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MultiPoint Newsletter - July 2019

FCC Marine VHF Radio Requirements

Question: We are designing a radio to operate in the 156-162 MHz marine VHF band under Part 80. What compliance issues do we face?

Answer: To obtain certification, a marine VHF radio must comply with the following:

  1. Transmitting frequencies limited to those in the table in 47CFR§80.871(d), with simplex and semi-duplex mode requirements.
  2. If radio and manual provide channel numbers, they must be consistent with the channel numbers in the aforementioned table.
  3. If radio and manual provide a domestic mode (e.g., US, USA, domestic use), the frequencies in the domestic mode may consist only of those listed in the tables in 47CFR§80.371(c) and 47CFR§80.373(f), except for the following case: the domestic mode may contain marine VHF channel numbers 3, 21, 23, 61, 64, 81, 82, or 83, provided that the radio or the manual make clear these frequencies are not for use by the general public in U.S. waters. Instead, a user would need to have special authorization under a private land mobile license, or from the Coast Guard. The domestic mode may not contain marine VHF channel numbers 2, 4, 60, and 62; these are slightly offset from private land mobile frequencies and there is no means to legally use these as carrier frequencies in U.S. waters. Note that the rules do not require specific warning labels, nor place additional burdens on manufacturers that meet these requirements.
  4. If radio and manual provide an international mode (e.g., international, ITU, Appendix 18, foreign), or a mode specific to a particular administration (e.g., Canada, Japan, UK), the radio and manual need only comply with item #1 listed above.

Additional requirements for Digital Selective Calling (DSC) became effective March 25, 2011 per FCC 47CFR§80.225(a)(4), which prohibited the manufacture, importation, sale and installation of fixed mounted (non-portable) DSC-equipped marine radios that do not meet the following standards:

  1. International Telecommunications Union (ITU-R) Recommendation M.493-13
  2. Class D VHF DSC equipment only, International (IEC) International Standard 62238

These international standards include many safety features, such as the requirement that channel switching have two receivers for DSC. More information can be found here. All equipment authorization applications for devices subject to this requirement must include the following:

  1. Letter Exhibit stating the applicable standards used to determine compliance
  2. Full ITU 439-13/IEC 62238 test report(s)

Promotional Electronic Giveaways

Question:斗地主达人 We manufacture promotional electronic items that our clients give away during trade shows. These promotional items have small micro-controllers, oscillators and LEDs. Since these items are only given away, not sold nor marketed, are we required by the FCC to certify them?

Answer:斗地主达人 Yes, these giveaway items must comply with the applicable FCC rules and regulations if they meet the definition and criteria for radio frequency (RF) devices as defined in 47CFR§2.801. Although not being marketed or sold, the intent is for these promotional electronic items to be used in the U.S., which makes them subject to the FCC rules and regulations.

There are only a few specific instances when RF devices may be marketed, or operated, prior to FCC authorization; refer to 47CFR§2.803 and 47CFR§2.805 respectively.

Harmonized Standards and the Official Journal of the European Union

Question: Has the OJEU modified the kind of information it provides for some of the product categories?

Answer:斗地主达人 Effective December 1, 2018 the European Union began employing a new format when publishing the harmonized standards in the Official Journal. While the change has impacted only a few product categories at this time, it is likely to impact all products eventually.

Currently, the new format can be found under the CE Marking Directives for Machinery, Personal Protection Equipment (PPE), and Construction Products. The list of harmonized standards has been removed. This change was made as a result of Regulation (EU) No. 1025/2012 on European Standardisation, and a number of rulings by the European Court of Justice.

Essentially, these rulings state that harmonized standards lists must now be issued as Legislative (L) notices, not informative (C) notices. The European Union is not able to issue Consolidated Lists, so amended notices will now include specific lists of new references and withdrawn references.

斗地主达人As a result, harmonized standards will now be listed within the 。pdf files referenced on the web page, not listed on the web page itself。 Currently, there are two files referenced, the legacy consolidated list, and the new specific list。

To determine if a standard is harmonized, first search the legacy consolidated list, and then search the specific list to determine if a standard was withdrawn or introduced。 It remains to be seen how information will be presented when there are multiple amendments。

Harmonized Standard Revisions

Question: How do we determine the correct revision of the harmonized standard to apply?

Answer: A standard becomes harmonized when its reference is published on the Official Journal of the European Union (OJEU), which will only occur after the EU is satisfied that the new standard meets the requirements to offer a presumption of conformity to the legislation, and after the standard has been published by the relevant standards body, e.g. CEN, CENELEC, or ETSI.

With the exception of Machinery, PPE and Construction Products as described in the previous Q/A, the OJ entry will indicate a “date of cessation of conformity of superseded standard”, allowing either revision of the standard to be used until the cessation of conformity date, at which time, the new revision must be used.

斗地主达人It is possible that the current revision of a standard indicated on a non-OJ web site may not be published in the OJ, and may instead be a withdrawn or superseded revision that offers presumption of conformity, so the source of your information is critical to determining the correct revision.

There are three very common electrical safety standards whose revisions create confusion for manufacturers. EN 60204-1:2006 + A1:2009, EN 60335-1:2012 + A11 2014 and EN 61010-1:2010 should be used for CE Marking purposes despite having been superseded by EN 60204-1:2018, EN 60335-1:2012 + A13:2019 and EN 61010-1:2010 + A1:2019 respectively.

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:

  • - 6/14/2019 - Explosive atmospheres - Part 39: Intrinsically safe systems with electronically controlled spark duration limitation
  • - 6/21/2019 - Appliance couplers for household and similar general purposes - Part 1: General requirements
  • - 6/21/2019 - Safety of transformers, reactors, power supply units and combinations thereof - Part 1: General requirements and tests
  • - 6/28/2019 - Human exposure to radio frequency fields from hand-held and body-mounted wireless communication devices - Human models, instrumentation, and procedures - Part 2: Procedure to determine the specific absorption rate (SAR) for wireless communication devices used in close proximity to the human body (frequency range of 30 MHz to 6 GHz)
  • - 7/5/2019 - Environmental testing - Part 2-82: Tests - Test Xw1: Whisker test methods for components and parts used in electronic assemblies
  • - 7/5/2019 - Electromagnetic compatibility (EMC) - Part 4-18: Testing and measurement techniques - Damped oscillatory wave immunity test
  • - 7/5/2019 - Electric vehicle conductive charging system - Part 1: General requirements

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 2019) - Broadcast Sound Receivers; Part 1: Generic requirements and measuring methods
  • - (June 2019) - Transport and Traffic Telematics (TTT); Dedicated Short Range Communication (DSRC) transmission equipment (500 kbit/s / 250 kbit/s) operating in the 5 795 MHz to 5 815 MHz frequency band; Part 2: Harmonised Standard for access to radio spectrum; Sub-part 2: On-Board Units (OBU)
  • - (June 2019) - Short Range Devices (SRD); Ultra Low Power (ULP) wireless medical capsule endoscopy devices operating in the band 430 MHz to 440 MHz; Harmonised Standard for access to radio spectrum
  • - (June 2019) - Access, Terminals, Transmission and Multiplexing (ATTM); Sustainable Digital Multiservice Communities; Key Performance Indicators for Sustainable Digital Multiservice Areas; Part 2: Global KPIs for Sustainable Digital Multiservice Areas
  • - (June 2019) - Core Network and Interoperability Testing (INT); Diameter Conformance testing for the Sh/Dh interfaces; (3GPPTM Release 13); Part 3: Abstract Test Suite (ATS) and partial Protocol Implementation eXtra Information for Testing (PIXIT) pro forma specification
  • - (June 2019) - Access, Terminals, Transmission and Multiplexing (ATTM); Sustainable Digital Multiservice Cities; Broadband Deployment and Energy Management; Part 2: Multiservice Networking Infrastructure and Associated Street Furniture; Sub-part 2: The use of lamp-posts for hosting sensing devices and 5G networking

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:

  • - 6/14/2019 - Electroacoustics – Hearing aids – Part 13: Requirements and methods of measurement for electromagnetic immunity to mobile digital wireless devices
  • - 6/21/2019 - Amendment 1 - Electromagnetic compatibility of multimedia equipment - Emission requirements
  • - 6/21/2019 - Safety requirements for electrical equipment for measurement, control and laboratory use - Part 2-032: Particular requirements for hand-held and hand-manipulated current sensors for electrical test and measurement
  • - 6/21/2019 - Safety requirements for electrical equipment for measurement, control, and laboratory use - Part 2-033: Particular requirements for hand-held multimeters and other meters for domestic and professional use, capable of measuring mains voltage
  • - 6/25/2019 - Amendment 1 - Specification for radio disturbance and immunity measuring apparatus and methods - Part 2-3: Methods of measurement of disturbances and immunity - Radiated disturbance measurements
  • - 6/25/2019 - Specification for radio disturbance and immunity measuring apparatus and methods - Part 2-3: Methods of measurement of disturbances and immunity - Radiated disturbance measurements
  • - 6/27/2019 - Explosive atmospheres - ALL PARTS
  • - 6/27/2019 - Interpretation Sheet 2 - Explosive atmospheres - Part 0: Equipment - General requirements
  • - 6/28/2019 - Measurement procedure for the assessment of specific absorption rate of human exposure to radio frequency fields from hand-held and body-mounted wireless communication devices - Part 3: Vector measurement-based systems (Frequency range of 600 MHz to 6 GHz)
  • - 7/2/2019 - Environmental testing - Part 2: Tests - ALL PARTS

See for additional information.

EU – Technical Guidance Note for Radio Modules and Equipment with Integrated Modules

The Radio Equipment Directive Compliance Association (REDCA) of the European Union has released the technical guidance note for RED compliance requirements for radio modules and final radio equipment products that integrate a radio module。

Prior to being placed on the market in the EU, radio modules that meet the definition of radio equipment (as per Article 2 of the RED), and are within the scope of the RED, must be assessed to the RED. In all cases, an assessment of the radio module must be made to the requirements of Article 3 of the RED.

Despite the possibility that the radio module’s operation may be reassessed later as part of a final radio product, a full assessment of safety, EMC, and radio performance is necessary to demonstrate the radio module’s compliance with the RED.

The radio module manufacturer must define at least one operating environment (or selection of environments) for their assessment, and this must be clearly detailed in the technical documentation of the radio module。

For radio modules that will be installed by end users rather than be professionally installed, radio module manufacturers must either assess the module in a range of possible environments, or limit the types of installation permitted。

The radio module manufacturer must consider a range of possible conditions, such as input voltage, temperature, and other environmental conditions, which may apply in the final environment of use. This includes the internal operating temperatures and voltage variations of possible host devices.

Other aspects to be considered by the radio module manufacturer include:

  • Antenna type and gain
  • Antenna assembly, path, or configuration
  • Software versions or modifications
  • Installation
  • Type of operation and use
  • Shielding or reflective effects of the host product (if known)
  • All safety aspects

Any items that could affect RED compliance, such as critical accessories, antennas, antenna assembly or path, software versions, etc。, shall be documented in the radio module’s installation instructions and on the radio module’s EU declaration of conformity。

斗地主达人When installing a radio module into a host product, assessment or testing will be required at the final radio product level if the host product was not used at the time of the original assessment.

For example, if a host product and final radio product have other functions beside the operation of the radio module, the assessment will cover the radio operation as well as the other functions, which may likely be covered under different standards。

The complete technical guidance note can be found here.

Switzerland – Updates to Radio Interference Regulations

The Swiss Federal Office of Communications (OFCOM) is updating the Radio Interference Regulations (RIR) to follow the latest frequency management regulations in Europe; the revised RIR will be enforced September 1, 2019。 The Ordinance of the Swiss OFCOM on telecommunications installations (OOIT) specifies the basic technical requirements with regard to telecommunications installations set out by the Swiss Federal Council, and regulates the use of radio interfaces in Switzerland。

The updates are as follows (no Radio Interface Regulation (RIR) is completely new or repealed):





The "application description" will be modified to "Video PMSE" instead of "SAP/SAB and ENG/OB。”




The channeling requirement (7 MHz) and the maximum occupied bandwidth requirement (20 MHz) will be removed.


Harmonized standard changed from EN 302 217-4-2 to EN 302 217-4 (due to transition from the R&TTE-Directive to the RE-Directive)。







Additional channelings (55 MHz, 112 MHz, 56 MHz, 56 MHz, 1000 MHz, and 112 MHz) will be added.


A reduction of the receiving frequency range from 3.40 - 4.20 GHz down to 3.60 - 4.20 GHz will be introduced.


Adaptions will be made due to the amendment of the ECC/DEC/(13)01。


The reference ERC/DEC/(99)05 will be removed because this decision has been withdrawn。



斗地主达人The requirement of a minimum occupied bandwidth of 600 kHz will be introduced.


The reference ERC/DEC(01)08 will be replaced by ECC/DEC/(18)03.


An additional limit (25mW) is defined, which applies to equipment to be used inside vehicles.


Canada – Changes to the 3500 MHz Band

The Ministry of Innovation, Science and Economic Development of Canada (ISED) recently announced its decision on revisions to the 3450-3650 MHz band (also known as the 3500 MHz band) to accommodate flexible use for fixed and mobile services, as well as the potential changes to the 3400-3450 band and the 3650-4200 MHz band (referred to as the 3800 MHz band).

  1. Changes to the allocations in the 3500 MHz band – ISED will add a primary mobile allocation to the 3450-3475 MHz band and remove the radiolocation allocation from the 3450-3500 MHz band.
  2. Flexible use in the 3500 MHz band – ISED is adopting a flexible use licensing model for fixed and mobile services in the 3450-3475 MHz band, which will provide ISED with the ability to issue flexible use licenses in a 200 MHz frequency range from 3450-3650 MHz.
  3. Coexistence of radiolocation and other services in the 3400-3450 MHz band – ISED will continue to monitor and study the 3400-3450 MHz band to assess its potential future use in other services. Any changes to the use of the band will be subject to a future consultation.
  4. Provisions to allow existing licensees to continue services in the 3500 MHz band
    • For each license area, existing licensees that meet all conditions of license will be eligible to be issued flexible use licenses covering the same geographic area for a fixed amount of spectrum.
    • Existing licensees that currently hold 75 MHz or more of fixed use licenses in a given area will be eligible to apply for a new flexible use license of 60 MHz in the related area; those with 50 MHz of spectrum will be eligible to apply for a new flexible use license of 50 MHz; and all other existing licensees will be eligible to apply for new flexible use licenses of 20 MHz.
    • Any license transfers or divisions of a license by area and/or frequency made subsequent to June 6, 2018 will not alter the total amount of spectrum available to eligible incumbent licensees for flexible use through the transition process.
    • Prior to the auction, any transfer request involving a portion of 3500 MHz fixed licenses must specify the amount of flexible use spectrum available for each transfer applicant based on blocks of 10 MHz.
    • All transfer requests for existing fixed use licenses in the 3500 MHz band received prior to the auction process will be considered as transfers of commercial mobile spectrum.
    • Any portion of a fixed license that remains with no appropriation of eligibility for a flexible use license will be automatically cancelled upon completion of the competitive licensing process.
  5. Changes to the 3500 MHz band plan and interference mitigation – ISED is adopting a band plan using unpaired blocks of 10 MHz in the frequency range of 3450-3650 MHz.
  6. Interference mitigation – ISED will establish a coordination procedure between operators and technical limits in a future standard.
  7. Timing for the introduction of mobile services in the 3500 MHz band – Existing licensees who are eligible and wish to provide mobile services must acquire a flexible use license.

Additional information can be found .

Canada – Regulatory Updates for White Space Devices

The Ministry of Innovation, Science and Economic Development of Canada (ISED) opens consultation for RSS-222, Issue 2, White Space Devices (WSDs), as well as DBS-01, Issue 2, White Space Database Specifications.

  • RSS-222, Issue 2, White Space Devices (WSDs), delineates the certification requirements for license-exempt radio apparatus operating in the frequency bands 54-72 MHz, 76-88 MHz, 174-216 MHz, 470-608 MHz, and 657-663 MHz, known as white space devices (WSDs).
  • DBS-01, Issue 2, White Space Database Specifications, delineates the technical requirements for the designation of a database capable of identifying available channels for use by white space devices in the white space frequency bands noted above.

Following is the list of changes in RSS-222, Issue 2:

  1. The sections on RSS-102 (for radio frequency exposure) and RSP-100 (requirements for the certification of radio apparatus) have been removed since these documents are normative references in RSS-Gen.
  2. White space frequency bands have been revised based on the Decision on the Technical and Policy Framework for White Space Devices.
  3. Additional Equivalent Isotropic Radiated Power (e.i.r.p.) and associated conducted power limits, power spectral densities, and conducted adjacent channel emission limits, have been included for fixed white space devices.
  4. New sections have been included to address certification and licensing requirements.
  5. Channel bonding requirements have been clarified, and additional requirements prescribed.
  6. A definition for less congested areas has been added.
  7. A transition period has been included for the certification of WSDs.
  8. The measurement section on multiple antennas has been removed since the measurement method is defined in ANSI C63.10, American National Standard for Testing Unlicensed Wireless Devices (referenced in RSS-Gen, General Requirements for Compliance of Radio Apparatus).
  9. A confidence level associated with the uncertainty of the geo-location accuracy has been prescribed.
  10. A requirement has been added stating that the description of alternate geo-location determination (other than GPS) must be included in the test report.
  11. A dependency requirement for the power level of a mode I personal/portable device has been added when the controlling device is limited to 40 mW.
  12. Additional editorial changes and clarifications have been made, as appropriate.

Effective six months from the date of publication, ISED will no longer accept applications for the certification of new WSDs complying with RSS-222, Issue 1. After this period, applications for the certification of new WSDs demonstrating compliance with Issue 2 of RSS-222 shall be accepted.

Following is the list of changes in DBS-01, Issue 2:

  1. White space frequency bands have been revised based on the Decision on the Technical and Policy Framework for White Space Devices.
  2. In addition to the list of available channels, the WSDB will also provide the associated maximum power levels on which a WSD may operate.
  3. Editorial changes and clarifications have been made to improve the standard.
  4. Definition for less congested areas has been added.
  5. The use of the term “Television White Space (TVWS)” has been revised to “White Space (WS).” This reflects the expanded and more general use of spectrum beyond the former TV spectrum.
  6. Tables of separation distances between WSDs and TV-protected contours has been updated to facilitate the operation of WSDs’ power levels up to 10 Watts e.i.r.p. and for various power levels below 4 Watts e.i.r.p. The separation distances have also been revised to address separation distances for antenna height below 30 m (outside the F curve range).
  7. Allow a higher effective height above average terrain (EHAAT), directional height above average terrain (dirHAAT), and antenna height above ground level (AGL). The separation distances have been revised in light of those changes.
  8. A transition period has been defined to facilitate the transition from DBS-01 Issue 1 requirements to DBS-01, Issue 2 requirements.
  9. The separation distances must now include the difference of geo-location’s uncertainty if above the reference ±50 m uncertainty.

Within six months of this standard’s date of publication, a WSDBA having an existing WSDB designation from ISED shall submit an application to ISED demonstrating compliance with the current issue of this standard.

Upon receipt of the application, ISED will review and assess compliance with the current issue of this standard. In order to maintain its designation, the WSDBA will be required to take satisfactory corrective measures as identified, and within the timeline set out by ISED. Additional information can be found .

South Korea – Regulatory Update for IoT Equipment

South Korea’s National Radio Research Agency (RRA) is revising the technical standards for wireless equipment telecommunications testing as the international standard for narrowband Internet of Things (IoT) equipment is revised.

Article 4 (Wireless facility for mobile communication) Technical standards for narrowband IoT wireless facilities for mobile telecommunication that uses frequency division multiplexing method are as follows:

4. Conditions of Mobile Station Transmitter
B. Out-of-band drivers shall meet the following conditions:

Occupied Frequency BandwidthFrequency Band*Average Power of Unwanted EmissionResolution Bandwidth
200 kHz ±100 kHz < 26 dBm 30 kHz
±200 kHz < -5 dBm
±250 kHz < -8 dBm
±400 kHz < -29 dBm
±(600 - 1800) kHz < -35 dBm

* NOTE: The average power of unwanted emissions between frequency bands should be linearly interpolated.

South Korea – Updated EMC Technical Requirements

斗地主达人On May 28, 2019, South Korea’s National Radio Research Agency (RRA) updated Phase I procedures of Annex I, including technical requirements for electromagnetic compatibility。

Following is the list of updates from the previous version posted on 3/19/2019:

  • Added a link referencing the technical regulations regarding the EMC test items.
  • Updated notice on the designation and management of testing laboratories for broadcasting and communications equipment (RRA Public Notification 2019 - 5, March 11, 2019).
  • Updated test methods for electromagnetic compatibility (RRA Announce 2018-128, Dec 24, 2018).

The following EMC standards found in Article 3 of the Notice were removed (see Section 3 of Table 1 Matters Related to Test Items by Examination Field):

  • KN 301 489-7
  • KN 301 489-24
  • KN 301 489-26

Mexico – Modified Import Rules

The Secretariat of Economy of Mexico recently notified Mexican customs authorities that NOM-208 certificates issued on behalf of someone other than the importer will be accepted。

NOM-208-SCFI-2016 regulates Bluetooth, WLAN, and other short-range devices operating in the frequency bands 2400-2483。5 MHz, 5725-5850 MHz, and 902-928 MHz。 This standard has replaced both NOM-121-SCT1-1999 (NOM 121) and NOM-EM-016-SCFI-2015 (NOM-016), although certifications obtained under NOM-121 and NOM-EM-016 remain valid。

For the purpose of demonstrating compliance with the NOM-208-SCFI-2016 standard before the customs authorities, valid certificates of conformity and/or compliance with the Official Mexican Standard NOM-208-SCFI-2016, NOM-121-SCTI-2009, of the Official Standard Mexican Emergency NOM-EM-016-SCFI-2015 is required. Certificates of conformity issued in accordance with Technical Provision IFT-008-2015 are also mandatory and will be accepted until the end of their date of validity (expiration date).

If the certificate is valid, it will be accepted even if the certificate is issued to a person, party, or entity that is not the importer. Certificates completed under NOM-121 and NOM-016 have permanent validity; however, they cannot be modified to include similar products or additional models.

Additionally, all previously issued certificates will now need to be updated to include the product's HS Code. This is now required in order to carry out the normal importation process.

Any importer using an exception letter in order to waive obtaining a NOM is not required to obtain a mandatory NOM certificate.

Goods that are not sold to the general public or are imported for manufacturing will now require NOM.

Dictums/product declarations on specialized products and exemptions will continue to be issued; however, these products will be checked at customs and may be rejected if it is determined that they are not highly specialized. This update affects all devices submitted for radio and safety Type Approval in Mexico for NOM standards, and is effective as of June 3, 2019.

Additional information can be found .

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