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MultiPoint Newsletter - February 2013

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.


Every 10 years or so, the FCC proposes and implements changes to its rules and regulations in order to keep up with the innovation and growth in wireless telecommunications and to streamline its operations and equipment authorization processes to enable new products to reach the marketplace sooner。 The FCC recently published two documents, a NOTICE OF PROPOSED RULEMAKING (NPRM), , with proposed changes to FCC Part 2, and a REPORT & ORDER (R&O), FCC , to promote expanded opportunities for radio experimentation and market trials。 This month’s edition of Multipoint addresses some of the questions asked by our readers in response to NPRM FCC 13-19A1 and R&O FCC 13-15A1, both of which are extremely relevant to our industry。

Accredited & Listed Test Laboratories

Question: In its Notice of Proposed Rule Making (NPRM) FCC 13-19A1, released on February 15th, 2013, the FCC is proposing to terminate “listed laboratories”. What is a “listed laboratory”, and how will this termination affect laboratories and manufacturers in general?

Answer: Listed laboratories and manufacturers’ laboratories do not need accreditation under ISO/IEC (International Organization for Standardization/International Electrotechnical Commission) 17025 Standard “General Requirements for the Competence of Calibration and Testing Laboratories". Instead, they are required to file documents with the FCC in accordance with the requirement of . The documents must include a physical description of their test sites, photographs, drawings, an equipment list, and calibration and site attenuation data in accordance with ANSI C63.4-2001. After the FCC reviews and accepts the laboratory’s 47CFR§2.948 documentation, it maintains a list of the (unaccredited) laboratories, hence the reference to “listed laboratories”.

Under current FCC rules and regulations, listed laboratories can test devices that are subject to certification or verification, or other FCC rule parts in the licensed services, but not devices that are subject to DoC under and . Only accredited laboratories can test and devices subject to DoC.

斗地主达人Accredited laboratories must demonstrate compliance with ISO/IEC 17025 through on-site assessments by an Accrediting Body (AB). The on-site assessments are typically conducted once each year or once every two years. While on-site at the laboratory, the AB assessors audit its quality system, measurement test procedures, equipment, calibration records, test personnel capabilities, etc. If the on-site assessment results prove that the laboratory meets ISO/IEC 17025, the AB submits the required information to the FCC and the laboratory is accredited.

If and when the FCC’s proposal to end “listed laboratories” is incorporated into its rules, all listed laboratories, and manufacturers’ laboratories, will be required to obtain ISO/IEC 17025 accreditation, and the list of the accredited laboratories will be made available。 The FCC Office of Engineering Technology (OET) must recognize all ABs responsible for accrediting test laboratories。 If the FCC does not recognize an AB, the test laboratories it assesses may not be accredited。

It is not clear at this time if the FCC would provide an immediate cut-off date for listed laboratories, or provide a “grace period” during which listed laboratories must be accredited。 Depending on the implementation of the FCC proposed rule change, you may be forced to find a different, accredited laboratory, or your current laboratory may have sufficient time to be accredited by a recognized AB。

Scope of Accreditation

Question: As a manufacturer with products that include many FCC unlicensed and licensed services, we are wondering, under the proposed rule changes, if the FCC will require that a test laboratory only test equipment that is detailed on its scope listing?

Answer: 斗地主达人The FCC is proposing that all test laboratories obtain accreditation based on ISO/IEC 17025, “General Requirements for the Competence of Calibration and Testing Laboratories". A test laboratory’s scope must list each type of equipment for which it has been assessed and found competent to perform testing under the FCC certification, verification, and DoC rules for both unlicensed and licensed services. If your product offering is subject to many unlicensed and licensed rule parts, you have to make sure your test laboratory’s scope covers the test methods and test requirements for the equipment for which you are seeking FCC certification, verification, and DoC.

Test Laboratories & MRA

Question: As a global manufacturer, our products are tested in many different countries for compliance with FCC rules and regulations. How will the FCC’s proposed changes impact test laboratories outside the U.S.?

Answer: 斗地主达人The FCC proposes listing accredited laboratories located outside the U.S., on the following conditions:


  • A government-to-government Mutual Recognition Agreement/Arrangement (MRA) exists between the U.S. and the country in which the test laboratory is located.
  • The country’s designated regulatory authority has approved the accredited test laboratory, and the FCC recognizes the foreign designated regulatory authority under the terms of the MRA.
  • If the test laboratory is in a country that does not have a MRA with the United States, then the test laboratory’s Accrediting Body must be recognized by the FCC under the provisions of its proposed new rule §2.948(e)(2) (Selection of laboratory accreditation bodies), for performing accreditations in the country where the laboratory is located.

OATS Compliance Testing License

Question: The FCC recently released a Report and Order (R&O) on Experimental Radio Services (ERS) that requires test laboratories to have a compliance testing experimental radio license for Open Area Testing Sites (OATS). Can you elaborate on this point and briefly comment on the R&O as well?

Answer: On January 13, 2013 the FCC published R&O FCC 13-15A1 on ERS that provides guidelines for all types of experimentation and consolidates rules for broadcasting experiments into a new subpart within 47CFR§5. The FCC eliminated developmental licensing rules in several of its rule parts so that all experimental authority will be under its 47CFR§5 Rules.

In addition, the R&O creates a compliance testing experimental radio license that will be available to FCC-recognized test laboratories that perform compliance testing on radio frequency devices under its equipment authorization program for certification purposes, as well as to other test laboratories that the FCC finds has sufficient expertise to undertake such testing.

A compliance testing experimental radio license will be issued to FCC-recognized laboratories under to perform the following:

  • product testing of radio frequency equipment, and
  • testing of radio frequency equipment on an Open Area Test Site.

The authority of a compliance testing experimental radio license is limited to only those testing activities necessary for product certification (including antenna calibration, test site validation, proficiency testing, and testing on an Open Area Test Site); i.e., compliance testing experimental radio licensees are not authorized to conduct immunity testing. A compliance testing experimental radio license is not required if the radio frequency device is fully contained in an anechoic chamber or a Faraday cage.

The R&O also expands opportunities for market trials by adopting a new subpart within the ERS rules that contains provisions for product developmental trials, as well as market trials, and modifies the rules to clarify when operating or marketing radio frequency devices is permitted prior to equipment certification, including the number of devices that can be imported for such purposes.

Imported radio frequency products are limited to quantities of 4,000 or fewer units for testing and evaluation to determine compliance with the FCC rules and regulations, product development, or suitability for marketing. The products are not to be offered for sale or to be marketed.

Please note that in accordance with Section V, paragraph 169 ORDERING CLAUSES of R&O FCC 13-15A1, §5.501-§5.505 Subpart G, compliance testing experimental radio licenses will take effect 30 days after publication of a summary of this R&O in the Federal Register.

Standards Updates


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

  • - (1/18/2013) - Household and similar electrical appliances - Safety - Part 2-6: Particular requirements for stationary cooking ranges, hobs, ovens and similar appliances
  • - (1/18/2013) - Medical electrical equipment - Part 2-22: Particular requirements for basic safety and essential performance of surgical, cosmetic, therapeutic and diagnostic laser equipment
  • - (1/18/2013) - Medical electrical equipment - Part 2-66: Particular requirements for the basic safety and essential performance of hearing instruments and hearing instrument systems
  • - (1/25/2013) - Desktop and notebook computers - Measurement of energy consumption
  • - (1/25/2013) - Low voltage surge protective devices - Part 21: Surge protective devices connected to telecommunications and signalling networks - Performance requirements and testing methods
  • - (1/25/2013) - Magnetic materials - Part 11: Method of test for the determination of surface insulation resistance of magnetic sheet and strip
  • - (1/25/2013) - Lamp controlgear - Part 1: General and safety requirements
  • - (2/1/2013) - Safety of machinery - Functional safety of safety-related electrical, electronic and programmable electronic control systems
  • - (2/1/2013) - LED modules for general lighting - Safety specifications
  • - (2/8/2013) - Double-capped fluorescent lamps - Safety specifications
  • - (2/8/2013) - Household and similar electrical appliances - Safety - Part 2-7: Particular requirements for washing machines
  • - (2/8/2013) - LCD backlight unit - Part 2: Electro-optical measurement methods of LED backlight unit
  • - (2/8/2013) - Methods of measurement for digital network - Performance characteristics of terrestrial digital multimedia transmission network

See CENELEC for additional information.


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

  • - (January 2013) - Electromagnetic compatibility and Radio spectrum Matters (ERM); Digital Mobile Radio (DMR) General System Design
  • - (February 2013) - LTE; Evolved Universal Terrestrial Radio Access (E-UTRA); Electromagnetic compatibility (EMC) requirements for mobile terminals and ancillary equipment (3GPP TS 36.124 version 11.2.0 Release 11)
  • - (February 2013) - LTE; Evolved Universal Terrestrial Radio Access (E-UTRA); Base Station (BS) and repeater ElectroMagnetic Compatibility (EMC) (3GPP TS 36.113 version 11.2.0 Release 11)

Seeor additional information。


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

  • - (1/16/2013) - Medical electrical equipment - Part 2-11: Particular requirements for the basic safety and essential performance of gamma beam therapy equipment
  • - (1/25/2013) - Household and similar electrical appliances - Test code for the determination of airborne acoustical noise - Part 2-14: Particular requirements for refrigerators, frozen-food storage cabinets and food freezers
  • - (1/25/2013) - Corrigendum 1 - Reliability testing - Compliance tests for constant failure rate and constant failure intensity
  • - (1/29/2013) - Summary of requirements and tests for products in the scope of IEC 60601-2-66
  • - (1/30/2013) - Safety of machinery - Electro-sensitive protective equipment - Part 2: Particular requirements for equipment using active opto-electronic protective devices (AOPDs)
  • - (2/5/2013) - Corrigendum 1 - Household and similar electrical appliances - Safety - Part 2-9: Particular requirements for grills, toasters and similar portable cooking appliances
  • - (2/6/2013) - Connectors for electronic equipment - Tests and measurements - Part 28-100: Signal integrity tests up to 1 000 MHz on IEC 60603-7 and IEC 61076-3 series connectors - Tests 28a to 28g
  • - (2/6/2013) - Mechanical structures for electronic equipment - Tests for IEC 60917 and IEC 60297 - Part 3: Electromagnetic shielding performance tests for cabinets and subracks
  • - (2/6/2013) - Environmental testing - Part 2-65: Tests - Test Fg: Vibration - Acoustically induced method

See IEC for additional information.

EU - Product Safety and Market Surveillance

Recently, the European Commission (EC) proposed new legislative and non-legislative measures to improve consumer product safety and strengthen market surveillance of all non-food products in the European Union (EU), including those imported from third countries.

The package was adopted by the EC on February 13, 2013, and will be discussed in the European Parliament and in the Council, and is expected to come into effect in 2015.

The main elements of the proposal are:

  • Alignment of the general obligations of economic operators to ensure the safety of all consumer products with clearer responsibilities for manufacturers, importers and distributors.
  • More effective tools to enforce safety and other product-related requirements and to take action against dangerous and non-compliant products across all sectors through a single set of coherent rules for market surveillance.
  • Improved traceability of consumer products throughout the supply chain - enabling a swift and effective response to safety problems (e.g. recalls).
  • Creation of a more cooperative system of market surveillance across the EU.
  • Streamlined procedures for the notification of dangerous products, and synergies between the existing Rapid Alert Information System (RAPEX) and the Information and Communication System for Market Surveillance (ICSMS).

When adopted by the European Parliament and by the Council, the new rules will be enforced by the national market surveillance authorities in the Member States which will benefit from strengthened cooperation and enhanced tools to carry out controls。

India - Safety Approval Scheme

India’s Ministry of Communications and Information Technology (MCIT) recently announced the Electronics and Information Technology Goods Order (Requirements for Compulsory Registration), which is expected to go into effect on March 7, 2013.

The Order requires that certain electronic products imported to, manufactured in, stored, distributed or sold in India must conform to the Indian safety standards and these products must then be registered as compliant。

Prior to registering products, manufacturers/importers/distributors must first register themselves with the Bureau (Department of Electronics and Information Technology, of the Ministry of Communications and Information Technology, Government of India).

Compliant products must bear the mark “Self Declaration - Conforming to IS xxxxxx” on the product or its packaging. Where the product is not packaged and it is impractical to mark the product, the marking can be placed on a Test Certificate relating to the product.

The scheme currently includes a provision for samples of product (or product family) to be drawn and tested to ensure compliance on a regular basis (once every two years)。

Additionally, samples of product must be tested every two years to ensure compliance on an ongoing basis.

Brazil - ANATEL Enforcement of Labeling

Recently we have learned that Brazil’s ANATEL is more strictly enforcing their labeling guidelines for small products。

ANATEL Resolution 242 (with label guidelines) has not changed, but in the past, ANATEL accepted placement of the ANATEL label (and interference/SAR mandatory statements in Portuguese) in the User Manual for smaller sized products if a “labeling declaration” was obtained from ANATEL to utilize this method.

Currently, all labeling declarations are being rejected by ANATEL, even for products with dimensions of 5 cm and less.  New approval applications are being affected by this process change, however previously approved imports may be impacted as well.

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