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MultiPoint Newsletter - January 2015

FCC Rule Changes for TCBs

Question: How will the rule changes in 斗地主达人FCC Report and Order FCC 14-208 that eliminate the TCB exclusion list and the “permit-but-ask” procedure affect our ability to certify our products through our TCB?

Answer: The FCC’s rule changes, in effect now, will have little impact, if any, on your ability to certify products through your TCB.

The FCC adopted new rules to “facilitate the continued rapid introduction of new and innovative products to market while ensuring that these products do not cause harmful interference to each other, or to other communications devices and services.”

Under the new rules, the FCC no longer accepts applications for RF equipment certification and instead permits the TCBs to process and grant all applications for certification per the new “pre-approval guidance procedure”.

All of the items that were on the exclusion list or considered under the “permit-but-ask” procedure are now addressed in the pre-approval guidance procedure in which the FCC Office of Engineering Technology (OET) identifies the types of devices or types of testing that require TCBs to consult with the OET before issuing the grant of certification。

Under the new rules your TCB will do the following:

  • Perform an initial review of your application and determine if any issues exist that require FCC guidance;
  • Contact the FCC to obtain guidance;
  • Review the application in accordance with the FCC's guidance to determine whether the equipment complies with the appropriate FCC rules;
  • Electronically submit all exhibits to the FCC, which may include a recommendation to grant or dismiss the application;
  • Under the new procedures, your TCB has the specific authority, consistent with the current FCC policies under , to dismiss certification applications, amending the rules by uniformly employing the phrase “set aside” to describe such action by the TCB. Some reasons for dismissal include failure to comply with the FCC rules, failure to comply with a request for additional information or test samples, or a request by the applicant. TCBs only have authority to set aside those applications that have been submitted to them, not those submitted to other TCBs;
  • Similarly, TCBs only have authority to set aside grants of certification that they have issued within the prior 30 days, and not those granted by other TCBs.

Under the new rules, the FCC OET may take the following actions:

  • Conclude that the TCB should issue the grant of certification;
  • Advise that additional information or equipment testing is required;
  • Indicate that the equipment cannot be approved because it does not comply with the FCC rules;
  • Require a sample device submission for pre-grant testing to confirm compliance with the pre-approval guidance procedure.

FCC Report and Order FCC 14-208 includes other changes for TCBs and test laboratories as well, some of which are summarized in the Standards Update section of this edition。


Giveaway Devices and Waiver of Importation Requirements

Question:斗地主达人 We design small electronic radio devices that we use as promotional gifts to clients. We have the following questions:

  1. Since we do not market our devices but instead give them away for free, do our devices require FCC authorization?
  2. We want to import uncertified electronic devices for evaluation and demonstration purposes only. The devices will not be marketed or sold in the U.S. What are the FCC importation requirements in such a case?

Answer:

  1. The FCC equipment authorization rules and regulations include some exclusions and exemptions, based on the product characteristics and intended operating environment. Please refer to , Importation of Devices Capable of Causing Harmful Interference and Exempted Devices, to see if your devices are excluded or exempt from FCC authorization. We would also strongly recommend that you review Marketing of radio frequency devices prior to equipment authorization, and Operation of radio frequency devices prior to equipment authorization, for the specific circumstances and criteria under which RF devices may be marketed and operated.
  2. The FCC does allow uncertified devices to be imported for evaluation and demonstration under strict guidelines. Subpart K, Importation of Devices Capable of Causing Harmful Interference, provides a thorough explanation of the importation rules and regulations, and should be a valuable resource. Based on the few details provided, unless listed under Exclusions in §2.1202, your specific situation may be addressed by .

If your situation does not meet the Import Conditions in §2.1204, you will need to submit a request to the FCC for the waiver of importation requirements, with detailed information and justification. The request should be submitted to the FCC well in advance of the importation date to allow for processing, review, and response.

To submit a waiver of importation requirements:

  1. Access the FCC Office of Engineering and Technology (OET) Laboratory Division Knowledge Database (KDB) Inquiry System at
  2. On the left side of the page, under “Site Options”, select “Submit an Inquiry”
  3. Provide the required contact information
  4. At “Inquiry Category”, First category, select “Administrative Request” and for Second category, select “Import Waiver 741304”
  5. In the Subject field enter “Import Waiver Request”
  6. Enter your inquiry. The following specific information needs to be provided to the FCC before they can review a request. The requested information may be put into a document and uploaded as an attachment.
    1. Identification of the party importing the device
    2. Identification of the party responsible for control of the device during the importation period
    3. Specific import period dates
    4. Reason the device is being imported
    5. Standard for which you are seeking the waiver
    6. Information about device for which you are seeking the importation waiver, including:
      1. a description of the device and how it is identified (e.g. model #)
      2. a description of any labelling on the device
      3. the quantity of the device you want to import
      4. Is it identical in version to a FCC certified or approved device?
    7. Appropriate statements of justification
    8. Intended plan for devices at end of the importation period
      1. Will it/they be certified or approved?
      2. Will it/they be exported or destroyed if not certified and approved?

 


Integral Antenna Connectors

Question: We would like to use a crimp-on locking antenna connector that cannot be removed without breaking either the connector or the printed circuit board (PCB) on our transmitter. Would this connector qualify as an integral antenna connector?

Answer: If the antenna is capable of being permanently locked, meaning it cannot be removed with a special tool available to end users, and end users are unable to replace the antenna under any circumstances, the crimp-on locking antenna connector would qualify as an integral antenna connector. provides the antenna requirements for an intentional radiator operating under .


Part 24 Band-Edge Measurements

Question: We are making measurement on a carrier with an emission bandwidth that is 4.5 MHz wide, 1% of this is 45 kHz. Can we use a 30 kHz resolution-bandwidth (RBW) and video-bandwidth (VBW) to perform band-edge measurements?

Answer: The FCC accepts measurements using narrower resolution bandwidths provided they sum the power from all contiguous reduced resolution bandwidths within the 1% or 1 MHz resolution specified, per .

An alternative measurement method is to add an additional correction factor of 10 Log (RBW1/RBW2) to the 43 +10 Log (P) limit. RBW1 is the narrower measurement resolution bandwidth and RBW2 is either the 1% emissions bandwidth or 1 MHz.

As stated in , the power of any emission outside of the authorized operating frequency ranges in the Broadband Personal Communication Services (see ) must be attenuated below the transmitting power (P) by a factor of at least 43 + 10 log(P) dB。

In the adjacent 1 MHz bands above and below the operating frequency, the power spectrum density limit is based on a resolution bandwidth of 1% of the emission bandwidth.

The emission bandwidth is defined as the width of the signal between two points, one above and one below the carrier center frequency of the device under test, outside of which all emissions are attenuated at least 26 dB below the transmit power. An accepted practice for measuring the 26 dB points is to use a resolution bandwidth of 1% of the emission bandwidth.

In all other bands outside of the operating frequency ranges, the power spectrum density limit is based on a frequency resolution of 1 MHz.


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:

  • - (12/19/2014) - Explosive atmospheres - Part 2: Equipment protection by pressurized enclosure "p"
  • - (1/9/2015) - Primary batteries - Part 4: Safety of lithium batteries
  • - (1/9/2015) - Luminaires - Part 2-20: Particular requirements - Lighting chains
  • - (1/9/2015) - Luminaires - Part 2-21: Particular requirements - Rope lights
  • - (1/9/2015) - Electric toys - Safety
  • - (1/16/2015) - Electromagnetic compatibility - Electrical apparatus for the detection and measurement of combustible gases, toxic gases or oxygen
  • - (1/16/2015) - Power line communication apparatus used in low-voltage installations - Radio disturbance characteristics - Limits and methods of measurement - Part 1: Apparatus for in-home use
  • - (1/16/2015) - Household and similar electrical appliances - Safety - Part 2-23: Particular requirements for appliances for skin or hair care
  • - (1/16/2015) - LED modules for general lighting - Safety specifications
  • - (1/16/2015) - Secondary cells and batteries containing alkaline or other non-acid electrolytes - Secondary lithium cells and batteries for use in industrial applications

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 2015) - Electromagnetic compatibility and Radio spectrum Matters (ERM); Wireless microphones in the 25 MHz to 3 GHz frequency range; Part 1: Technical characteristics and methods of measurement
  • - (January 2015) - Electromagnetic compatibility and Radio spectrum Matters (ERM); Wireless microphones in the 25 MHz to 3 GHz frequency range; Part 2: Harmonized EN covering the essential requirements of article 3.2 of the R&TTE Directive
  • - (January 2015) - Electromagnetic compatibility and Radio spectrum Matters (ERM); ElectroMagnetic Compatibility (EMC) standard for radio equipment and services; Part 4: Specific conditions for fixed radio links and ancillary equipment
  • - (January 2015) - Electromagnetic compatibility and Radio spectrum Matters (ERM); ElectroMagnetic Compatibility (EMC) standard for radio equipment and services; Part 6: Specific conditions for Digital Enhanced Cordless Telecommunications (DECT) equipment

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:

  • - (12/17/2014) - Specification for radio disturbance and immunity measuring apparatus and methods - ALL PARTS
  • - (12/17/2014) - Electroacoustics - Audio-frequency induction loop systems for assisted hearing - Part 1: Methods of measuring and specifying the performance of system components
  • - (12/17/2014) - Amendment 1 - Electroacoustics - Audio-frequency induction loop systems for assisted hearing - Part 1: Methods of measuring and specifying the performance of system components
  • - (12/17/2014) - Specification for radio disturbance and immunity measuring apparatus and methods - Part 1-5: Radio disturbance and immunity measuring apparatus - Antenna calibration sites and reference test sites for 5 MHz to 18 GHz
  • - (12/17/2014) - Specification for radio disturbance and immunity measuring apparatus and methods - Part 1-6: Radio disturbance and immunity measuring apparatus - EMC antenna calibration
  • - (1/16/2015) - Explosive atmospheres - Part 10-2: Classification of areas - Explosive dust atmospheres
  • - (1/14/2015) - Corrigendum 1 - Electric and magnetic field levels generated by AC power systems - Measurement procedures with regard to public exposure

See for additional information。

FCC – Rule Amendments in Report and Order FCC 14-208

As stated previously in the Q/A section of this edition, on December 30, 2014, the FCC released Report and Order FCC 14-208, Amendment of Parts 0, 1, 2, and 15 of the Commission's Rules regarding Authorization of Radiofrequency Equipment and Amendment of Part 68 regarding Approval of Terminal Equipment by Telecommunications Certification Bodies. In this Report and Order, the FCC updated its radiofrequency (RF) equipment authorization program to build on the success realized by Telecommunications Certification Bodies (TCBs). In addition to the changes already summarized in the Q/A, in this Report and Order the FCC:

  • Clarifies a TCB's responsibilities in performing post-market surveillance of products it has approved;
  • Specifies steps for addressing instances of deficient TCB performance, including appropriate sanctions for deficiencies that do not warrant rescinding a TCB's authority to issue a grant of Certification;
  • Modifies the rules to reference new standards used to accredit TCBs that approve RF equipment under Part 2 of the FCC's rules and terminal equipment under Part 68;
  • Requires accreditation of all laboratories that test equipment subject to any of the certification procedures under Part 2 of the FCC's rules, and codifies a procedure through which the FCC currently recognizes new laboratory accreditation bodies;
  • Updates references to industry measurement procedures in the FCC rules, and provides greater flexibility under the OET’s existing delegated authority to enable it to address minor technical issues that may arise when updating to the latest versions of industry standards that are referenced in Parts 2, 5, 15, and 18.

EU – EN 300 328 V1.8.1 Effective January 1, 2015

As we reported in the November edition of MultiPoint, EN 300 328 V1.8.1 replaced EN 300 328 V1.7.1 as a harmonized standard effective January 1, 2015. The standard has been extensively overhauled; there are numerous differences between EN 300 328 V1.7.1 and EN 300 328 V1.8.1, with changes to both the test requirements and methodology. Manufacturers must fully comply with EN 300 328 V1.8.1 and will no longer be able to test using a combination of EN 300 328 V1.7.1 and the Adaptivity and Receiver Blocking clause from V1.8.1.

As a reminder, EN 300 328 V1.8.1 can be found and a marked-up pdf document that shows the differences between V1.7.1 and V1.8.1 can be found .

Canada – E-Filing Type Approval Offline for Two Weeks

Canada's Certification and Engineering Bureau (CEB) is in the process of updating their current online E-filing application system to a new system, SPECTRAWeb. In order to transition to SPECTRAWeb, the CEB will shut down the existing E-Filing service for a period of two weeks, beginning February 13, 2015 and ending March 2, 2015. The CEB will be unable to receive certification/registration applications from TCBs and all other applicants during this period. Additionally, other online services such as "Test Site Registration" and "Company Number Request" will not be available during this period.

In conjunction with the transition to SPECTRAWeb, the current IC account registration system will be decommissioned, and those individuals who are currently identified as the primary contact for companies registered with IC/CEB will receive a “Shared Secret” via email in mid-January 2015, with instructions for creating an account within the SPECTRAWeb application, etc。 Companies registered with IC/CEB includes: applicants, TCBs, test laboratories, agents, Canadian representatives, manufacturers, etc。

Ecuador – New Safety Requirements

On November 7, 2014, Ecuador published Resolution No. 14 460 in its Official Journal No. 370, requiring safety compliance certification for printing and digitization equipment imported into Ecuador. Specifically, mains-powered (not exceeding 600 V) scanners, printers, photocopiers and fax machines are now subject to safety compliance certification.

Congo – Samples Now Required for Type Approval

As of January 1, 2015, Congo's Agence de Regulation des Postes et des Communications Electroniques (ARPCE) requires that one sample be submitted along with each Type Approval application。 In some cases, a waiver may be requested if there is a size constraint/restriction in transporting the sample。 Previously, the Type Approval process for Congo did not require a sample, and was a paperwork effort only, with appropriate test reports to EU standards。

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