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MultiPoint Newsletter - July 2013

Grant Note Restrictions for Wireless Modules

Question: We manufacture wireless transmitters that integrate other wireless modules from OEM vendors.  We were recently informed that we could not integrate an OEM wireless module into our end product because of the following grant note:

“The antenna(s) used for this transmitter must be installed to provide a separation distance of at least 20 cm from all persons and must not transmit simultaneously with any other antenna or transmitter, except in accordance with FCC multi-transmitter product procedures.”

Can you provide an explanation as to why we could not integrate this OEM module?

Answer:  Grant notes are utilized to clearly state any FCC restrictions on the use or implementation of the granted device, in this case the parameters for integration of the OEM wireless module.  The grant notes strictly prohibit module integration in multi-transmitter configurations that generate simultaneous transmission, and in portable configurations (used less 20 cm from a person).

If you can configure your end product so that only one transmitter transmits at a time and there is no simultaneous transmission, and it is a mobile or fixed device (used greater than 20 cm from a person), you would not be in violation of the restrictions.

If your end product requires simultaneous transmission and is a mobile or fixed device, you can pursue the following options:

  • Search for another module to integrate that does not have a grant note restriction on simultaneous transmission.
  • Ask your OEM vendor to perform co-location testing with all transmitters operating, and to perform a Class II Permissive Change indicating the allowed co-located transmitters.  RF exposure must also be addressed, typically via a Maximum Permissive Exposure (MPE) evaluation covering all transmitters.

If your end product requires simultaneous transmission and is a portable device, you can pursue the following options:

  • Ask your OEM vendor to perform Specific Absorption Rate (SAR) testing on your end product with their module installed, and to perform a Class II Permissive Change indicating that your specific portable configuration is authorized. 

Going forward, before committing to the integration of any OEM module, we advise you to first carefully review the FCC grant notes for the module under consideration in order to determine any FCC restrictions.  This due diligence prior to module selection will eliminate wasted effort, improve time to market, and save money.

For more information on this and other FCC permissive change policies that affect wireless modules in particular, please click here.

Additional information on RF exposure issues related to modules can be reviewed by clicking on the link here.  

Class II Permissive Change for Wireless Module Integration

Question: We are integrating a licensed 1.5 watt EIRP wireless module with an unlicensed 100 mW EIRP Wi-Fi module into a host device.  The FCC grant for each module restricts co-location and simultaneous transmission, therefore we need to apply for a Class II Permissive Change (C2PC).  Do we file a C2PC only for the module with the highest transmitting power, or do we need to file C2PC’s for both modules?

Answer: Because both modules have grant note restrictions, a C2PC will be required for each module.  Before a C2PC can be submitted, SAR and MPE, whichever is applicable, must be addressed. 

Please note that C2PC applications have to be submitted by the grantee code holder (grantee) for each module.  When you contact the grantees for the modules, they may prefer that you apply for a change in FCC ID for the modules that require additional approval, after which you will then become the grantee (in addition to the original grantee(s)).  You will then be able to request the applicable C2PC from the FCC to address any grant restrictions to enable the module to be incorporated in your host configuration and other qualified host devices (after appropriate testing has been performed).  For more information on RF exposure issues related to modules, please click here.

Alternatively, following the necessary testing, including RF exposure, you could submit a certification application under your grantee code to obtain an FCC ID for your host configuration that includes the two modules. 

This is our interpretation of the current FCC rules and regulations on this issue.  However, please note that the FCC is the final arbiter, and it may be prudent to ask the FCC to review your specific situation before moving forward.

For more information, review the links presented in Answer 1.

ANSI C63.19 2011, Hearing Aid Coil & Permit But Ask

Question: We manufacture a Hearing Aid Coil (HAC) that was tested per the ANSI C63.19 2011 technical standard.  Will the FCC allow our TCB to approve our device without utilizing the Permit but Ask (PBA) procedure?

Answer:  The FCC will only allow a TCB to approve your product through its PBA procedure.  Your application filing report must include the following items, taken from 285076 D01 HAC Guidance v03r02, Equipment Authorization Guidance for Hearing Aid Compatibility.

  1. M Rating:
    1. If tested, a description of the method and test equipment (manufacturer and model number) used to establish the Modulation Index Factor (MIF) as defined in Clause of the standard.
      • A validation test demonstrating measured results for sample pulse and sine wave modulations defined in C63.19-2011 Annex D.7, Tables D.3 and D.4
      • Provide justification for MIF values that are less than the sample values expected in annex D.7 table D.5 and values approaching the margin.
    2. If not tested using manufacturer’s provided MIF files
      • Statement signed by manufacturer that values used represent worst case air interfaces and operation.
      • For the MIF values used, document the version number/version date of the MIF values provided (manufacturer’s files, etc.) and the supporting documentation for the related (version number/version and date) values.
    3. Provide the margin, in dB, defined as: the e-field transition value for the next lower rated category of the established HAC category minus the maximum steady-state RMS field strength (before adding the MIF). 
    4. When T-Coil for VoLTE (provisional period for VoLTE) is not tested, there cannot be an associated LTE VoLTE M test value in the M test reports.
  2. T ratings for VoLTE:
    1. When T-Coil for VoLTE (provisional period for VoLTE) is capable to be activated on the phone shall be noted.
    2. Evaluation of T rating for VoLTE. VoLTE is an emerging service and is based on voice over IP technologies, which can be implemented in different ways depending on the carrier and service offered. It is expected that test equipment manufacturers will offer test equipment for VoLTE HAC measurements. During the provisional period for VoLTE (see Item 4(e) in 285076 D01 HAC Guidance v03r02) it is not necessary to evaluate T rating for such operation; however an applicant can seek approval for VoLTE implementation for T-coil tests under the PBA procedure. The following information shall be included in the PBA request:
      • A description of the VoLTE T-coil test set up.
      • Identification of the manufacturer and model numbers.
      • Software used to simulate servers.
      • Voice Codex tested.
      • Soft code imbedded, soft code API, hardware, etc.
      • Justification for codex tested and not tested.
Note:  On July 17 the FCC published a draft KDB guidance document on test configurations for T-Coil testing for VoLTE.  You may view the document by clicking on this link: .

EN 300 220-1 Standard Sub-band/Band Edge Interpretation

Question: Can you provide an interpretation of Section 7.7 of the ETSI EN 300 220-1 standard with regard to the meaning of sub band/band edge (fe) in the context of a channelized system operating within a band?  Specifically, is the band edge (fe斗地主达人) in Section 7.7 the edge of the channels in such cases? Take for example, ten 100 kHz channels between 865 MHz and 866 MHz.

Answer:  If you are referring to the EN 300 220-1 standard frequency band from 863 MHz to 870 MHz for which the application category is non-specific use, the EIRP limit is 25 mW, the Channel Spacing is ≤100 kHz with 0.1% Duty Cycle or Listen Before Talk (LBT) + Adaptive Frequency Agility (AFA), where the band is divided into sub-bands, the limit is applicable to the sub-bands edge frequencies such that (fe, lower), and (fe, upper) are the lower and upper edges of the band in which the equipment operates.

In your example of 865 MHz (fe, lower) and 866 MHz (fe, upper) based on 100 kHz channels, the first frequency would be 865.05 MHz and the last frequency would be 865.95 MHz. 

Therefore, the answer to your question is yes, the edge of the lowest and highest channel would be the sub-band edge or band-edge.

Nonetheless, if the transmitter does not comply with the requirements or the mask shown below in Figure 7 (taken from the EN 300 220-1 standard) when it is operating on the lowest/highest channel, then it is not possible to use the channels which are the closest to the band-edge.


Standards Updates


EU: New CENELEC Standards Recently Released

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

  • - (6/21/2013) - Basic standard for the calculation and measurement of electromagnetic field strength and SAR related to human exposure from radio base stations and fixed terminal stations for wireless telecommunication systems (110 MHz - 40 GHz)
  • - (6/21/2013) - Sound and television broadcast receivers and associated equipment - Radio disturbance characteristics - Limits and methods of measurement
  • - (6/28/2013) - Fire hazard testing - Part 2-10: Glowing/hot-wire based test methods - Glow-wire apparatus and common test procedure
  • - (6/28/2013) - Alarm and electronic security systems - Part 11-1: Electronic access control systems - System and components requirements
  • - (6/28/2013) - Test methods for electrical materials, printed boards and other interconnection structures and assemblies - Part 11: Measurement of melting temperature or melting temperature ranges of solder alloys
  • - (6/28/2013) - 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 10: Combined measuring equipment for testing, measuring or monitoring of protective measures
  • - (6/28/2013) - 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 14: Equipment for testing the safety of electrical equipment of machinery
  • - (7/5/2013) - Coaxial cables - Part 4-1: Sectional specification for cables for BCT cabling in accordance with EN 50173 - Indoor drop cables for systems operating at 5 MHz - 3 000 MHz

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:

  • - (July 2013) - Fixed Radio Systems; Characteristics and requirements for point-to-point equipment and antennas; Part 2-2: Digital systems operating in frequency bands where frequency co-ordination is applied; Harmonized EN covering the essential requirements of article 3.2 of the R&TTE Directive
  • - (July 2013) - Electromagnetic compatibility and Radio spectrum Matters (ERM); Maritime Personal Homing Beacon intended for use on the frequency 121,5 MHz for search and rescue purposes only; Part 1: Technical characteristics and methods of measurement
  • - (July 2013) - Electromagnetic compatibility and Radio spectrum Matters (ERM); Maritime Personal Homing Beacon intended for use on the frequency 121,5 MHz for search and rescue purposes only; Part 2: Harmonized EN covering the essential requirements of article 3.2 of the R&TTE Directive
  • - (July 2013) - Electromagnetic compatibility and Radio spectrum Matters (ERM); Digital Mobile Radio (DMR) Systems; Part 1: DMR Air Interface (AI) protocol
  • - (July 2013) - Electromagnetic compatibility and Radio spectrum Matters (ERM); Digital Mobile Radio (DMR) Systems; Part 3: DMR data protocol
  • - (July 2013) - Electromagnetic compatibility and Radio spectrum Matters (ERM); Digital Mobile Radio (DMR) Systems; Part 2: DMR voice and generic services and facilities
  • - (July 2013) - Electromagnetic compatibility and Radio spectrum Matters (ERM); System Reference document (SRdoc); Mobile broadband services in the 2 300 MHz – 2 400 MHz frequency band under Licensed Shared Access regime
  • - (July 2013) - Electromagnetic compatibility and Radio spectrum Matters (ERM); Short Range Devices; Smart Metering Wireless Access Protocol; Part 1: PHY layer
  • - (July 2013) - Electromagnetic compatibility and Radio spectrum Matters (ERM); System Reference document (SRdoc); Broadband Direct-Air-to-Ground Communications System operating in the 5,855 GHz to 5,875 GHz band using 3G technology
  • - (July 2013) - Electromagnetic compatibility and Radio spectrum Matters (ERM); System Reference Document (SRDoc); Short Range Devices; Low Power Cochlear Implant Systems (LP-CIS) operating in the band 2 483,5 MHz - 2 500 MHz

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:

  • - (6/25/2013) - Determination of certain substances in electrotechnical products - Part 2: Disassembly, disjunction and mechanical sample preparation
  • - (6/25/2013) - Determination of certain substances in electrotechnical products - Part 5: Cadmium, lead and chromium in polymers and electronics and cadmium and lead in metals by AAS, AFS, ICP-OES and ICP-MS
  • - (6/26/2013) - Corrigendum 1 - Secondary cells and batteries containing alkaline or other non-acid electrolytes - Safety requirements for portable sealed secondary cells, and for batteries made from them, for use in portable applications
  • - (6/27/2013) - Household and similar electrical appliances - Safety - Part 2-105: Particular requirements for multifunctional shower cabinets
  • - (7/9/2013) - Assessment of lighting equipment related to human exposure to electromagnetic fields - Part 1: Results of the EMF measurement campaign from the VDE Test and Certification Institute and ZVEI, the German Electrical and Electronic Manufacturers' Association
  • - (7/9/2013) - Medical electrical equipment - Part 2-62: Particular requirements for the basic safety and essential performance of high intensity therapeutic ultrasound (HITU) equipment
  • - (7/9/2013) - Aircraft batteries - Part 1: General test requirements and performance levels
  • - (7/10/2013) - Radio frequency connectors - Part 1: Generic specification - General requirements and measuring methods
  • - (7/10/2013) - Safety of transformers, reactors, power supply units and combinations thereof - Part 2-26: Particular requirements and tests for transformers and power supply units all for saving energy and other purposes
  • - (7/11/2013) - Corrigendum 1 - Effects of current on human beings and livestock - Part 5: Touch voltage threshold values for physiological effects
  • - (7/17/2013) - Integrated circuits - Measurement of impulse immunity - Part 3: Non-synchronous transient injection method

See for additional information.

US – FCC Extends Comment Period for U-NII Devices in the 5 GHz Band

斗地主达人On 6/17/2013, the FCC announced that it was extending the commenting period to July 24th, 2013 on the Notice of Proposed Rulemaking (NPRM) - Revision of Part 15 of the Commission's Rules to Permit Unlicensed National Information Infrastructure (U-NII) Devices in the 5 GHz Band.

US – FCC Measurement Procedure Guidance Issued for DTS Devices

In April 2013, the FCC issued KDB Guidance on measurement procedures applicable to digital transmission system (DTS) devices operating in the 902 MHz to 928 MHz, 2400 MHz to 2483.5 MHz, and/or 5725 MHz to 5850 MHz bands under §15.247 of the FCC rules. The procedure is not applicable to frequency-hopping spread spectrum systems (FHSS) that are not hybrid systems, authorized under the same rule part. For measurements of non-hybrid FHSS devices, see KDB Guidance DA 00-705, released on March 30th, 2000.   Note, that whenever a device utilizes combined technologies (e.g., DTS and U-NII), each component must be shown to be in compliance with the applicable rule requirements.

Canada - Transition Period Ends for ICES-003, Issue 5

After August, 31, 2013, only new product models in compliance with ICES-003, Issue 5, will be accepted by Industry Canada. Existing models in compliance with a previous issue of ICES-003 will remain compliant under the requirements of that previous issue. New models that comply with the technical requirements in ICES-003 issue 5 must implement the labeling requirements in ICES-003 Issue 5.  Existing models may continue with the labelling requirements in Issue 4.

The minimum requirements for labeling of models complying with the technical requirements in Issue 5 are detailed in section 8 of ICES-003 issue 5. When complying with ICES-003 issue 5, the Industry Canada ICES-003 compliance label must be in accordance with the following as per section 8:

CAN ICES-3 (*)/NMB-3(*) 
* Insert either "A" or "B" but not both to identify the applicable Class of ITE.

For example, if the ITE is determined to be class B then the minimum label requirement is as follows:

Additionally, the product test report must provide a record of the tests and results demonstrating compliance with ICES-003 Issue 5 technical requirements. The test report must indicate the date the tests were completed. The test report should clearly identify the Class of Limits, A or B, that the ITE was tested for compliance with, and clearly state which reference publication from Section 3 that was used for methods of measurement. The test report must be retained by the manufacturer or importer for a minimum period of five years from the date the model of ITE is first offered for sale, distributed and/or leased in Canada, and the report should be made available to Industry Canada upon request.   Link to

South Korea – Type Approval Changes

Recently, the Korea Communications Commission (KCC) had a name change and is now known as the Ministry of Science, ICT & Future Planning (MSIP). This change occurred as a result of Korea's National Government Organization Act (Law No. 11690, 2013. 3. 23).  Per announcement NRRA Public Notice 2013-5 on Conformity Assessment, product Type Approval labeling identification code has changed from "KCC" to "MSIP".

The Korean Type Approval label is made up of the Conformity Assessment mark (KC mark/logo), which remains unchanged and the Conformity Assessment Number, which is made up of four key parts:

  1. The identification code (now MSIP), followed by
  2. Indication of Basic Certification Information (e.g. CRM or REM etc), followed by
  3. Applicant code (identifying the applicant) and
  4. Product code (14 characters provided by the applicant to identify the product).

Products approved from July 1, 2013 should use the new labeling format. There is a three month grandfathering period whereby newly approved products can use the KCC identification code (to accommodate any manufacturers who have pre-made labels). After September 2, 2013, labels should transition to use the MSIP identification code. There is no requirement for manufacturers to change product labels for those products approved prior to July 1, 2103.

斗地主达人 Additionally, NRRA Public Notice 2013-5 allows manufacturers to make small changes to certain components (resistors, capacitors, inductors and diodes (including LEDs) without the need to update their MSIP Type Approval, provided:

  1. Type Approval was obtained based on EMC testing only.
  2. Electrical circuit (schematic and layout) remains identical.
  3. Changes to component does not increase the power capacity (wattage) of the circuit.


Indonesia - Modular Approval Rule Clarification

Recently, Indonesia's SDPPI clarified its rules relating to leveragability of modular approvals.  During the transitional period until December of 2013, the following rules will be implemented:
  1. If the module will be imported into Indonesia as a module, i.e. not installed in a host product, modular approval is sufficient.
  2. If the module will be imported into Indonesia installed in a notebook or tablet PC, modular approval should be obtained. The notebook or tablet PC must then be approved separately. However, there will be no repeat of local testing, the notebook or tablet PC can be approved via a simple paperwork only process.
  3. If the module will be imported into Indonesia installed in other products (not notebook or tablet PCs), host level approval is then required and the host itself must undergo local testing. Local importers are no longer able to apply for Type B Approval for a host product based on Type A Approval for a module.

Please note that the situation is expected to be subject to further change over the coming months.

Qatar – New Type Approval Regulations in Force

Qatar's Regulatory Authority, ictQatar, recently confirmed that their Type Approval regulations published in 2011 are now in force and several changes to their Type Approval procedure are now implemented. 

Moving forward, there are 2 possible means to obtain approval in Qatar:
  1. Simplified procedure: This procedure can be followed if one of the below criteria can be met:
    1. the product has already obtained approval in Bahrain, Saudi Arabia or UAE
    2. the product has already obtained approval with a recognized CAB. The Authority advises that under the simplified scheme, certificates will take 5 working days to process.
  2. Standard procedure: This procedure must be followed if approval has not been issued by a recognized National Regulatory Authority as detailed above. Nevertheless, ictQatar will only accept test reports issued by a recognized test lab. The Authority advises that under the standard scheme, certificates will take up to 15 working days to process.  

Additionally, all certificates issued by ictQatar, including those issued previously, are now valid indefinitely.


Philippines – Modular Approval Rule Update

We were recently updated by our local agent that the Philippine’s National Telecommunications Commission (NTC) has determined that Modular Approval is no longer sufficient to fully cover the host product into which the module will be integrated.

NTC is still issuing Type Approval Certificates for modules, however it is required that all host products are assessed and certified (including an assessment of EMC and safety compliance) as well.

Our agent also advised that the requirements have been in place for some time but due to misinterpretation of the requirements by some NTC regional offices, import permits have been incorrectly issued for host products leveraging the modular approval. Moving forward, it is anticipated that all NTC regional offices will only issue import permits for host products with a valid Type Approval Certificate.

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