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MultiPoint Newsletter - February 2014

Software Drivers & Split Modular Requirements

Question:斗地主达人 We manufacture modular transmitters; our module software drivers reside on hosts that incorporate our modular transmitters. Our clients informed us that as a result of hosting our module’s software drivers on their final products, their FCC applications for certification have to meet the FCC split-modular requirements. Can you provide an explanation as to why?

Answer: Software drivers for modular transmitters can control different aspects of the modules themselves. For example, if your software drivers control your module’s transmit power, modulator circuitry and/or frequency of operation including other radio frequency parameters specified in , then the combination may be considered a split-modular transmitter.

If your software drivers do not modify the radio frequency parameters of your modules when your clients integrate them into their hosts, they should not be subject to the FCC’s split-modular transmitter requirements. We suggest that you “Submit an Inquiry” to the Knowledge Database detailing the operation of your module and its software driver(s) to help determine if the split-modular requirements apply in your case.

Transition Date Extended for Wi-Fi Clients Transmission on Channels 12 & 13

Question: You reported in your September 2013 MultiPoint newsletter that starting in March 2014, Wi-Fi client devices utilizing only passive scanning operating on Channels 12 and 13 must ensure compliance with all the emission requirements in the FCC rules and regulations. Is this date still valid?

Answer: The FCC has extended the March 31, 2014 deadline to September 1, 2014, after considering additional information provided by many parties, and receiving comments to draft 斗地主达人KDB Publication 594280.

As a reminder of the issue, we have provided a recap of the September 2013 MultiPoint article to which you are referring:

“Wi-Fi clients that transmit on Channels 12 and 13 must meet all of the emission requirements specified in 47CFR§15.247 for that band. If the client does not meet these requirements, these channels must be disabled.

Wi-Fi client devices typically contain active or passive roaming circuitry algorithms that are proprietary and not part of 802.11 Wi-Fi protocols. This on-roam scanning may use active or passive scanning to determine if a master transmits on Channels 12 and 13. In these cases, the Wi-Fi client device must still be able to determine that the master is transmitting in a manner compliant with the FCC rules and regulations.

Many Wi-Fi clients rely on the access point to ensure proper operation. Thus, some changes will be required for these devices to operate in compliance in all circumstances. In recognition of the need for changes, and the time required to implement the changes, the FCC is permitting a transition period until March 31, 2014 to ensure that all new device approvals are consistent with the requirements, and where appropriate, changes are made to currently approved products. During this transition period, devices that rely on scanning circuitries may be approved, but the FCC is encouraging manufacturers to implement revisions as quickly as possible.

To obtain approval for transmitting on Channels 12 and 13, your test report would need to clearly show that Channels 12 and 13 were tested and compliant. Your application filing should also specify the appropriate frequency band and the reduced output power required for radiated field strength compliance at the band edge of 2483.5 MHz.”

Population and Depopulation of a Certified Transmitter

Question:  We designed a wireless transmitter with multiple frequency bands to support both U.S. and international markets and we obtained FCC certification for it. The printed circuit board (PCB) is fully populated with transmitter components for all U.S. and international markets. Since obtaining the FCC grant, we depopulate and populate the PCB, removing and adding transmitter components to serve the various different markets. In doing so, are we in violation of the FCC rules?

Answer: Yes, you are in violation of the FCC’s rules and regulations. Your FCC certification grant covers all the hardware components (transmitter and non-transmitter alike) in the wireless transmitter certification application that was submitted and approved. Changes such as population or depopulation of transmitter components intended for the U.S. or international markets render your device non-identical to the original certified device, and therefore would require a new FCC ID in accordance with , which states that a certification is an equipment authorization issued by the Commission, based on representations and test data submitted by the applicant. Furthermore, certification attaches to all units subsequently marketed by the grantee, which are “identical” to the sample tested, except for permissive changes or other variations authorized by the Commission pursuant to .

In accordance with , the term “identical” means identical within the variation that can be expected to arise as a result of quantity production techniques. Populating and depopulating your transmitter as the situation demands makes it non-identical to the certified transmitter, and thus you are in violation of the FCC grant that was issued, and thus the FCC rules and regulations.

EU Audit of 5 GHz WLAN Products

Question: We would like to know if 5 GHz WLAN products interfere with weather radars in the European Union (EU), and would also like to know the status of any EU conducted market surveillance of 5 GHz WLAN products.

Answer: At the recent MRA Workshop in Japan on February 19, 2014, Mr. Jan Coenraads, Secretary of the Radio and Telecommunications Terminal Equipment Compliance Association (R&TTE CA) and the European Union Association of Notified Bodies (EUANB), presented the following facts on interference to weather radars by 5 GHz WLAN devices, including market surveillance results of 5 GHz WLAN products in the EU:

Interference has occurred, and is occurring, to weather radars due to 5 GHz WLAN products with disabled Dynamic Frequency Selection (DFS), whose function is meant to avoid, and not interfere with, weather radars.

The reasons that the 5 GHz WLAN products are causing interference with weather radar are as follows:

5 GHz WLAN Products are placed in the EU market with DFS, but the end user can disable the DFS functionality either with the software delivered with the product, or with software available on the Internet, which means that the 5 GHz WLAN products do not meet the essential requirement to ensure that the DFS cannot be switched off。

The R&TTE ADCO (Administrative Cooperation) group started a EU Market Surveillance Campaign for 5 GHz WLAN products in which 21 Market Surveillance Authorities (MSA) participated and 101 products were audited and tested.

Following are the audit test results:

Overall CE marking compliance 87%
Overall DoC compliance 64%
Technical Document compliance 49%
Administrative compliance 32%
Products in which DFS were not implemented 5%
Products in which DFS can by deactivated 34%
Products tested that avoided frequency bands where DFS is mandatory 35%
Products tested that are using frequency bands where the DFS system is mandatory had their DFS function implemented 95%
Products tested that can have their DFS deactivated by the user 34%
Of the 34% of the products tested that can have their DFS deactivated, the deactivation can be performed using the 5 GHz WLAN product original firmware or a firmware provided on the manufacturer’s web site 91%
The 5GHz WLANs products tested allow the possibility for the user to change the “Region of use” 59%

In summary, most 5 GHz WLAN products are being placed in the EU with DFS capability, as they should be. Unfortunately, in a substantial percentage of the cases reviewed in the audit, the end user is able to deactivate the DFS capability using the original product’s firmware, or firmware downloaded from the manufacturer, thus allowing the 5 GHz WLAN products to create interference with weather radars in the EU.

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:

  • - 1/17/2014 - General requirements for Home and Building Electronic Systems (HBES) and Building Automation and Control Systems (BACS) - Part 6-1: HBES installations - Installation and planning
  • - 1/17/2014 - Service diagnostic interface for consumer electronics products and networks - Implementation for echonet
  • - 1/17/2014 - Video surveillance systems for use in security applications - Part 2-1: Video transmission protocols - General requirements
  • - 1/24/2014 - Household range hoods and other cooking fume extractors - Methods for measuring performance
  • - 1/24/2014 - Maritime navigation and radiocommunication equipment and systems - Class B shipborne equipment of the automatic identification system (AIS) - Part 1: Carrier-sense time division multiple access (CSTDMA) techniques
  • - 2/7/2014 - Optical amplifiers - Test methods - Part 3-3: Noise figure parameters - Signal power to total ASE power ratio
  • - 2/7/2014 - Superconductivity - Part 19: Mechanical properties measurement - Room temperature tensile test of reacted Nb3Sn composite superconductors
  • - 2/14/2014 - Guidance on how to conduct Round Robin Tests

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:

  • - (January 2014) - Electromagnetic compatibility and Radio spectrum Matters (ERM); Using the EN 301 489 series of EMC standards
  • - (January 2014) - Electromagnetic compatibility and Radio spectrum Matters (ERM); System Reference Document (SRdoc); Surveillance Radar equipment for helicopter application operating in the 76 GHz to 79 GHz frequency range
  • - (January 2014) - Electromagnetic compatibility and Radio spectrum Matters (ERM); Continuous Tone Controlled Signalling System (CTCSS) and Digitally Coded Squelch Signalling (DCSS) system

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:

  • - (1/21/2014) - Primary batteries - ALL PARTS
  • - (1/24/2014) - Corrigendum 1 - Amendment 1 - Household and similar electrical appliances - Safety - Part 1: General requirements
  • - (1/21/2014) - Arc welding equipment - Part 10: Electromagnetic compatibility (EMC) requirements
  • - (1/22/2014) - Metallic communication cable test methods - Part 4-1: Electromagnetic compatibility (EMC) - Introduction to electromagnetic screening measurements
  • - (2/6/2014) - Railway applications - Communication, signalling and processing systems - Safety related communication in transmission systems
  • - (2/6/2014) - Fire hazard testing - Part 2-11: Glowing/hot-wire based test methods - Glow-wire flammability test method for end-products (GWEPT)
  • - (2/12/2014) - 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 15: Functional safety requirements for insulation monitoring devices in IT systems and equipment for insulation fault location in IT systems
  • - (2/14/2014) - Specification for radio disturbance and immunity measuring apparatus and methods - ALL PARTS
  • - (2/14/2014) - Specification for radio disturbance and immunity measuring apparatus and methods - Part 4-2: Uncertainties, statistics and limit modelling - Measurement instrumentation uncertainty
  • - (2/14/2014) - Amendment 1 - Specification for radio disturbance and immunity measuring apparatus and methods - Part 4-2: Uncertainties, statistics and limit modelling - Measurement instrumentation uncertainty
  • - (2/14/2014) - Amendment 1 - International Electrotechnical Vocabulary - Part 161: Electromagnetic compatibility; Part 732: Computer network technology; Part 851: Electric welding

See for additional information.

FCC - New Wideband Consumer Signal Booster Compliance Measurement Guidance Published

斗地主达人On 1/22/2014, the FCC published .

Additionally, the following Signal Booster documents have been published by the FCC:

  • provides guidance for classifying types of devices and applicable rules for performing compliance measurements on signal boosters operating under 47C.F.R.§20.21, 90.219, and Parts 22, 24, 27, 90; considerations for some provisions and devices under other rules is also given, e.g., Parts 2, 25, 97, 101.
  • provides certification requirements for signal boosters that operate under Parts 20, 22, 24, 27 and 90 of the FCC rules.

At this time, uniform procedures for provider-specific consumer signal boosters remain under development with the ASC C63® working group. Based on this work, a draft KDB providing guidance on performing compliance measurements for provider-specific consumer signal boosters will be released for public comment. Pending the release of final guidance, a KDB inquiry needs to be submitted seeking approval for the test procedures to be used.

FCC - New Draft Issued for Guidance on Software Configuration on Non-SDR Devices

斗地主达人On January 10, 2014, the FCC issued a new draft publication () for 。 The prior version () has been completely revised, resulting in the new draft publication。 This new draft is issued for comment only at this time; the prior guidance should be followed until the new draft is adopted。 Comments on the new draft were due to the FCC by February 14, 2014。

FCC - Upcoming Spring 2014 TCBC Workshop

The Telecommunications Certification Body Council (TCBC) will host its Spring 2014 Workshop from April 7 - 11, 2014 in Baltimore, Maryland:

  • April 7, 2014 - Day 1 – Beginner TCB Training, for newbies
  • April 8-10, 2014 - Days 2-4 – regular 3 day TCB Council Workshop
  • April 11, 2014 - Day 5 – ISO Guide 17065 Training

As indicated by the schedule, the regular 3-day Workshop event will be bracketed by a day for beginner training and a day for ISO 17065 training。 The Beginner Training day is geared for people who are new to the TCB programs, to provide a foundation of knowledge and resources to people who need to know what the TCBs do, and how to navigate the resources for information。 If you plan on attending the beginner training, or sending someone from your company, you should contact Chris Harvey (contact information below) so that he may plan accordingly。

The ISO Guide 17065 Training day is geared to go into more detail of the new ISO Guide for Certification Programs than was provided in the October 2013 Workshop.

Additional details of the agendas for these sessions will be distributed as they are available. The registration structure will allow for people to register for any or all of the Workshop programs. Please save the dates, and look for further details in the months to come. Should you have any questions, contact Chris Harvey at or call 443-622-3300.

Canada - Licensing Framework for BRS Released for Comment

On January 10, 2014, Industry Canada released , which sets out Industry Canada's decisions with respect to the auction process for spectrum licenses in the 2500 MHz band. In particular, the document announces the decisions related to the licensing process, the auction format and the auction rules, as well as the conditions of licenses applicable to the 2500 MHz band.

Industry Canada will accept written questions until April 28, 2014 seeking clarification of the rules and policies set out in the framework。 Every effort will be made to post the questions received, along with Industry Canada's responses, by August 18, 2014, depending on the volume of questions received。 Any answers provided to these questions will be considered as clarification of the policies set out in the above-mentioned SMSE-002-12 document, and as amendments or supplements to the rules set out in the framework。

Pakistan – Type Approval Process for Mobile Phones

Pakistan Telecommunication Authority (PTA) recently implemented Type Approval requirements for cellular mobile phones under Section 29 of Pakistan Telecommunication Re-Organization Act, 1996, in order to protect customers' interests. Previously, mobile phones were exempt from the Type Approval process. Under the new requirement, PTA will approve mobile phones according to the standards listed below:

  • Radio Communication Standards
    • EN 301 511: V7.0.2
    • EN 301 908-1/EN 301 908-2
  • Electromagnetic Compatibility Standards
    • EN 301 489-1: V1.3.1 / V1.4.1
    • EN 301 489-7: V1.1.1 / V1.2.1
  • Safety Standards (including SAR test)
    • EN 50360/CENELEC
    • EN 50361/CENELEC
    • EN 60950
    • EN 62209-1: 2005

Malaysia - Changes to Type Approval Rules

We were recently advised by our local agent that Malaysia's has recently stated that Notebook PCs can now be considered as host devices for host approval applications. Previously, Notebook PCs could be approved in Malaysia via a modular approach, with the option to add hosts, whereby the RF radios were approved as modules and then each host device listed on the approval for the modules. However, under the new regulations, Notebook applications will now fall under the hybrid product category, meaning each Notebook PC will need to be approved in full, regardless of whether it uses modules approved in Malaysia. This new requirement is effective immediately and official regulations confirming all changes will be published shortly.

Vietnam – New Technical Standards Issued January 15th, 2014

Our local agent recently informed us that Vietnam's Type Approval Authority MIC (Ministry of Information and Communications) has implemented new technical standards beginning January 15, 2014。 The new standards impact RFID/SRD devices and radars previously approved under the QCVN47:2011 standard。

斗地主达人A summary of the changes are below (standards in blue are the new standards which replaced QCVN47:2011):

No Device Name Before 15-Jan-14 After 15-Jan-14
1 Wireless radio equipment using frequency modulation (FM) frequency band from 54MHz to 68MHz  QCVN47:2011/BTTTT    
2 Radio equipment operating on 25MHz - 1GHz  QCVN18:2010/BTTTT 
3 Radio equipment operating on 1GHz - 40GHz  QCVN18:2010/BTTTT
4 Data transmission equipment for low speed 5.8GHz specially used in the field of transportation  QCVN18:2010/BTTTT
5 Data transmission equipment for high speed 5.8GHz specially used in the field of transportation  QCVN18:2010/BTTTT

Rhein Tech Laboratories has been advised that products previously approved under QCVN54:2011 and QCVN65:2013 standards are not affected by this change as these are still valid standards for products operating on 2.4 GHz and 5 GHz. Our agent is investigating whether products previously approved under QCVN47:2011 will need to be re-approved under the new standards.

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