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MultiPoint Newsletter - March 2014

Class II Permissive Change to Obtain Modular Approval

Question: We currently have an FCC grant on an end product, that is, it is not a modular approval grant. Would the FCC permit a Class 2 permissive change to obtain a modular or limited modular approval grant for the radio board within this end product?

Answer: In some cases it may be possible to perform a Class 2 permissive change to obtain a modular certification for an already certified end product, assuming certain criteria are met:

  • The change must meet all the requirements for a Class 2 permissive change per ;
  • The module must meet all the requirements for modular transmitters per and all other applicable rules. If all the FCC 15.212 modular requirements cannot be met, it may be possible to obtain a limited modular approval (LMA).

The requirements for FCC permissive changes are discussed in ; see sections 6)a) and 6)c) for information on the specific question above).

斗地主达人Additionally, modular approval requirements are discussed in .


On-line User Manuals for Licensed Devices

Question: Our company manufactures land mobile radios that are certified under FCC Part 90. We would like to provide our user manuals on-line rather than in hard copy form in the box with the radio, but we are not sure if the FCC will allow that. Our compliance team has researched this and the closest reference they can find is regarding compliance information, but this part appears to be specific to equipment authorized under a Declaration of Conformity.

Do you know if the FCC will allow a manufacturer of licensed devices subject to certification to provide an on-line user manual?

Answer: Yes, the FCC will allow the user manual to be provided on-line instead of in hard copy form. However, it is imperative that the details on where to find the user manual on-line, that is the link to the manual, be clearly visible to the user on the packaging and/or other material supplied with the radio.


Transmitter Co-location Criteria

Question: We design wireless devices and would like to know whether the FCC still determines co-location of transmitters using the following criteria?

  • 20 cm separation distance from a user (used to determine mobile or portable status as applicable to RF exposure)
  • 20 cm separation distance between antenna elements of different transmitters (used to determine if transmitters are considered co-located).

Answer: The FCC previously used the criteria you noted to determine the applicability of co-location. However, since the publication of 447498 D01 General RF Exposure Guidance v05r02斗地主达人, the 20 cm separation distance is no longer used as the determining factor for mobile or portable environments, and co-location.

If there is antenna elements transmission then the elements are co-located and would need to be evaluated for RF Exposure。 Specific Absorption Rate (SAR) evaluation is now independently evaluated based on a formula of frequency, distance from the user, and power。

Furthermore, simultaneous transmissions have several other more complex ramifications that must be considered; a 20 cm separation distance is no longer an automatic exemption from evaluating for RF Exposure. You would have to show how independent and simultaneous exclusions are applied for portable devices, or provide Maximum Permissible Exposure (MPE) for mobile devices.


Radiated Emissions of Non-Hybrid FCC Part 15.247 Device

Question: We are testing an FHSS FCC Part 15.247 device that has a single RF output but has many available antenna options. We have applied a 50-ohm termination to our antenna port and performed cabinet radiated emissions testing in accordance with KDB 558074, instead of radiated emissions testing with the antennas terminating the antenna port. Is this an acceptable approach?

Answer: Though the new DTS procedure in KDB 558074, Guidance for Performing Compliance Measurements on Digital Transmission Systems (DTS) Operating Under §15.247 allows termination of an antenna port to be performed in accordance with the procedure in 12.2.1 Antenna-port conducted measurements, General and 12.2.7, Radiated spurious emission test, it is only applicable to hybrid systems (hybrid systems are those that employ a combination of both frequency hopping and digital modulation techniques) authorized under FCC rule part.

For measurements of non-hybrid FHSS devices, you must use the DA 00-705 procedure, released on March 30, 2000.

If you are testing your product using the FHSS procedures provided in DA 00-705, you cannot use antenna port conducted measurements in lieu of radiated measurements as this procedure does not permit it。


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:

  •  - (2/21/2014) - Electric strength of insulating materials - Test methods - Part 3: Additional requirements for 1,(2/50 µs impulse tests
  •  - (2/21/2014) - Electromagnetic compatibility (EMC) - Part 4-6: Testing and measurement techniques - Immunity to conducted disturbances, induced by radio-frequency fields
  •  - (2/28/2014) - Alarm systems - Intrusion and hold-up systems - Part 2-2: Intrusion detectors - Passive infrared detectors
  •  - (2/28/2014) - Alarm systems - Intrusion and hold-up systems - Part 2-7-1: Intrusion detectors - Glass break detectors (acoustic)
  •  - (2/28/2014) - Railway applications - Fixed installations - D.C. surge arresters and voltage limiting devices - Part 2: Voltage limiting devices
  •  - (3/7/2014) - Collection, logistics & Treatment requirements for WEEE - Part 1: General treatment requirements
  •  - (3/14/2014) - Explosive atmospheres - Part 17: Electrical installations inspection and maintenance
  •  - (3/14/2014) - Video surveillance systems for use in security applications - Part 1-1: System requirements - General
  •  - (3/21/2014) - Basic standard for the in-situ measurement of electromagnetic field strength related to human exposure in the vicinity of base stations
  •  - (3/21/2014) - Environmental testing - Part 1: General and guidance
  •  - (3/21/2014) - Fire hazard testing - Part 11-2: Test flames - 1 kW nominal pre-mixed flame: Apparatus, confirmatory test arrangement and guidance
  •  - (3/28/2014) - Explosive atmospheres - Part 14: Electrical installations design, selection and erection
  •  - (3/28/2014) - Measuring relays and protection equipment - Part 27: Product safety requirements
  •  - (3/28/2014) - Measurement of DC magnetic, AC magnetic and AC electric fields from 1 Hz to 100 kHz with regard to exposure of human beings - Part 1: Requirements for measuring instruments

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:

  • - (March 2014) - Electromagnetic compatibility and Radio spectrum Matters (ERM); Portable Very High Frequency (VHF) radiotelephone equipment for the maritime mobile service operating in the VHF bands with integrated handheld class D DSC; Part 1: Technical characteristics and methods of measurement
  • - (March 2014) - Electromagnetic compatibility and Radio spectrum Matters (ERM); Portable Very High Frequency (VHF) radiotelephone equipment for the maritime mobile service operating in the VHF bands with integrated handheld class D DSC; Part 2: Harmonized EN covering the essential requirements of article 3.2 of the R&TTE Directive
  • - (March 2014) - Electromagnetic compatibility and Radio spectrum Matters (ERM); Portable Very High Frequency (VHF) radiotelephone equipment for the maritime mobile service operating in the VHF bands with integrated handheld class D DSC; Part 3: Harmonized EN covering the essential requirements of article 3.3(e) of the R&TTE Directive
  • - (March 2014) - Electromagnetic compatibility and Radio spectrum Matters (ERM); Portable Very High Frequency (VHF) radiotelephone equipment for the maritime mobile service operating in the VHF bands with integrated handheld class D DSC; Part 2: Harmonized EN covering the essential requirements of article 3.2 of the R&TTE Directive
  • - (March 2014) - Electromagnetic compatibility and Radio spectrum Matters (ERM); Portable Very High Frequency (VHF) radiotelephone equipment for the maritime mobile service operating in the VHF bands with integrated handheld class D DSC; Part 3: Harmonized EN covering the essential requirements of article 3.3(e) of the R&TTE Directive
  • - (March 2014) - Electromagnetic compatibility and Radio spectrum Matters (ERM); Additional ElectroMagnetic Compatibility (EMC) requirements and resistibility requirements for telecommunications equipment for enhanced availability of service in specific applications
  • - (March 2014) - Electromagnetic compatibility and Radio spectrum Matters (ERM); System Reference document (SRdoc); Technical characteristics for pan European harmonized communications equipment operating in the 5,855 GHz to 5,925 GHz range intended for road safety and traffic management, and for non-safety related ITS applications
  • - (March 2014) - Electromagnetic compatibility and Radio spectrum Matters (ERM); Definition of radio parameters

See for additional information。

EU: New IEC Standards Recently Released

斗地主达人This is a shortened list of the new IEC standards published during the past month:

  • - (2/19/2014) - Corrigendum 1 - Medical electrical equipment - Part 2-2: Particular requirements for the basic safety and essential performance of high frequency surgical equipment and high frequency surgical accessories
  • - (2/19/2014) - Guidelines for the measurement method of nonlinearity for surface acoustic wave (SAW) and bulk acoustic wave (BAW) devices in radio frequency (RF)
  • - (2/24/2014) - Conformity assessment -- Vocabulary related to competence of persons used for certification of persons
  • - (2/25/2014) - Household and similar electrical appliances - Safety - Part 2-6: Particular requirements for stationary cooking ranges, hobs, ovens and similar appliances
  • - (2/25/2014) - Medical electrical equipment - Part 1-2: General requirements for basic safety and essential performance - Collateral Standard: Electromagnetic disturbances - Requirements and tests
  • - (2/25/2014) - Medical electrical equipment - ALL PARTS
  • - (2/26/2014) - Specification for radio disturbance and immunity measuring apparatus and methods - Part 2-1: Methods of measurement of disturbances and immunity - Conducted disturbance measurements
  • - (2/26/2014) - Audio/video, information and communication technology equipment - Part 1: Safety requirements
  • - (3/6/2014) - Fire hazard testing - Part 9-2: Surface spread of flame - Summary and relevance of test methods
  • - (3/6/2014) - Classification of environmental conditions - Part 2-9: Environmental conditions appearing in nature - Measured shock and vibration data - Storage, transportation and in-use
  • - (3/6/2014) - Information technology - Wireless beacon-enabled energy efficient mesh network (WiBEEM) for wireless home network services - Part 1: PHY layer
  • - (3/11/2014) - Electric vehicle conductive charging system - Part 23: DC electric vehicle charging station
  • - (3/12/2014) - Amendment 1 - Information technology -- Telecommunications and information exchange between systems -- Local and metropolitan area networks -- Specific requirements -- Part 11: Wireless LAN medium access control (MAC) and physical layer (PHY) specifications - Prioritization of management frames (adoption of IEEE Std 802-11ae-2012)
  • - (3/12/2014) - Amendment 2 - Information technology -- Telecommunications and information exchange between systems -- Local and metropolitan area networks -- Specific requirements -- Part 11: Wireless LAN medium access control (MAC) and physical layer (PHY) specifications - MAC enhancements for robust audio video streaming (adoption of IEEE Std 802.11aa-2012)
  • - (3/12/2014) - Amendment 3 - Information technology -- Telecommunications and information exchange between systems -- Local and metropolitan area networks -- Specific requirements -- Part 11: Wireless LAN medium access control (MAC) and physical layer (PHY) specifications - Enhancements for very high throughput in the 60 GHz band (adoption of IEEE Std 802.11ad-2012)
  • - (3/14/2014) - Specification for radio disturbance and immunity measuring apparatus and methods - Part 2-3: Methods of measurement of disturbances and immunity - Radiated disturbance measurements
  • - (3/14/2014) - Amendment 2 - Specification for radio disturbance and immunity measuring apparatus and methods - Part 2-3: Methods of measurement of disturbances and immunity - Radiated disturbance measurements
  • - (3/19/2014) - Intrepretation Sheet 1 - Explosive atmospheres - Part 28: Protection of equipment and transmission systems using optical radiation
  • - (3/21/2014) - Specification for radio disturbance and immunity measuring apparatus and methods - Part 1-2: Radio disturbance and immunity measuring apparatus - Coupling devices for conducted disturbance measurements
  • - (3/21/2014) - Specification for radio disturbance and immunity measuring apparatus and methods - ALL PARTS

See for additional information.

US - FCC Publishes Provider-Specific Signal Booster Compliance Measurement Guidance

On 3/6/2014, the FCC published a draft version of .

斗地主达人935210 D04 Provider-Specific Booster Measurements v01 (Draft) provides guidance for demonstrating compliance to the various requirements for Provider-Specific Consumer Signal Boosters as specified in paragraph 20。21(e), Consumer Signal Booster Network Protection Standard。 The document also represents the current version of an ongoing effort by the RF Booster Task Group within the ASC C63® Wireless Working Group to develop applicable measurement guidance。 The procedures described represent draft guidance and as such are still subject to further review, evaluation and update。 The guidance is being offered now as a draft KDB so as to provide the opportunity for review and comment。 The measurement procedures will be further refined as necessary based on comments received from the public and the ASC C63® working group。 Alternative measurement procedures acceptable to the FCC may also be used to prepare data demonstrating compliance to the applicable technical and operational requirements as per Section 2。947(a)(3) of the FCC rules:

  • The current KDB publication 935210 includes attachments D01 Booster Definitions, D02 Certification Requirements, and D03 Signal Booster Measurement. These attachments are final and are not open for comment.
  • Draft 935210 D04 Provider-Specific Booster Measurements v01is open for comment during the open comment period. The measurement procedure may be used to demonstrate compliance with the technical requirements. The FCC encourages the use of this procedure on actual devices to determine if further changes should be made and encourages all parties to provide comments based on experience with applying the test procedures.

Canada - RSS-216 (Wireless Chargers) Draft Released for Comment

斗地主达人In mid-March 2014, Industry Canada released : Radio Standards Specification 216, Issue 1, Wireless Power Transfer Devices (Wireless Chargers), which sets out the minimum requirements for wireless power transfer devices with power management and/or control capabilities。 These devices are either defined as Category I equipment or Category II equipment as per RSS-Gen。 Industry Canada is seeking industry input on the draft by Thursday, April 17, 2014。

Canada - Release of RSS-287, Issue 2

On March 8, 2014 Industry Canada published and adopted Radio Standards Specification RSS-287, Issue 2, Emergency Position Indicating Radio Beacons (EPIRB), Emergency Locator Transmitters (ELT), Personal Locator Beacons (PLB), and Maritime Survivor Locator Devices (MSLD), which sets out the certification requirements for radio frequency beacons using the frequencies 121。5 MHz, 161。975 MHz, 162。025 MHz and 406 MHz。 These are EPIRBs for carriage on-board ships, ELTs for carriage on-board aircraft, PLBs for carriage on the person and MSLDs, which are designed to be worn on the person while aboard a marine vessel, and which can send an alert to a receiver installed on the vessel in a man overboard event。

Listed below are the changes:

  • The requirement that RSS-Gen, General Requirements and Information for the Certification of Radio Apparatus shall be used in conjunction with this RSS is stated.
  • Material common to most Radio Standards Specifications has been moved to RSS-Gen.
  • An addition of technical requirements for Maritime Survivor Locator Devices (MSLDs) operating at 161.975 MHz and 162.025 MHz has been made.
  • The manufacturing, importation, or sale for use of EPIRB and PLB that operates only on 121.5 MHz or 243 MHz is prohibited.
  • ELT equipment without 406 MHz frequency is not allowed to be certified.
  • PLB equipment is required to include a homing frequency on 121.5 MHz.
  • The previous requirement to submit a letter of ELT approval from Transport Canada has been replaced with the requirement for a certification applicant to submit a Declaration of Conformity (DOC) that ELT complies with the requirements outlined in the Canadian Aviation Regulations Part VI, Section 605.38, Airworthiness Manual (AWM) 551.104.

EU - New Radio Equipment Directive Adopted

斗地主达人On March 13, 2014, the text of the new was adopted by the Members of the EU Parliament (MEPs) and now awaits approval by the EU Council. After council approval, RED will then be published in the Official Journal of the European Union. Member states will have two years to transpose the rules into their national laws and manufacturers will have an additional year to comply.

Changes in the new directive are as follows:

  • A clearer requirement that radio receivers achieve a minimum level of performance so as to contribute to an efficient use of radio spectrum;
  • Clear obligations for manufacturers, importers and distributors. The new directive is aligned with the New Legislative Framework for products (IP/14/111), which makes the overall regulatory framework for products more consistent and easier to apply;
  • Improved instruments for market surveillance, in particular the traceability obligations of manufacturers, importers and distributors and the possibility to require prior registration of radio equipment within categories affected by low levels of compliance;
  • Deletion of unnecessary administrative obligations, such as the prior notification of radio equipment using non-harmonised frequency bands.
  • The Commission will have the possibility to require that mobile phones and other portable devices are compatible with a common charger.
  • The new directive also introduces some new specific requirements:
    • Ensure that software can only be used with radio equipment after the compliance of that particular combination of software and the radio equipment has been demonstrated;

斗地主达人Please see the article that references (a) the push for a common charger and (b) the inclusion in the RED of the option for a registration database.

Argentina - Re-test at Renewal Required for WLAN & BT Devices

Our local agent in Argentina recently informed us that in accordance with "Protocolo de equipos de espectro ensanchado por salto en frecuencia", all WLAN (2.4GHz & 5GHz) and Bluetooth 4.0 products will require re-testing at the time of renewal of Type Approval in Argentina.

Additional information is provided below:

  • For all devices currently being imported and sold in Argentina, manufacturers must ensure that the 5600 - 5650MHz portion of the 5GHz Band 3 (for all WLAN devices) is disabled*. This corresponds to the following channels:
    • 802.11a and 802.11n (HT20): channels 120, 124 and 128
    • 802.11n (HT40): channels 118 and 126
    • 802.11ac (VHT80): channel 122
  • For new and renewal applications submitted for local testing, sample requirements remain unchanged. Local labs will simply not perform conformance testing in the 5600 - 5650MHz portion of 5GHz Band 3.
  • In addition, all Bluetooth 4.0 and 2.4GHz WLAN radios will need to be re-tested at the time of renewal and in accordance with the new regulation.
  • All current Type Approvals remain valid until their expiration date.

*A frequency notch is required for master devices; for client devices passive scanning only is sufficient.

Brazil - IEC 60601 Requirements

Brazil's INMETRO recently issued new requirements under Normative Instruction 9/2013 that expand certification requirements for some electronic and other medical devices.

Normative Instruction 9/2013 adds 30 types of medical devices to the list of products requiring INMETRO certification in order to obtain market authorization in Brazil.

Devices requiring INMETRO certification now include self-test glucose meters, products where 61010-2-101:2002 testing is applied, gas mixers used for medical purposes and in vitro diagnostic (IVD) equipment。

Additionally, compliance with the 3rd Edition of the NBR IEC 60601 standard for electrical equipment is now required for INMETRO certification. However, ANVISA will, on a temporary basis, accept INMETRO certifications using IEC 60601 2nd Edition that were obtained after December 31, 2013, but only until the full accreditation and training of the medical device applicant's INMETRO certifier.

斗地主达人Per Rhein Tech's local contact in Brazil, no INMETRO certifiers have the current capability to issue test reports according to the new IEC 60601 standard. Until INMETRO laboratories are able to certify devices according to IEC 60601 3rd Edition, registrants will need to submit letters from their INMETRO certifiers explaining inabilities to provide test results based on the new standard.

ANVISA has set a December 2014 deadline for implementing new regulations requiring all INMETRO certifiers be accredited and trained in IEC 60601 3rd Edition。 Currently, existing INMETRO certification requirements remain in effect for medical device registrants。 Our local agent believes ANVISA will provide official notice that IEC 60601 2nd Edition-compliant INMETRO certification will continue to be accepted on a temporary basis, but the regulator has issued no such statement as of yet。 We will provide additional details as soon as possible。

United Arab Emirates - Samples Now Required for Type Approval

On March 3, 2014, we were updated that the Regulatory Authority of the United Arab Emirates (UAE) will require one test sample for most RF Type Approvals。 Furthermore, two test samples are required for GSM Type Approvals。 Test samples are non-returnable and will be kept by the Authority for market surveillance issues。 UAE Type Approvals have a validity of three years and renewal applications also now require the submission of test samples。 Previously, the Type Approval process for the UAE was a paperwork effort only (with appropriate test reports) and no samples were required。

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