannot be made, consult ANSI C63.4 Section 8.1. Frequency scans of the field strength with both polarities of the measuring antenna must be made at a minimum of 16 azimuth angles (nominally 22.5 degrees apart) around the device.

Note that the device will only be authorized for use in below-ground tank installations, as tested and presented in the certification application。

Please also note the following:

  • The grant will include the appropriate conditions or limitations
  • Professional installation is required; the instructions must provide appropriate details for the tank transmitter installation, specify the types of tanks and lids that can be used, and provide any materials necessary to comply with the conditions of the grant.

 


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:

  • - (11/18/2014) - Household and similar electrical appliances - Safety - Part 2-30: Particular requirements for room heaters
  • - (11/21/2014) - Household and similar electrical appliances - Safety - Part 2-56: Particular requirements for projectors and similar appliances
  • - (11/21/2014) - Household and similar electrical appliances - Safety - Part 2-101: Particular requirements for vaporizers
  • - (11/21/2014) - Photovoltaic (PV) module safety qualification - Part 1: Requirements for construction
  • - (11/28/2014) - Plugs, socket-outlets, vehicle connectors and vehicle inlets - Conductive charging of electric vehicles - Part 3: Dimensional compatibility and interchangeability requirements for d.c. and a.c./d.c. pin and contact-tube vehicle couplers
  • - (12/5/2014) - Radiation protection instrumentation - Radon and radon decay product measuring instruments - Part 3: Specific requirements for radon decay product measuring instruments
  • - (12/5/2014) - Discharge lamps (excluding fluorescent lamps) - Safety specifications
  • - (12/12/2014) - Power line communication apparatus used in low-voltage installations - Radio disturbance characteristics - Limits and methods of measurement - Part 1: Apparatus for in-home use

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:

  • - (November 2014) - Reconfigurable Radio Systems (RRS); Radio Reconfiguration related Requirements for Mobile Devices
  •  - (November 2014) - Electromagnetic compatibility and Radio spectrum Matters (ERM); Maritime low power personal locating devices employing AIS; Part 2: Harmonized EN covering the essential requirements of article 3.2 of the R&TTE Directive
  •  - (November 2014) - Electromagnetic compatibility and Radio spectrum Matters (ERM); System Reference document (SRdoc); Technical characteristics and spectrum requirements of wideband SRDs with advanced spectrum sharing capability for operation in the UHF 870 - 876 MHz and 915 - 921 MHz frequency bands
  •  - (December 2014) - Fixed Radio Systems; Characteristics and requirements for point-to-point equipment and antennas; Part 2-1: System-dependent requirements for digital systems operating in frequency bands where frequency co-ordination is applied
  • - (December 2014) - Electromagnetic compatibility and Radio spectrum Matters (ERM); Wideband transmission systems; Data transmission equipment operating in the 2,4 GHz ISM band and using wide band modulation techniques; Harmonized EN covering the essential requirements of article 3.2 of the R&TTE Directive
  •  - (December 2014) - Electromagnetic compatibility and Radio spectrum Matters (ERM); Radio Frequency Identification Equipment operating in the band 865 MHz to 868 MHz with power levels up to 2 W and in the band 915 MHz to 921 MHz with power levels up to 4 W; Part 1: Technical requirements and methods of measurement
  •  - (December 2014) - Electromagnetic compatibility and Radio spectrum Matters (ERM); Radio Frequency Identification Equipment operating in the band 865 MHz to 868 MHz with power levels up to 2 W and in the band 915 MHz to 921 MHz with power levels up to 4 W; Part 2: Harmonized EN covering the essential requirements of article 3.2 of the R&TTE Directive

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:

  • - (11/25/2014) - Luminaires - Part 2-21: Particular requirements - Rope lights
  • - (11/25/2014) - Dynamic modules - Part 5-1: Test methods - Dynamic gain tilt equalizer - Gain tilt settling time measurement
  • - (11/25/2014) - Secondary cells and batteries containing alkaline or other non-acid electrolytes - Secondary lithium cells and batteries for use in industrial applications
  • - (11/25/2014) - Luminaire performance - Part 2-1: Particular requirements for LED luminaires
  • - (11/27/2014) - Electrostatics - Part 4-8: Standard test methods for specific applications - Electrostatic discharge shielding - Bags
  • - (11/27/2014) - Conformity assessment -- Requirements for bodies providing audit and certification of management systems -- Part 6: Competence requirements for auditing and certification of business continuity management systems
  • - (12/11/2014) - Amendment 51 - Lamp caps and holders together with gauges for the control of interchangeability and safety - Part 1: Lamp caps
  • - (12/11/2014) - Electroacoustics - Hearing aids - Part 4: Induction-loop systems for hearing aid purposes - System performance requirements
  • - (12/11/2014) - Electroacoustics - Simulators of human head and ear - Part 3: Acoustic coupler for the calibration of supra-aural earphones used in audiometry
  • - (12/11/2014) - Luminaires - Part 2-20: Particular requirements - Lighting chains
  • - (12/11/2014) - Electrical safety in low voltage distribution systems up to 1 000 V a.c. and 1 500 V d.c. - Equipment for testing, measuring or monitoring of protective measures - Part 8: Insulation monitoring devices for IT systems
  • - (12/11/2014) - Electrical safety in low voltage distribution systems up to 1 000 V a.c. and 1 500 V d.c. - Equipment for testing, measuring or monitoring of protective measures - Part 9: Equipment for insulation fault location in IT systems
  • - (12/11/2014) - Electrical safety in low voltage distribution systems up to 1 000 V a.c. and 1 500 V d.c - Equipment for testing, measuring or monitoring of protective measures - Part 16: Equipment for testing the effectiveness of the protective measures of electrical equipment and/or medical electrical equipment
  • - (12/11/2014) - Measurement of DC magnetic, AC magnetic and AC electric fields from 1 Hz to 100 kHz with regard to exposure of human beings - Part 2: Basic standard for measurements
  • - (12/12/2014) - Explosive atmospheres - Part 18: Equipment protection by encapsulation "m"
  • - (12/3/2014) - Process management for avionics - Atmospheric radiation effects - Part 6: Extreme space weather and potential impact on the avionics environment and electronics

斗地主达人See for additional information.

Armenia – Customs Union Membership effective 1/1/2015

On October 10, 2014, Armenia signed "" and will become a member of the Customs Union (CU) effective January 1, 2015。 The transition period from the National Type Approval scheme to the Customs Union scheme and the full impact have not yet been advised, however the Eurasian Commission is currently working on harmonization efforts of EMC and Safety standards。 It is possible CU Approval will be recognized by Armenian customs on January 1st, 2015; but until further notice, National Level Type Approvals will still be required in Armenia。 Additionally, please be aware RF compliance is still to be determined by National Regulators。

Egypt – License-Free 5 GHz Band (indoor use only)

The Egyptian Authority (NTRA) recently advised that WLAN devices operating in Band 4 and Band 4+ of the 5 GHz band may now operate indoors only, up to 200 mW EIRP, on a license-free basis.

The 5 GHz bands now permitted in Egypt are as follows:

  • 5150 - 5350 MHz - <200mW (EIRP) for indoor operation, license-free.
  • 5725 - 5850 MHz - <200mW (EIRP) for outdoor operation, license required.

Uruguay: WLAN Band is Closed

During late November 2014, we were informed by our local agent that the Uruguayan Authority, Unidad Reguladora de Servicios de Comunicaciones (URSEC), will no longer permit the 5.470 - 5.725 GHz WLAN band for future commercial products. The band has been assigned for government use only. We were also advised that any products with existing URSEC Type Approval operating in this band may continue to operate and no further action is required. For any new products requiring URSEC Type Approval in the 5 GHz band, master devices must have the restricted band disabled and client devices must be set to passive scanning mode only (no active scanning is allowed); Ad Hoc mode is allowed.

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