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MultiPoint Newsletter - June 2014

E-Labelling Guidance

Question: We manufacture modular devices with very small footprints and we have difficulty finding sufficient surface area on our devices to place our FCC ID label. What is the status of the FCC’s proposed e-labelling guidance?

Answer: The FCC proposed, published and received comments on the Public Draft for Review for Electronic Labelling Guidance for certified devices with an integrated display screen, however until the final version of the guidance is released, the electronic display of labels will not be allowed, with the exception of those already permitted for software-defined radios and modular transmitters which display the information electronically via a display. The proposed e-labelling guidance applies to all the aforementioned devices. At this time it is not known when the FCC will publish the final guidance document.

The current proposal includes requirements for the information to be displayed on the integrated screen, user access to the e-label information, removable adhesive labeling for importation and purchasing, and other topics。

The following are some highlights from the proposal; the final published document may include additional guidance:

斗地主达人Information to be Displayed on Integrated Screen Using E-label:

  • FCC ID and Declaration of Conformity (DoC) logo if applicable.
  • Information required by specific rule to be provided on the surface of the product.

斗地主达人Access to the Information on the E-label:

  • Users must be able to access the information without special access codes or permissions, and in all cases it must be accessible in no more than three steps in a device’s menu.
  • Information access must be permitted without special accessories or installation of a SIM/USIM card.

斗地主达人Removable Adhesive Labelling for Importation and Purchasing

  • Products utilizing e-labels are required to have a physical label on them at the time of importation, marketing and sales; a removable adhesive label is acceptable. The removable label must include:
    • FCC ID and Declaration of Conformity (DoC) logo if applicable.
    • Information required by specific rule to be provided on the surface of the product.

The proposed e-labelling guidelines include several other important requirements including but not limited to:

  • FCC ID, DoC logo if applicable, and other information required by specific rule must be programmed by the responsible party and the information must be secured so that it cannot be modified by third parties.
  • Product packaging material must display the FCC ID, and the DoC logo if applicable.

SDR Configuration by Professional Installer

Question: We manufacture a Software-Defined Radio (SDR) and would like our professional installers to configure certain operating parameters in the field. Is this allowed?

Answer: In many cases, a radio frequency transmitter requires professional installation or configuration by authorized service personnel. In such cases, professional installers may be allowed access to the configuration parameters for adjusting power or location information to accommodate local installation.

As long as your radio complies with the FCC’s SDR requirements, and the professional installer’s on-site programming matches the specific configuration parameters identified in the radio’s FCC certification, the professional installers may configure your device in the field.

However, professional installers are not permitted to make on-site adjustments such as using country code parameters to select the transmitter’s frequency of operation, nor to program other technical parameters such as Dynamic Frequency Selection (DFS) used for radar detection on a UNII device.

Device Configuration for Frequency Bands of Operation

Question: Within FCC , and , does the FCC permit service personnel limited access to configure devices to operate on a licensee’s frequency bands of operation?

Answer: Yes, these rule parts permit service personnel limited access to configure devices to operate on a licensee’s frequency bands of operation. The Operational Description exhibit submitted with the certification application for the device must clearly describe the control procedures implemented to ensure that only service personnel have access to the programming capabilities. Under no circumstance should the end users be able to program the radio.

The grantee may secure the radio software by implementing password protection through a web-based authentication procedure, or the grantee may require the service personnel to set the password by resetting the factory-based configuration。

SAR Information in User Documentation

Question: We would like to add Specific Absorption Rate (SAR) measurement values to our user manual. What are the FCC guidelines for doing so?

Answer: The FCC does not require SAR values to be listed in user manuals or operating instructions, but does require that if included, the SAR values must be correct and consistent with the FCC grant.

In order to ensure compliance, if operating restrictions are necessary, i.e. in the use of body-worn accessories, the user manual must clearly specify the operating conditions and the required minimum separation distance between the user and the device.

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