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MultiPoint Newsletter - March 2013

RF/EMC Regulatory Update for USA, Canada and European Union

Dear Colleague,

We have provided typical questions and answers that represent in most cases technical opinions with justification in FCC, IC and CE requirements. The particulars of the product for certification must be considered with respect to the applicability of these questions and answers. We hope you find our update valuable and welcome your feedback if you have any special needs or questions. Call us at 703.689.0368 for your testing requirements. You can view archived issues of MultiPoint at our website.


FCC/ETSI Composite Devices

Question: We manufacture a product that integrates a wireless device which we would like to market in the U.S. and Europe. We are wondering which standards should be used for testing an intentional radiator with a short-range communications device, specifically a dielectric heater or wireless charger that includes a Bluetooth transceiver for monitoring purposes. We’re thinking that the transceiver would fall under FCC Part 15 and ETSI EN 300 440. However, if this is the case, the product will not comply because the intentional radiator will violate the conducted/radiated emissions limits. Can we test the two product components separately, applying different standards to the components, for the radiator and for the transceiver?


Answer:斗地主达人 In your situation, the dielectric heater or wireless charger is the product, and the Bluetooth transceiver is for "monitoring" purposes only. FCC Part 15.33(k) considers this type of product combination a composite system - different devices incorporated into a single or separate enclosure. Composite systems may be subject to different FCC rule parts and thus are allowed to be tested separately in order to comply with the relevant standard(s). The FCC would allow the Bluetooth transceiver to be tested with the dielectric heater or wireless charger installed in the enclosure but not active. However, for this to be allowed, the Bluetooth transceiver must act as a peripheral device to control the dielectric heater or wireless charger. The Bluetooth transceiver would be tested under , and the dielectric heater or wireless charger would be tested under Part 15 or Part 18.

 

斗地主达人Following is FCC Part 15.33(k) that addresses composite systems:


"FCC Part 15.33(k): A composite system is a system that incorporates different devices contained either in a single enclosure or in separate enclosures connected by wire or cable. If the individual devices in a composite system are subject to different technical standards, each such device must comply with its specific standards. In no event may the measured emissions of the composite system exceed the highest level permitted for an individual component. For digital devices which consist of a combination of Class A and Class B devices, the total combination of which results in a Class A digital device, it is only necessary to demonstrate that the equipment combination complies with the limits for a Class A device. This equipment combination may not be employed for obtaining a grant of equipment authorization or verifying a Class B digital device. However, if the digital device combination consists of a Class B central control unit, e.g., a personal computer, and a Class A internal peripheral(s), it must be demonstrated that the Class B central control unit continues to comply with the limits for a Class B digital device with the Class A internal peripheral(s) installed but not active."


For Information on testing wireless charging devices, please click on this for the 2012 FCC TCBC training on the subject.


ETSI’s position on composite wireless charging devices is similar to that of the FCC; click on this for their explanation of when the Short Range Device framework is applicable.


Log Averaging

Question:斗地主达人 An EMC laboratory is testing our product that operates with a carrier frequency above 1 GHz. When we apply a log-average detector, our product is compliant with the FCC Part 15.209 radiated field strength average limit, however when we apply a linear-average detector, our product is not compliant. The laboratory tells us that it must use a linear-average detector because the FCC rule part under which our product falls requires the use of voltage averaging to measure the carrier field strength of our product. Can you explain further?

Answer: Your EMC laboratory is correct; the FCC does not permit the use of log-averaging in any rule part. The use of power averaging or voltage averaging is determined by the language in the relevant FCC rules, regulations and measurement procedures.

For example, if a rule specifies a limit on average power, or on average power spectral density, power averaging is required。

If a rule specifies average detection of a field strength, as in measurements above 1 GHz for example, voltage averaging is required since field strengths are proportional to the measurement antenna induced voltage.

斗地主达人In instances where voltage averaging is required, some measurement procedures may also permit the use of power averaging, since power averaging produces a measurement result that is equal to or greater than that of voltage averaging when the measurement results are converted to the same units。

There are typically three common types of average detection namely:

  • Power averaging, also referred to as RMS, in which averaging is performed on the voltage-squared;
  • Voltage averaging, also referred to as linear averaging, in which averaging is performed on the absolute value of the voltage;
  • Log averaging, also referred to as dB averaging, in which averaging is performed on the log of the power, or the log of the absolute value of voltage;

斗地主达人in most advanced spectrum analyzers.


FCC NPRM 13-19 Proposal to Replace Exclusion List with Pre-approval Guidance Procedure

Question: The FCC has proposed eliminating the Telecommunication Certification Bodies (TCB) Exclusion List in favor of a codified pre-approval guidance procedure. How would this work?

Answer: In this proposal, the FCC would eliminate the present TCB Exclusion List and replace it with a pre-approval guidance procedure, which is currently incorporated into its rules and regulations, but is not policy. The pre-approval guidance procedure will be utilized when TCBs require guidance from the FCC to certify products for which there are no clear rules, requirements or measurement procedures. Based on our understanding at this time, the FCC’s proposed procedure should work as follows:

  • The FCC will issue a KDB (Knowledge Data Base) publication identifying the categories of equipment or types of testing that fall under the pre-approval guidance procedure and for which a TCB will be required to consult with the FCC before granting certification. This list will include devices currently on the TCB exclusion list and the permit-but-ask (PBA) list. A few examples are Dynamic Frequency Selection (DFS), Ultra Wide Band (UWB) and TV Bands Device (TVBD), which presently only the FCC can approve.
  • The TCB will perform an initial review of the application and determine the issues on which it needs to obtain guidance from the FCC and will then electronically submit the relevant exhibits to the FCC.
  • In accordance with the FCC guidance it receives, the TCB will continue to review the application to determine whether the equipment complies with the FCC rules.
  • The TCB will electronically submit all exhibits to the FCC, along with a recommendation to grant or dismiss the application.
  • If the FCC determines that the equipment complies with the rules, it will give its approval to the TCB to grant the application. However, the FCC may instead request and test a sample before the application can be granted, or it may advise the TCB that additional information or equipment testing is required, or it may advise the TCB that the equipment cannot be approved because it does not comply with the FCC rules.

The FCC will continue to exercise the necessary control and oversight of particular sections of the rules until such time that it determines that these sections can be considered routine and the additional oversight procedures are no longer needed.

The benefit of this proposal is that TCBs will be able to perform all of the routine review of equipment applications that fall under the proposed pre-approval guidance procedure, resulting in shorter processing time。 The FCC Office of Engineering & Technology (OET) would only need to review the portions of an application that require additional oversight。


FCC NPRM 13-19 Proposed “Permit But Ask” Changes

Question: In NPRM 13-19, the FCC proposes to improve the current “Permit-But Ask” (PBA) process that must be utilized by TCBs. How would this be accomplished?

Answer: The current PBA process is time consuming for applicants, the TCBs and the FCC because it does not fully integrate the inquiry/response function in the Knowledge Data Base (KDB) with the application processing function in the Equipment Authorization System (EAS), forcing the use of multiple electronic systems: 

  • The TCB sends a request via the KDB to obtain FCC guidance on processing the application.
  • The TCB then uploads files for FCC review using the EAS.
  • All further communications between the FCC and TCB are conducted via the KDB.
  • The FCC and the TCB must cross-reference application files and related communications stored on the separate KDB and EAS.

The FCC proposal would fully integrate the pre-approval guidance procedure with the EAS. Providing necessary guidance for new equipment representing new technologies, fully integrated with the EAS, would considerably improve FCC response time, leading to improved TCB processing time.


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:

  • - (2/22/2013) - Household and similar electrical appliances - Safety - Part 2-17: Particular requirements for blankets, pads, clothing and similar flexible heating appliances
  • - (2/22/2013) - Medical electrical equipment - Part 1-8: General requirements for basic safety and essential performance - Collateral Standard: General requirements, tests and guidance for alarm systems in medical electrical equipment and medical electrical systems
  • - (2/22/2013) - Nuclear power plants - Instrumentation and control important to safety - General requirements for systems
  • - (3/1/2013) - Safety of transformers, reactors, power supply units and combination thereof - Part 2-14: Particular requirements and tests for variable transformers and power supply units incorporating variable transformers
  • - (3/8/2013) - 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
  • - (3/8/2013) - Safety of primary and secondary lithium cells and batteries during transport
  • - (3/15/2013) - Maritime navigation and radiocommunication equipment and systems - Integrated navigation systems - Part 2: Modular structure for INS - Operational and performance requirements, methods of testing and required test results
  • - (3/15/2013) - Product standard to demonstrate compliance of radio frequency fields from handheld and body-mounted wireless communication devices used by the general public (30 MHz - 6 GHz)
  • - (3/15/2013) - Specification for radio disturbance and immunity measuring apparatus and methods - Part 2-3: Methods of measurement of disturbances and immunity - Radiated disturbance measurements

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:

  • - (February 2013) - Satellite Earth Stations and Systems (SES); Harmonized EN for Earth Stations on Mobile Platforms (ESOMP) transmitting towards satellites in geostationary orbit in the 27,5 GHz to 30,0 GHz frequency bands covering the essential requirements of article 3.2 of the R&TTE Directive
  • - (February 2013) - Electromagnetic compatibility and Radio spectrum Matters (ERM); Digital Private Mobile Radio (dPMR) using FDMA with a channel spacing of 6,25 kHz
  • - (February 2013) - Electromagnetic compatibility and Radio spectrum Matters (ERM); digital Private Mobile Radio (dPMR) General System Design
  • - (February 2013) - Electromagnetic compatibility and radio spectrum matters (ERM); The specification and implementation of design changes to interrogators and specification of the test plan for the Preliminary Tests and the Trial; Modification of interrogators and specification of test plans for the Preliminary Tests and Trial
  • - (February 2013) - Electromagnetic compatibility and Radio spectrum Matters (ERM); Digital Mobile Radio (DMR) Systems; Part 1: DMR Air Interface (AI) protocol
  • - (February 2013) - Electromagnetic compatibility and Radio spectrum Matters (ERM); Digital Mobile Radio (DMR) Systems; Part 4: DMR trunking protocol
  • - (February 2013) - Electromagnetic compatibility and Radio spectrum Matters (ERM); Peer-to-Peer Digital Private Mobile Radio using FDMA with a channel spacing of 6,25 kHz with e.r.p. of up to 500 mW
  • - (March 2013) - Electromagnetic compatibility and Radio spectrum Matters (ERM); ElectroMagnetic Compatibility (EMC) standard for radio equipment and services; Part 50: Specific conditions for Cellular Communication Base Station (BS), repeater and ancillary equipment
  • - (March 2013) - Electromagnetic compatibility and Radio spectrum Matters (ERM); Short Range Devices (SRD); Conformance test procedure for the exterior limit tests in EN 302065-3 UWB applications in the ground based vehicle environment

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:

  • - (2/20/2013) - Nuclear power plants - Instrumentation and control important to safety - Selection and use of industrial digital devices of limited functionality
  • - (2/21/2013) - Interpretation Sheet 1 - Limits and methods of measurement of radio disturbance characteristics of electrical lighting and similar equipment
  • - (2/21/2013) - Interpretation sheet 2 - Limits and methods of measurement of radio disturbance characteristics of electrical lighting and similar equipment
  • - (2/21/2013) - Interpretation sheet 1 - Safety requirements for electrical equipment for measurement, control, and laboratory use - Part 1: General requirements
  • - (2/22/2013) - Nuclear power plants - Instrumentation and control important to safety - Hardware design requirements for computer-based systems
  • - (2/22/2013) - Safety requirements for electrical equipment for measurement, control, and laboratory use - General requirements for equipment intended to be used in educational establishments by children
  • - (2/25/2013) - Corrigendum 2 - Medical electrical equipment - Part 2-20: Particular requirements for the basic safety and essential performance of infant transport incubators
  • - (2/25/2013) - Corrigendum 1 - Medical electrical equipment - Part 2-21: Particular requirements for the basic safety and essential performance of infant radiant warmers
  • - (2/25/2013) - Safety requirements for electrical equipment for measurement, control and laboratory use - Part 2-201: Particular requirements for control equipment
  • - (2/26/2013) - Ultrasonics - Physiotherapy systems - Field specifications and methods of measurement in the frequency range 0,5 MHz to 5 MHz
  • - (3/14/2013) - Communication networks and systems in substations - ALL PARTS
  • - (3/18/2013) - Specification for radio disturbance and immunity measuring apparatus and methods - ALL PARTS
  • - (3/18/2013) - Specification for radio disturbance and immunity measuring apparatus and methods - Part 2-1: Methods of measurement of disturbances and immunity - Conducted disturbance measurements
  • - (3/18/2013) - Amendment 2 - Specification for radio disturbance and immunity measuring apparatus and methods - Part 2-1: Methods of measurement of disturbances and immunity - Conducted disturbance measurements
  • - (3/22/2013) - Power transformers - ALL PARTS
  • - (3/22/2013) - Analysis of quantification methodologies of greenhouse gas emissions for electrical and electronic products and systems

See for additional information。

FCC – Chairman Genachowski to Step Down

On March 22, 2013, FCC Chairman announced his plans to step down in the next several weeks.

"I'm proud of what we've done together to harness technology to advance the American dream for the 21st century. I know you’ll continue to fight hard to fulfill this agency’s vital mission, and I look forward to continuing to work together until my last day at the agency, and to count you as family and as an inspiration for long after that," he said in a statement released by the FCC. Genachowski was nominated to the post by President Obama in 2009 and his term was set to end in July 2013.

FCC – Additional Spectrum for U-NII Devices

On February 20, 2013, the FCC released its plans to make available an additional 195 MHz of spectrum in the 5 GHz bands for Unlicensed National Information Infrastructure (U-NII) devices. This is a 35% increase in available spectrum and a significant addition to capability. The FCC's rules define U-NII devices as "intentional radiators operating in the frequency bands 5.15–5.35 GHz and 5.470–5.825 GHz that use wideband digital modulation techniques and provide a wide array of high data rate mobile and fixed communications for individuals, businesses, and institutions."

The FCC plans are also intended to create a more flexible regulatory environment, and to streamline existing rules and equipment authorization procedures for devices throughout this band. The proposed modifications would provide access to additional contiguous spectrum with consistent technical requirements, allowing unlicensed devices to use wider bandwidth channels, leading to faster speeds.

Australia – RCM Mark Now In Effect

As of March1, 2013, the Regulatory Compliance Mark (RCM) replaced the C-tick and A-tick marks and the new Electrical Equipment Safety Scheme (EESS) has been introduced. The new national EESS requires the use of the RCM and will replace the current state and territory based electrical safety approval systems. The use of the RCM requires manufacturers, importers and suppliers to register products on the new EESS national database. The RCM is a single compliance mark and may only be used after establishing compliance with all applicable regulations including EMC, Telecoms, Radiocoms, Electromagnetic Radiation (EMR) and electrical safety.

Israel – SII Regulatory Update

The Standards Institute of Israel (SII) has announced the following changes to regulations impacting the validity of SII Certificates as follows:

  • All SII Certificates issued before 1/1/2011 and in accordance with IEC 60950 PART 1: First Edition: 2001 (equivalent Israel standard 60950 Part 1 March 2003) ceased to be valid as of March 1, 2013.
  • SII Certificates that have been issued after 1/1/2011 and in accordance with IEC 60950 – PART 1: Second Edition: 2005-12 + Corrigendum 1: August 2006 (equivalent Israeli standard 60950 Part 1, May 2009) will remain valid until 12/31/2013.
  • Effective 1/1/2014, all devices under the scope of the IEC60950 standard (and mandated by SII as requiring Approval for Israel) will need to be compliant with IEC 60950 – PART 1 : Second Edition : 2005-12 + Amendment 1: 2009-12 (equivalent Israel standard 60950 Part 1 February 2012)
  • Any SII Certificates issued in accordance with IEC 60950 – PART 1 : First Edition: 2001 should be re-issued immedicately (if the devices concerned are still being imported in to Israel). For such devices, the safety part of the SII scheme will need to be followed in full, with the product undergoing complete local safety testing in Israel.
  • Any SII Certificates issued in accordance with IEC 60950 – PART 1: Second Edition: 2005-12 + Corrigendum 1: August 2006 should be re-issued before 12/31/2013 (if the devices concerned are still being imported in to Israel). For such devices, only partial safety testing will need to be carried out locally in Israel, testing to a subset of clauses of the equivalent Israel standard 60950 Part 1, February 2012.

 

 

 

 

 

 

 

 

 

 

 

 

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