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MultiPoint Newsletter - November 2015

Non-Modularly Approved Device in Host

Question: We are an OEM and would like to manufacture a product that contains an embedded computer with USB ports, to which we want to add wireless connectivity using a Wi-Fi USB dongle which would be inaccessible to the end user. This USB dongle has FCC certification, but is not certified as a module. Does the Wi-Fi USB dongle require additional testing and/or certification?

Answer:斗地主达人 Had you asked this question two months ago, the answer would have been “yes”. Previously, the FCC would have required that the USB dongle be certified as a module, or be accessible to the user.

But just last month, the FCC released new guidance that will allow use of the USB dongle as-is. The FCC now allows some non-modularly certified devices to be contained within hosts and not be accessible to the end user (under some conditions).

Specifically, the non-modularly approved device (transmitter) must also be a computer peripheral approved via certification or the DoC procedure, be unmodified, and use only the antennas originally approved with the transmitter。

Please see the most recent module guidance from the FCC for specific details and host labelling instructions here.

Importation and Form 740

Question: We import many FCC-certified devices, and have always had to complete FCC Form 740 and attach it to our custom import papers per 47CFR§2.1203 and 47CFR§2.1205. Our supplier has recently informed us this is no longer necessary. Is this true, and if so, do you have any additional details?

Answer: Your supplier is not quite right, but here are the details. On October 19, 2015, the FCC released FCC 15-135 which temporarily waives the requirements of 47CFR§2.1203 and 47CFR§2.1205 only from July 1, 2016, to December 31, 2016. The main reason for this waiver is that U.S. Customs and Border Protection (CBP) is in the process of updating their electronic filing system to a new system called the Automated Commercial Environment (ACE), and this system does not currently have the capability to accept Form 740 information.

斗地主达人We are not sure what the requirements will be after the expiration of the waiver on December 31, 2016. The new ACE system could be modified to accept the typical information found on Form 740, but no decisions have been made. We will update you when the FCC releases additional information.

Identifying Equipment Authorization Process

Question:斗地主达人 We are a manufacturer of industrial process equipment for industries such as food, chemical, oil & gas, etc. Our products measure and monitor several liquid parameters, and they contain digital circuits, but no wireless transmitters. How do we determine the required FCC equipment authorization process?

Answer: Assuming your digital circuitry operates at greater than 9 kHz, it would be considered a “digital device” per . Since your device is intended for an industrial environment, it would be considered a “Class A digital device”; per and thus subject to the FCC verification procedure per the following table taken from .

Type of device Equipment authorization required
TV broadcast receiver Verification.
FM broadcast receiver Verification.
CB receiver Declaration of Conformity or Certification.
Superregenerative receiver Declaration of Conformity or Certification.
Scanning receiver Certification.
Radar detector Certification.
All other receivers subject to part 15 Declaration of Conformity or Certification.
TV interface device Declaration of Conformity or Certification.
Cable system terminal device Declaration of Conformity.
Stand-alone cable input selector switch Verification.
Class B personal computers and peripherals Declaration of Conformity or Certification. 1
CPU boards and internal power supplies used with Class B personal computers Declaration of Conformity or Certification. 1
Class B personal computers assembled using authorized CPU boards or power supplies Declaration of Conformity.
Class B external switching power supplies Verification.
Other Class B digital devices & peripherals Verification.
Class A digital devices, peripherals & external switching power supplies Verification.
Access Broadband over Power Line (Access BPL) Certification.
All other devices Verification.

Module Colocation - Update

In the October MultiPoint, we presented the following Q/A. Based on updated FCC guidance released in October, we have updated the answer; please see “Answer (updated)” below.

Question: Frequently, our customers want to place two certified modules on the same host PCB, though the individual module grants do not permit colocation. Is there a way we can obtain FCC and IC certification for an end product with this configuration?

Answer: In these cases, we recommend a Class II permissive change to the grant for one of the modules, in order to allow colocation with the other module in your specific host. Intentional emissions with both transmitters transmitting simultaneously should be tested, with particular attention paid to any intermodulation products or increased spurious emissions.

Unintentional emissions to FCC Part 15B/ICES-003 should also be performed for your host.

If your application is mobile or fixed (typical use >20 cm from users), an RF exposure MPE calculation should be done considering both transmitters transmitting simultaneously. If it is a portable application, SAR testing may have to be performed depending on the combined output power of both transmitters.

Answer (updated): For a mobile device (use >20 cm from persons), a Class 1 permissive change per 47CFR§2.1043(b)(1) may apply in certain circumstances. MPE must be evaluated for the simultaneous transmissions, and if the result shows that the MPE test exclusion applies, a Class 1 approach may be used. The MPE evaluation, as well as the emissions test results for simultaneous transmission and unintentional emissions per FCC Part 15B, should be included in the Class 1 permissive change documentation that you keep on file.

Please see the following for more details:

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:

  • - 11/6/2015 - Cable networks for television signals, sound signals and interactive services - Part 2: Electromagnetic compatibility for equipment
  •  - 11/6/2015 - Surface acoustic wave (SAW) filters of assessed quality - Part 1: Generic specification
  • - 11/6/2015 - Organic light emitting diode (OLED) panels for general lighting - Safety requirements
  • - 10/30/2015 - Fire hazard testing - Part 1-11: Guidance for assessing the fire hazard of electrotechnical products - Fire hazard assessment
  • - 10/30/2015 - Electric motor-operated hand-held tools, transportable tools and lawn and garden machinery - Safety - 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:

  •  - (October 2015) - Meteorological Aids (Met Aids); Radiosondes to be used in the 400,15 MHz to 406 MHz frequency range with power levels ranging up to 200 mW; Part 2: Harmonised Standard covering the essential requirements of article 3.2 of the Directive 2014/53/EU
  •  - (October 2015) - Meteorological Aids (Met Aids); Radiosondes to be used in the 1 668,4 MHz to 1 690 MHz frequency range; Part 1: Technical characteristics and test methods
  •  - (October 2015) - Meteorological Aids (Met Aids); Radiosondes to be used in the 1 668,4 MHz to 1 690 MHz frequency range; Part 2: Harmonised Standard covering the essential requirements of article 3.2 of the Directive 2014/53/EU         
  • - (November 2015) - Fixed Radio Systems; Energy efficiency metrics and test procedures for Point-to-point fixed radio systems
  • - (November 2015) - Short Range Devices (SRD); Medical Body Area Network Systems (MBANSs) operating in the 2 483,5 MHz to 2 500 MHz range; Harmonised Standard covering the essential requirements of article 3.2 of the Directive 2014/53/EU

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:

  • - (10/29/2015) - Primary batteries - Part 2: Physical and electrical specifications
  • - (10/30/2015) - Safety requirements for radio transmitting equipment - General requirements and terminology
  • - (10/28/2015) - Corrigendum 1 - Luminaires - Part 1: General requirements and tests
  • - (10/30/2015) - Fire hazard testing - Part 1-20: Guidance for assessing the fire hazard of electrotechnical products - Ignitability - General guidance
  • - (11/5/2015) - Electromagnetic compatibility (EMC) - Part 4-24: Testing and measurement techniques - Test methods for protective devices for HEMP conducted disturbance
  • - (10/29/2015) - Integrated circuits - Measurement of electromagnetic immunity - Part 1: General conditions and definitions
  • - (11/4/2015) - Metallic communication cable test methods - Part 4-10: Electromagnetic compatibility (EMC) - Transfer impedance and screening attenuation of feed-throughs and electromagnetic gaskets - Double coaxial test method

See for additional information。

FCC - SAR Guidance and Test Procedures for 3G/4G Devices Updated

On October 23, 2015, the FCC updated the following SAR guidance and test procedures:

  • :  SAR test procedures for 3G devices that operate under rule Parts 22H, 24E, 27L.  Note:  Previous versions of KDB 941225 D01, D02, D03 and D04 were consolidated into a single document to provide SAR measurement guidance for 3G wireless technologies.  This update also replaces PBA with PAG and corrects two typos.
  • :  SAR test procedures for devices incorporating Release 8 Long Term Evolution (LTE) capabilities.  This update removes outdated information, adds TDD test setup requirements and includes other minor clarifications on certain large frequency bands and A-MPR conditions.
  • :  Guidance on submitting KDB inquiries regarding the evaluation of devices using LTE Rel. 10 to SAR requirements.  This update clarifies the downlink carrier aggregation channel selection conditions for uplink power measurement, changes PBA to PAG, includes minor clarifications for LTE-U, LAA and LWA, and adds heading numbering.
  • :  SAR test procedures for devices incorporating SAR Evaluation Procedures for Portable Devices with Wireless Router Capabilities (Hot Spot SAR).  This update replaces PBA with PAG and includes minor editorial clarification for hotspot mode and body-worn accessory test consideration, and adds heading numbering.
  • :  SAR Evaluation Procedures for UMPC Mini-Tablet Devices.  This update includes editorial and format changes and updates footnote 1.

FCC - New Guidance on Non-SDR Devices Issued

斗地主达人On November 12, 2015, the FCC revised the rules effective June 2, 2014 for U-NII devices operating under Part 15 to require that all devices implement software security to ensure that the devices operate as authorized and cannot be modified. provides guidance on the information that must be provided in the application filing to show that proper security is implemented in the device. The FCC has established a transition period as follows:

  • New devices will be permitted to be approved under the old rules until June 1, 2015.
  • Starting June 2, 2016, permissive changes will not be permitted for devices approved under the old rules, unless they meet the requirements of the new rules.
  • All devices partially or completely approved under the old rules cannot be marketed starting June 2, 2016 unless they meet the requirements of the new rules in all the bands of operation.
  • Applications for devices for approval under the new rules must apply all of the applicable test procedures for such devices and provide software security documentation as discussed in 594280 D02 U-NII Device Security.  This also applies to all applications for new devices and applications for permissive changes of previously approved devices under the new rules.  Further, SDR devices must also provide software security documentation as discussed in 594280 D02 U-NII Device Security and KDB Publication 442812.
  • For further information on transition rules and requirements for permissive changes of already approved devices, refer to KDB Publication 926956.

Note: Effective January 1, 2015 equipment authorization applications for all new Wi-Fi Client devices capable of operating on Channels 12 and 13 (in 2.4 GHz band under Part 15 rules) must demonstrate compliance with the guidance in . Wi-Fi Client devices capable of operating on Channels 12 and 13 approved prior to that date, and otherwise relying on passive scanning modes, may be marketed without modification after that date.

Paraguay - 865-868 MHz Band Closed to New Product Approvals

斗地主达人In September, we were advised by our local agent that the Paraguayan Authority, Comisión Nacional de Telecomunicaciones (CONATEL), is no longer approving 915-928 MHz spread spectrum devices due to interference problems. In November, our local agent advised us that CONATEL is no longer approving 865-868 MHz spread spectrum devices either. CONATEL is discussing the possibility of re-opening the 915-928 MHz band for spread spectrum devices in the future, however a timeframe has not been provided. Additionally, we've been advised that products operating in these bands and with an existing Paraguayan Type Approval certificate may continue to operate until the existing Type Approval certificate expires.

Mexico – Temporary Standard Issued for Wi-Fi and Bluetooth Devices

As previously reported, Mexico's standard for Wi-Fi and Bluetooth (NOM-121) expired October 19, 2015. Mexico's Secretary of Economy has since issued a temporary standard, NOM-EM-016-SCFI-2015, to replace NOM-121 for six months. This temporary standard refers to the parameters set out in IFT-008 and after six months, there will be a new permanent NOM standard adopted that will also reflect IFT-008. Testing parameters will not change but all certifications completed under NOM-EM-016-SCFI-2015 will need to be updated to the new NOM standard, via a paperwork exercise.

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