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MultiPoint Newsletter - July 2015

Pre-Approval Guidance

Question: We are designing a wireless device that may require special permission from the FCC. While we continue development, we would like to learn more about the process to obtain certification for our device. How should we proceed?

Answer: If you believe that your device will require special permission, we recommend that you begin your research by reviewing 388624 D02 Pre-Approval Guidance List v16, in order to confirm that your device does in fact require Pre-Approval Guidance (PAG).

Published June 26, 2015 under Report and Order FCC 14-208, this Pre-Approval Guidance List replaces the Permit but Ask (PBA) List, and addresses changes to the new PAG procedures for Telecommunications Certification Bodies (TCBs).

When FCC oversight is still required, as with emerging technologies, or when the available FCC guidance is either only partial or non-existent, the PAG procedure outlines the applicable process that permits equipment authorization by TCBs.

There are three classes of applications for equipment authorization subject to a PAG review, prior to approval by a TCB:

  1. Devices subject to special conditions where the authorization procedures to be used must be approved by the FCC prior to approval by a TCB
  2. Devices for which a sample must be submitted to the FCC for pre-approval testing prior to approval by a TCB
  3. Devices for which there are new or unique operation or installation issues which are subject to FCC review prior to approval by a TCB

斗地主达人Each application class includes criteria for the corresponding device types/technologies/RF exposure requirements.

Once you have determined that your device does in fact require PAG, please refer to 388624 D01 Pre-Approval Guidance Procedure v11斗地主达人, also published June 26, 2015 to replace the PBA Procedure, for important process and information requirements to be considered now and as you move forward with the testing and certification process.


IC RSS-247 Issue 1

Question: We manufacture wireless modular devices. It was brought to our attention that Industry Canada (IC) has modified RSS-247, Issue 1, Digital Transmission Systems (DTSs), Frequency Hopping Systems (FHSS) and Licence-Exempt Local Area Network (LE-LAN) Devices. In particular, what are the changes to Section 5.4.2 Transmitter Output Power and Equivalent Isotropically Radiated Power (E.I.R.P.) Requirements?

Answer: Before the recent IC revision to RSS-247 Issue 1 May 2015, Section 5.4 Transmitter Output Power and Equivalent Isotropically Radiated Power (E.I.R.P.) Requirements, Paragraph 2 read as follows:

“For FHSs operating in the band 2400-2483.5 MHz, the maximum peak conducted output power shall not exceed 1.0 W and the e.i.r.p. shall not exceed 4 W if the hopset uses 75 or more hopping channels; the maximum peak conducted output power shall not exceed 0.125 W and the e.i.r.p. shall not exceed 0.5 W if the hopset uses less than 75 hopping channels (see Section 5.4(5) for exceptions).”

Following IC’s modification announced on July 14, 2015 and effective immediately, Section 5.4 Paragraph 2 now reads as follows:

“For FHSs operating in the band 2400-2483.5 MHz, the maximum peak conducted output power shall not exceed 1.0 W if the hopset uses 75 or more hopping channels; the maximum peak conducted output power shall not exceed 0.125 W if the hopset uses less than 75 hopping channels. Except as provided in Section 5.4(5), the EIRP shall not exceed 4 W.”

Section 5.4(5) states: “Fixed point-to-point systems in the bands 2400-2483.5 MHz and 5725-5850 MHz are permitted to have an e.i.r.p. higher than 4 W provided that the higher e.i.r.p. is achieved by employing higher gain directional antennas and not higher transmitter output powers. Point-to-multipoint systems, omnidirectional applications and multiple co-located transmitters transmitting the same information are prohibited from exceeding an e.i.r.p. of 4 W.”

To summarize, IC removed both the requirement for the equal to or less than 4 watts EIRP limit for greater than 75 hopping channels, and the requirement for equal to or less than 0。5 watts EIRP limit for less than 75 hopping channels in Section 5。4(2)。 Note however that an EIRP greater than 4 W is only permitted under Section 5。4(5) using higher gain antennas, and not by increasing the transmitter’s output power。


FCC Grant Dismissal

Question: As a wireless device manufacturer, what happens when our Telecommunications Certification Body (TCB) grant is dismissed?

Answer: When a grant is dismissed by the FCC, or authorizing TCB, for conditions of non-compliance, you must immediately cease marketing the device.

FCC grants are issued in accordance with 。

斗地主达人When the FCC, or the authorizing TCB, audits a TCB-issued grant and finds conditions of non-compliance with the FCC rules, a grant less than 30 days old may be set aside and dismissed under and .

Before the grant can be re-issued, as the applicant, you must coordinate with the TCB, and consult with the FCC as appropriate, to resolve any and all issues of non-compliance.

Grants over 30 days old may be dismissed by the FCC at the applicant’s request, or revoked by the FCC for non-compliance, per .

If it is determined that a certified product is non-compliant, and the grant is older than 30 calendar days, the resolution will be determined based on the merits of, and issues with, the original grant. In the event of an honest mistake, the TCB that issued the grant, and the applicant, must resolve any non-compliance issues to the satisfaction of the FCC. The grant can most likely be re-issued.

If it is determined that duplicitous actions or measures were employed by the applicant in order to obtain a grant under false pretenses, the FCC will revoke the grant, and it will not be re-issued。 In these cases, the FCC has been known to flag the applicant’s grantee code, and closely monitor future certification activities。


Demonstrating FCC Compliance

Question: We manufacture a product that was tested to CISPR 22 standard. Can we consider our product to be compliant with the FCC rules for an unintentional radiator?

Answer: No, you cannot consider your product to be compliant with the FCC rules for an unintentional radiator based on testing it to an international EMC standard such as CISPR 22, even if it has been adopted by several countries. FCC compliance can only be demonstrated by testing in accordance with the appropriate FCC standard, using the required FCC measurement methods, and proving that the device meets the FCC limits. To be considered compliant, the device must meet the requirements for FCC certification, Declaration of Conformity, or verification as required.


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:

  • - 5/29/2015 - Medical electrical equipment - Part 2-41: Particular requirements for basic safety and essential performance of surgical luminaires and luminaires for diagnosis
  • - 5/29/2015 - Medical electrical equipment - Part 2-54: Particular requirements for the basic safety and essential performance of X-ray equipment for radiography and radioscopy
  • - 5/29/2015 - Medical electrical equipment - Part 2-63: Particular requirements for the basic safety and essential performance of dental extra-oral X-ray equipment
  • - 5/29/2015 - Medical electrical equipment - Part 2-64: Particular requirements for the basic safety and essential performance of light ion beam medical electrical equipment
  • - 5/29/2015 - Medical electrical equipment - Part 2-68: Particular requirements for the basic safety and essential performance of X-ray-based image-guided radiotherapy equipment for use with electron accelerators, light ion beam therapy equipment and radionuclide beam therapy equipment
  • - 5/29/2015 - Medical electrical equipment - Part 2-58: Particular requirements for the basic safety and essential performance of lens removal devices and vitrectomy devices for ophthalmic surgery
  • - 6/5/2015 - Information technology equipment - Immunity characteristics - Limits and methods of measurement
  • - 6/12/2015 - Electromagnetic compatibility (EMC) - Part 4-6: Testing and measurement techniques - Immunity to conducted disturbances, induced by radio-frequency fields
  • - 6/17/2015 - Electric vehicle conductive charging system - Part 24: Digital communication between a d.c. EV charging station and an electric vehicle for control of d.c. charging
  • - 7/3/2015 - Electromagnetic compatibility of multimedia equipment - Emission Requirements
  • - 7/8/2015 - Conformity assessment - Requirements for bodies providing audit and certification of management systems - Part 1: Requirements (ISO/IEC 17021-1:2015)

斗地主达人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:

  •  - (June 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
  •  - (June 2015) - Electromagnetic compatibility and Radio spectrum Matters (ERM); Wireless microphones in the 25 MHz to 3 GHz frequency range; Part 2: Harmo
  •  - (June 2015) - Electromagnetic compatibility and Radio spectrum Matters (ERM); Impact of CENELEC EN 55032 on ETSI EMC Standards
  •  - (June 2015) - Global System for Mobile communications (GSM); Harmonised EN for mobile stations in the GSM 900 and GSM 1800 bands covering essential requirements under article 3.2 of the R&TTE directive (1999/5/EC)
  •  - (June 2015) - PowerLine Telecommunications (PLT); Coexistence of Narrow Band PLT technologies operating in the frequency bands 3kHz to 95 kHz, 95 kHz to 125 kHz and 125 kHz to 140 kHz; [IEEE Std 1901.2TM - 2013, IEEE Standard for Low-Frequency (less than 500 kHz) Narrowband Power Line Communications for Smart grid Applications, Section 10 Coexistence]
  •  - (July 2015) - Electromagnetic compatibility and Radio spectrum Matters (ERM); Digital Mobile Radio (DMR) Systems; Part 4: DMR trunking protocol

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:

  • - 5/29/2015 - Electromagnetic compatibility (EMC) -; Part 6-5: Generic standards -; Immunity for equipment used in power station and substation environment
  • - 5/29/2015 - Safety requirements for electrical equipment for measurement, control and laboratory use - Part 031: Safety requirements for hand-held probe assemblies for electrical measurement and test
  • - 5/29/2015 - Safety requirements for electrical equipment for measurement, control and laboratory use - Part 031: Safety requirements for hand-held probe assemblies for electrical measurement and test
  • - 6/5/2015 - Explosive atmospheres -; Part 10-1: Classification of areas -; Explosive gas atmospheres
  • - 6/8/2015 - Conformity assessment -- Requirements for bodies providing audit and certification of management systems -- Part 1: Requirements
  • - 6/9/2015 - Industrial, scientific and medical equipment - Radio-frequency disturbance characteristics - Limits and methods of measurement
  • - 6/9/2015 - Industrial, scientific and medical equipment - Radio-frequency disturbance characteristics - Limits and methods of measurement
  • - 6/11/2015 - Explosive atmospheres - Part 39: Intrinsically safe systems with electronically controlled spark duration limitation
  • - 6/12/2015 - Corrigendum 1 - Electromagnetic compatibility (EMC) - Part 4-6: Testing and measurement techniques - Immunity to conducted disturbances, induced by radio-frequency fields
  • - 6/19/2015 - Environmental testing -; Part 2-39: Tests -; Tests and guidance: Combined temperature or temperature and humidity with low air pressure tests
  • - 6/19/2015 - Amendment 1 - Low-voltage electrical installations -; Part 4-44: Protection for safety -; Protection against voltage disturbances and electromagnetic disturbances
  • - 6/26/2015 - Explosive atmospheres - Part 7: Equipment protection by increased safety 'e'
  • - 6/26/2015 - Medical electrical equipment - Part 2-66: Particular requirements for the basic safety and essential performance of hearing instruments and hearing instrument systems
  • - 6/26/2015 - Amendment 2 - Safety of machinery - Functional safety of safety-related electrical, electronic and programmable electronic control systems
  • - 6/26/2015 - Safety of machinery - Functional safety of safety-related electrical, electronic and programmable electronic control systems
  • - 7/7/2015 - Corrigendum 1 - Explosive atmospheres - Part 2: Equipment protection by pressurized enclosure "p"
  • - 7/7/2015 - Safety requirements for electrical equipment for measurement, control, and laboratory use - Part 2-040: Particular requirements for sterilizers and washer-disinfectors used to treat medical materials

See for additional information.

US - FCC Publishes AC Power-line Questions and Answers

On June 3, 2015, the FCC published the 。 This is a newer version of an existing publication and changes include Question 8 (on devices powered by a USB port) and footnote 1 to address use of new editions of the ANSI C63。4 and ANSI C63。10 standards。

Question 8 asked:

"If a Part 15 device is powered from a computer or any other external power source via a USB connection, what type of USB power source is required when measuring the AC power-line conducted emissions?"

The FCC's reply is as follows:

"It is required to perform the AC power-line conducted emissions testing and demonstrate compliance with the AC power-line emission requirements in Sections 15。107 or 15。207。 Section 15。31(i) requires that the device be fully exercised and configured in a manner that maximizes the emissions。 As such, the device is to be tested with each type of power source that is typically used to provide power via a USB connection such as computers and power adapters。"

FCC - October 2015 TCB Council Workshop

The Telecommunications Certification Body Council (TCBC) will host its Fall 2015 Workshop from October 27-29, 2015 at the Holiday Inn - Inner Harbor in Baltimore, Maryland. The agenda is being organized by the Education Committee and is currently set to include expanded RF Exposure sessions along with the typical FCC, Industry Canada, NIST, International and Technology sessions. The details of the agenda will be distributed as they are confirmed. Should you have any questions, contact Chris Harvey at admin@tcbcouncil.org, or call at 443-622-3300.

Canada - RSS-119, Issue 12 Released

On May 28, 2015, was published and went into effect。 Below is a summary of the changes in this new issue:

  • Requirements have been added for equipment with a 6.25 kHz channel bandwidth operating in the frequency bands 806-821/851-866 MHz and 821-824/866-869 MHz.
  • The provision for equipment with channel aggregation has been clarified to include mobile equipment where applicable.
  • An alternative provision has been added for frequency stability with which fixed and base equipment must comply.
  • The frequency stability has been modified for mobile equipment operating in the frequency bands 406.1-430 MHz, 450-470 MHz, 806-821/851-866 MHz and 821-824/866-869 MHz with an occupied bandwidth greater than 20 MHz.
  • The frequency bands 764-768 MHz and 794-798 MHz assigned for public safety services have been removed.
  • Limits have been added and clarified for the transmitter output power of equipment.
  • The date by which equipment operating in the frequency bands 768-776 MHz and 798-806 MHz must comply with a minimum data rate of 4.8 kbps or one voice channel per 6.25 kHz has been removed.
  • The requirement has been removed for equipment operating in the frequency bands 768-776 MHz and 798-806 MHz to have a minimum data rate of 128 kbps per 50 kHz.
  • The adjacent channel power (ACP) limits have been modified for equipment operating in the frequency bands 768-776 MHz and 798-806 MHz.
  • The requirement has been removed for including data port specifications in the user manual.
  • The requirement for receiver spurious emissions has been removed because it is specified in RSS-Gen, General Requirements for Compliance of Radio Apparatus.

Canada – Release of RSS-247, Issue 1, Digital Transmission Systems

On May 28, 2015, Industry Canada released Radio Standards Specification . RSS-247 is a new standard to replace Annexes 8 and 9 of RSS-210, Issue 8, . All devices covered under the scope of RSS-247 will no longer be certified under RSS-210, Issue 8. Listed below are the changes (list does not include the modifications referenced earlier in this MultiPoint that were announced on, and effective, July 14, 2015):

  • References have been added to the FCC Knowledge Database (KDB) and American National Standards Institute (ANSI) standards for the measurement method of dynamic frequency selection (DFS);
  • A measurement procedure has been added to be used for verifying the compliance of equipment to the e.i.r.p. at different antenna elevations;
  • The digital technology of systems operating in the band 5725-5850 MHz that employ digital modulation or both digital modulation and frequency hopping technology is covered under the LE-LAN provision;
  • Requirements for LE-LAN equipment operating in the band 5725-5825 MHz have been modified and the frequency band for LE-LAN equipment has been extended from 5725-5825 MHz to 5725-5850 MHz;
  • The unwanted emission limit for LE-LAN equipment operating in the band 5150-5250 MHz is determined outside the band 5150-5350 MHz instead of 5150-5250 MHz;
  • The unwanted emission limit for LE-LAN equipment operating in the band 5250-5350 MHz is determined outside the band 5150-5350 MHz instead of 5250-5350 MHz;
  • Conditions have been added to allow equipment in the band 5150-5350 MHz ;
  • The DFS procedure has been modified for LE-LAN equipment operating in the bands 5250-5350 MHz, 5470-5600 MHz and 5650-5725 MHz;
  • The requirement for in-service monitoring for equipment operating in the frequency bands 5250-5350 MHz, 5470-5600 MHz and 5650-5725 MHz does not apply to slave devices which do not have a radar detection mechanism;
  • Requirements have been added for LE-LAN devices operating in the 5 GHz band with bandwidths that overlap various frequency ranges within the 5 GHz band; and
  • A requirement has been added that all LE-LAN devices contain security features to protect against modification of software by unauthorized parties.

EU - Updated List of Harmonized Standards to the R TTE Directive

斗地主达人On July 10, 2015, the European Commission published in the Official Journal an updated list of standards to be used for assessing compliance to the .

EU – RTTECA/REDCA Bi Annual Meeting

On June 1-2, 2015, the 30th R&TTECA meeting took place in Göteborg, Sweden, hosted by SP - Sveriges Tekniska Forskningsinstitut。 The meeting was attended by more than 60 members including many from non-EU countries。 The main issues discussed were as follows:

  • Situation on transition of equipment in 2016 to and from the Radio Equipment Directive, EMC Directive and Low Voltage Directive
  • Consequences of the application of the RED and new EMCD and new LVD
  • Results of and input from R&TTECA in the EU Commissions working group developing the Guide for the new Radio Equipment Directive – RED
  • Report of the ongoing Market surveillance activities in the EU
  • Feedback from the recent TCBC Workshop in the USA
  • Update of the requirements for radio equipment entering the market in Japan
  • Discussion of a large number of technical issues and issues related to the operation of the R&TTE Directive or new RED such as, amongst others:
    • ”Making available” and products intended for own use
    • Question on the Declaration of Conformity in the user manual 
    • Health requirements not being assessed
    • Fixed or Portable use definition
    • Validity of NB opinion
    • AC in standards
    • 9.5 GHz Slope Stability Radar Standards
    • Indoor versus Outdoor use
    • Treatment of Non-linear Junction Detectors 
    • CE marking on "transport" (not sales packaging) packaging
    • Translate instructions and safety instruction in country languages
    • Using old versions of standards
    • Definition of TX Gap for FHSS in ETSI EN 300 328 V1.8.1
    • Bluetooth Worst Case Test
    • E compliance
    • Choice of standards for the safety of R&TTED products

The next meeting will be held in November 2015 in Nice, France in combination with an ETSI Workshop related to all new standards being developed currently for the RED and new EMCD.

Guinea Bissau - Type Approval Services Resumed

斗地主达人We were recently advised that Guinea Bissau's Type Approval agency, Autoridade Reguladora Nacional das TIC (ARN-TIC), has re-started its activities after a four month suspension. ARN-TIC is now receiving Type Approval requests and issuing Type Approvals with no change from the previous Type Approval procedures.

Russia – New 802.11n Regulation Released

Recently, the Russian Ministry of Telecom and Mass Communications and The Ministry of Justice released Radio Access Regulations for 802。11ac and 802。11ad standards。 These standards are now included in Order No。 124, and the regulations went into effect on June 14, 2015。 Russia Ministry Declarations and Certificates issued before June 14, 2015 for devices containing these technologies will not be affected。 Manufacturers may apply to update existing Declarations and Certificates to include 802。11ac and 802。11ad standards on a voluntary basis。 The process to update a Declaration and Certificate will be considered a new application。

Ghana - New Type Approval Requirements

We were recently advised that the Ghanaian Regulatory Agency, National Communication Authority (NCA), revised its regulation guidelines at the end of May 2015. Highlights from the updated guidelines are as follows:

  • Regarding Local Representation requirements:  "A local company is now required for all type approval applications if the manufacturer does not have a branch in Ghana"
  • Regarding the publication of the type approved devices on the NCA website:  "The Authority will maintain on its website a list of approved ECE (hereinafter referred to as "Type Approval Register") to be accessed by the general public"
  • Regarding recognized Test Laboratory:  The Authority will accept Test Reports from any accredited Test Laboratory included in the list of accredited Testing Laboratories recognized by the Authority.  An initial list of Testing Laboratories recognized by the Authority is provided, and a regularly updated list will be made publicly available on the Authority's website.  The Authority reserves the right to request for re-testing at a laboratory assigned by the Authority.  The applicant will be responsible for all laboratory or other costs incurred"
  • Regarding labelling:  "All Type Approved Terminal Equipment shall bear a legible label permanently affixed to such equipment, bearing the mark 'NCA Approved: XXX-XXXXX-XXX' as shown in Appendix 3 of these Guidelines.  E-Marking (Electronic Marking) shall be accepted in place of physical marking however it is the sole responsibility of the manufacturer to ensure that such mark is not altered"
  • Regarding market surveillance:  "The Authority shall perform market surveillance activities from time to time to ensure that only type approved ECE is sold in Ghana"

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