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Product Labeling under RED

Posted on April 22nd 2017 by


Question: We have a small radio product that we intend to distribute in EU member states. Due to the small size of the product, there is not enough space to affix our company name, company address, and model number, but we want to be in compliance with the requirements of the RED. What options do we have?

Answer: RED Article 10.7 stipulates that “Manufacturers shall indicate on the radio equipment their name, registered trade name or registered trade mark and the postal address at which they can be contacted or, where the size or nature of radio equipment does not allow it, on its packaging, or in a document accompanying the radio equipment. The address shall indicate a single point at which the manufacturer can be contacted. The contact details shall be in a language easily understood by end-users and market surveillance authorities.” Please keep in mind that all RED-compliant products are subject to market surveillance, so all requirements should be implemented as directed.


Question: Our wireless device operates between 2402 MHz ‑ 2481 MHz。 However, we intend to only use 2424 MHz ‑ 2479 MHz for our Ministry of Information and Communication (MIC) Japanese certification。 Is this acceptable for MIC certification?

Answer: The requirement in MIC regulations is that frequencies of operation fall within the frequency band of 2400 ‑ 2483。5 MHz; there are no specific frequencies of operation defined in the regulation(s)。 The lowest and highest possible frequencies in this band are determined by the 99% bandwidth, which must fall within 2400 MHz ‑ 2483。5 MHz。 Furthermore, your device must comply with the emission limit within the authorized band and the emission limits at the band edges。 The test report and all supporting documents must indicate the frequency range as defined in the operational description and block diagram, and for which your device was tested。 Therefore, for this device, the tested frequency range, to be reported in the operational description, block diagram, and test report, should be 2402 MHz ‑ 2481 MHz。


This is a shortened list of the new IEC standards published during the past month:

  • - (3/28/2017) - Semiconductor devices - Semiconductor devices for energy harvesting and generation - Part 3: Vibration based electromagnetic energy harvesting
  • - (3/31/2017) - Amendment 1 - Electromagnetic compatibility (EMC) - Part 2-2: Environment - Compatibility levels for low-frequency conducted disturbances and signalling in public low-voltage power supply systems
  • - (3/31/2017) - Amendment 1 - Medical electrical equipment - Part 2-63: Particular requirements for the basic safety and essential performance of dental extra-oral X-ray equipment
  • - (3/31/2017) - 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
  • - (3/31/2017) - Medical electrical equipment - Part 2-75: Particular requirements for the basic safety and essential performance of photodynamic therapy and photodynamic diagnosis equipment
  • - (4/10/2017) - Electricity metering data exchange - The DLMS/COSEM suite - Part 8-6: High speed PLC ISO/IEC 12139-1 profile for neighbourhood networks
  • - (4/10/2017) - Household and similar electrical appliances - Safety - Part 2-36: Particular requirements for commercial electric cooking ranges, ovens, hobs and hob elements
  • - (4/11/2017) - Electric toys - Safety
  • - (4/11/2017) - Product package labels for electronic components using bar code and two-dimensional symbologies
  • - (4/12/2017) - Electroacoustics - Simulators of human head and ear - Part 7: Head and torso simulator for the measurement of air-conduction hearing aids
  • - (4/14/2017) - Uninterruptible power systems (UPS) - Part 1: Safety requirements
  • - (4/19/2017) - Amendment 2 - Household and similar electrical appliances - Safety - Part 2-24: Particular requirements for refrigerating appliances, ice-cream appliances and ice makers
  • - (4/21/2017) - Electromagnetic compatibility (EMC) - Part 3-11: Limits - Limitation of voltage changes, voltage fluctuations and flicker in public low-voltage supply systems - Equipment with rated current ≤ 75 A and subject to conditional connection
  • - (4/21/2017) - Electromagnetic compatibility (EMC) - Part 3-11: Limits - Limitation of voltage changes, voltage fluctuations and flicker in public low-voltage supply systems - Equipment with rated current ≤ 75 A and subject to conditional connection

See for additional information.


This is a shortened list of the CENELEC standards published or made available during the past month:

  • - 4/7/2017 - Explosive atmospheres - Part 30-1: Electrical resistance trace heating - General and testing requirements
  • - 4/14/2017 - Information technology equipment - Safety - Part 22: Equipment to be installed outdoors
  • - 4/21/2017 - Industrial, scientific and medical equipment - Radio-frequency disturbance characteristics - Limits and methods of measurement
  • - 4/21/2017 - Safety requirements for electrical equipment for measurement, control, and laboratory use - Part 2-011: Particular requirements for refrigerating equipment
  • - 4/21/2017 - Safety requirements for electrical equipment for measurement, control and laboratory use - Part 2-202: Particular requirements for electrically operated valve actuators
  • - 4/21/2017 - Mechanical structures for electronic equipment - Tests for IEC 60917 and IEC 60297 series - Part 1: Environmental requirements, test set-up and safety aspects for cabinets, racks, subracks and chassis under indoor condition use and transportation
  • - 4/21/2017 - Safety of primary and secondary lithium cells and batteries during transport
  • - 4/28/2017 - Safety requirements for electrical equipment for measurement, control, and laboratory use - Part 2-020: Particular requirements for laboratory centrifuges
  • - 4/28/2017 - Adjustable speed electrical power drive systems - Part 5-1: Safety requirements - Electrical, thermal and energy
  • - 4/28/2017 - Fluorescent induction lamps - Safety specifications
  • - 4/28/2017 - Electromagnetic compatibility - Requirements for household appliances, electric tools and similar apparatus - Part 1: Emission
  • - 4/28/2017 - 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。



  1. We have warehouses in the EU with products deemed compliant with the R&TTE Directive. How long can we continue to sell these products in the EU?
  2. Our products provide Bluetooth connectivity via USB port to other devices such as microcontrollers. Are these other devices subject to the RED?
  3. Our products provide Wi-Fi connectivity through the physical integration of our Wi-Fi hotspot with other devices such as microcontrollers. Are these devices subject to the RED?


  1. Based on the minimal description provided, and the RED definition of “placing on the market”, the products in the warehouse may be able to be sold after June 13, 2017. However, before making any final determinations, we strongly recommend that manufacturers/importers read sections 2.1 to 2.5 and 3.1 to 3.6 of the , the “Blue Guide” on the implementation of EU products rules 2016.
  2. The BT radio must always be compliant with the RED, but since the BT connectivity is via USB only, easily removable, and not integrated nor installed within the microcontroller, the microcontroller must only comply with the EMC Directive and the LV Directive as a non-radio product。
  3. The physical, or permanent, integration of your Wi‑Fi hotspot into another device, e.g. a microcontroller, now makes that other device a radio product under the terms of the RED. Conversely, as with the BT radio above, if the Wi‑Fi hotspot was not permanently installed, and could be easily removed, e.g. a Wi‑Fi micro-card installed in a slot, the Wi‑Fi micro‑card is the radio product that must comply with the RED, whereas the microcontroller is a non radio product, and therefore must comply with the EMC‑D and the LV-D.

    Note: The RED does not allow application of the EMC Directive, as was allowed under the R&TTE. The RED includes all equipment that contains a radio, including those with a combination of multiple radio products in one, or a combination of radio and non-radio products.


On March 31, 2017, South Africa’s ICASA published Government Gazette no。 40733, , to inform the industry of its regulatory position on the equipment type approval exemption as follows:

  • There are no upfront exemptions granted on the basis of types of equipment at this stage。
  • ICASA will develop a framework for the exemption of equipment operating under certain circumstances. ICASA has listed some such circumstances as follows:
    • systems and equipment used for the production and distribution of broadcast and content services
    • test and measurement equipment used by professionals and engineers of a licensed entity in the provision of telecommunications or broadcast services
    • satellite communications equipment
    • equipment for research and development in the laboratory environment
    • equipment for demonstrations of prototypes and testing
    • equipment for sample testing, demonstrations and field trials
    • equipment for demonstrations and exhibitions
    • equipment for operations of specialized agencies
    • equipment for maritime or aeronautical operations
    • radio telescope array and radio astronomy facilities
    • amateur radios for the purposes of self‑training, intercommunication and technical investigations carried out by amateurs on a non‑commercial basis
    • equipment used by government services for national security and defense networks
    • equipment produced or imported for purposes of exporting and not for use in South Africa
    • spare parts, components to be used for repairs, provided that such part is used in a certified product
  • ICASA will consider entering into and amending existing memoranda of understanding with other regulatory bodies, such as the National Regulator for Compulsory Specifications.
  • ICASA will review its current type approval regulatory framework. The intention is to incorporate the circumstances under which mutual recognition agreements will be recognized, in a bid to improve market surveillance.


On March 23, 2017, the FCC took steps to reform certain outdated rules applicable to the 800 MHz cellular service band to facilitate the use of cellular spectrum for mobile broadband services such as long term evolution (LTE). Specific reforms adopted in this revision include:

  • Power Reform: FCC will facilitate broadband technologies by changing its technical rules to permit cellular licensees to transmit the same amount of power across the spectrum band, whether they are deploying a legacy (narrow bandwidth) technology or modern (wider bandwidth) technology like LTE.
  • Co-existence with Public Safety: FCC will continue to ensure co-existence of cellular and neighboring public safety systems by retaining cellular-specific interference resolution rules and procedures, and by engaging stakeholders via a public forum.
  • Consistent Treatment with Similar Spectrum Bands: FCC will treat cellular spectrum consistently with other similar commercial wireless spectrum bands by conforming rules related to power measurement, out of band emissions, field strength, and discontinuance of operations.
  • Unnecessary rules/burdens: FCC will eliminate unnecessary rules and burdens related to application filings, domestic and international coordination, and comparative renewal.


On March 17, 2017, Vietnam’s Ministry of Information and Communications (MIC) issued document No。 886/BTTTT-KHCN as guidance on the regulations contained in Circular 42/2016/TT-BTTTT with the following highlights:


  • Terminal public land mobile communication network equipment which is not used in land mobile communication service networks, and uses CDMA 2000-1x in the 800 MHz and 450 MHz bands, shall not require Type Approval or Declaration of Conformity (DoC), (in accordance with QCVN13:2010/BTTTT).
  • 60 GHz high speed radio accessing equipment shall be Type Approved against QCVN18:2014/BTTTT until September 30, 2018.  From October 1, 2018, the applicable standards will be QCVN18:2014/BTTTT and QCVN 88:2015/BTTTT. 
  • Digital microwave equipment operating above 40 GHz will be assessed against QCVN18:2014/BTTT, provided the operating band is compliant with the national frequency allocation plan. 
  • For DVB-S/S2 set-top-box equipment and tablets, a DoC shall not be required until 
    April 1, 2018. 
  • Lithium batteries for notebook computers, mobile phones and tablets, including integrated and separable batteries, shall only require a DoC from October 1, 2017.

Test reports accepted for DoC procedure

The use of test reports for DoCs shall be in accordance with Circular 30/2011/TT-BTTTT and with additional guidance as follows:

  • DVB-S/S2 receiving equipment - MIC temporarily accepts test reports in accordance with QCVN80:2014/BTTTT. 
  • Technical requirements for DVB-T in QCVN63:2012/BTTTT - MIC temporarily accepts test reports of the manufacturer for DVB-T2 Set Top Boxes. MIC continues to accept test reports based on QCVN63:2012/BTTTT for the chassis/platform (except for requirements in TCVN7600:2010) for DVT-T2 TVs. 
  • DoCs based on TCVN7189:2009 - MIC temporarily accepts test reports based on TCVN7189:2009 or EN 55032/CISPR 32。 

Separable or integrated lithium batteries - MIC temporarily accepts reports from testing labs accredited under ISO/IEC 17025; the declaration dossier must be submitted。

EU – RED Guidance

Posted on March 17th 2017 by


Recently, the EU Commission released situation as follows:

  • The new RED regulations became necessary due to the increasing number of devices with integrated radio capabilities on the market。
  • The aim of the RED is to ensure that all electrical and electronic devices that emit or receive radio waves adhere to essential safety and health requirements, taking care of the efficient use of radio spectrum and electromagnetic compatibility.
  • The RED became applicable on June 13, 2016 with a transitional period of one year, to ensure smooth transition from the former R&TTE Directive。

Currently ETSI, the European standardization organization, has submitted roughly 70% of the total standards needed。 Of these, 65 standards were received positively。 The EU commission and ETSI are now working on a solution to quickly increase the number of standards available by the beginning of June 2017。

In the meantime, manufacturers and suppliers are advised as follows:

  • In case ETSI does not deliver the missing standards on time, and/or the EU commission and ETSI cannot agree on a solution to speed up the process:
    • the EU commission could, on an interim basis, enforce the former R&TTE rules, for the currently missing standards
    • manufacturers can use alternative conformity assessment procedures to show that their products meet the requirements to legally place their products on the market in the EU and affix the CE marking. This can be achieved by using an accredited test laboratory in combination with a Notified Body.


Earlier this year, Canada’s ISED (Innovation, Science and Economic Development) published RSS‑131 Issue 3 with a transition period of July 1, 2017, setting out the certification requirements for zone enhancers used in conjunction with licensed radio equipment in certain radio services。 On March 28, 2017, ISED published a notice seeking comments on extending the transition period applicable to zone enhancers for compliance with the requirements of RSS‑131 Issue 3 until January 1, 2018。 After January 1, 2018, zone enhancers would have to comply with RSS‑131 Issue 3 in order to be manufactured, imported, distributed, leased, offered for sale, or sold in Canada, and to prevent harmful interference to wireless networks。

Israel’s Ministry of Communications (MoC), has advised via a Free Import Regulation letter dated January 21, 2017 that they will be no longer issue Type Approval certificates for simple wireless communication technologies. The following equipment no longer requires Type Approval by the MoC:

  1. Equipment ONLY operating with Bluetooth (BT) technology;
  2. Equipment ONLY including a receptor for satellite broadcasting to determine geographical location in systems such as GPS or GLONASS;
  3. Equipment ONLY operating in the technologies listed in both 1 & 2

If a device contains Bluetooth/GPS or GLONASS receiver technology, along with any other technology, such as WLAN, it remains mandatory to apply for Type Approval at MoC. This change of policy is for the radio regulations only. EMC and Safety Approval from the Standards Institute of Israel (SII) should still be obtained as before.

On February 23, 2017, Industry Canada released replacing RSS-247, Issue 1, dated May 2015.  Changes to Issue 2 are as follows:

  1. new section 3.3: state the requirement for emissions that fall within restricted frequency bands to comply with the provisions in RSS-Gen, General Requirements for Compliance of Radio Apparatus;
  2. section 5.4(b): reinstated the former e.i.r.p. limit for frequency hopping systems operating in the band 2400-2483.5 MHz, which employ a hopset with less than 75 channels
  3. section 6。2: add a clarification to ensure that emissions that fall within restricted frequency bands shall comply with the provisions in RSS-Gen
  4. section 6.2: state the measurement method for power and unwanted emission limits for licence-exempt local area network devices and digital transmission systems operating in the 5 GHz band
  5. section 6。2。1 and 6。2。2: add a provision to allow original equipment manufacturer (OEM) devices installed in road vehicles to operate in the band 5150-5250 MHz with an e。i。r。p。 limit of 30 mW or 1。76 + 10 log10B, dBm, whichever is less stringent;
  6. section clarify the requirement for devices operating in the band 5150-5250 MHz, which have bandwidth that falls into the band 5250-5350 MHz;
  7. section 6。2。2。2 (b): permit the requisite "for indoor use only" notice for equipment operating in the band 5250-5350 MHz to be included in the user manual;
  8. section apply the requirement of e.i.r.p. at different elevations for equipment operating in the band 5250-5350 MHz to outdoor fixed devices only;
  9. section 6。2。2。3: limit e。i。r。p。 of OEM devices installed in road vehicles to 30 mW or 1。76 + 10 log10B, dBm, whichever is less stringent;
  10. section allow equipment, other than outdoor fixed devices, operating in the band 5250-5350 MHz having e.i.r.p. greater than 200 mW to either comply with the e.i.r.p. elevation mask or to include a firmware feature to reduce their e.i.r.p. permanently should it be requested by the Department;
  11. section 6。2。3。2: allow equipment operating in the band 5650-5725 MHz with bandwidth overlapping the band 5725-5850 MHz to meet the emission limit of −27 dBm/MHz e。i。r。p。 at 5850 MHz;
  12. section 6。2。4。2: modify the unwanted emission limits for LE-LAN devices and DTSs operating in the band 5725-5850 MHz;
  13. section add a transition date for certification of LE-LAN devices and DTSs operating in the band 5725-5850 MHz to have unwanted emissions comply with either provisions in section 5.5 or section;
  14. section 6.2.4(b): add a transition date for manufacture, importation, distribute, lease, offer for sales, or sales of LE-LAN devices and DTSs operating in the band 5725-5850 MHz which do not comply with provisions in section 6.2.4(b); and
  15. Annex A: delete the word "pre-installation" to clarify that the verification of e.i.r.p. compliance at different elevations for devices operating in the band 5250-5350 MHz needs to be done at the time of certification (before installation); the verification of compliance must be submitted with the test report for equipment requiring certification.


Please contact Rhein Tech Laboratories, Inc. for any questions and/or testing requirements. 703. 689. 0368 or email sales @ hfytxx.com.

Troubleshooting EMI with Lee Hill, SILENT Solutions LLC, Hosted by Rohde & Schwarz

Join this highly focused one-day seminar and learn how to uncover, characterize, and solve the most elusive EMI problems. Troubleshooting and localizing intermittent signals or multiple layers of broadband and narrowband signals can be frustrating even for the most seasoned EMC troubleshooter and RF engineer. We will discuss and demonstrate a number of test setups that can help the root causes of EMC test failures and then demonstrate how real-time analysis can literally make previously-hidden signals leap into plain view.

This seminar is intended for engineers and technicians involved in the development, troubleshooting, pre-compliance testing and certification of electronic products, systems and assemblies for EMC.

Effective on February 14, 2017, Vietnam’s Ministry of Information and Communications (MIC) newly released Circular 46/2016/TT-BTTTT came into effect.  Please see below for important changes found in the new Circular:

  1. Output power limit for WLAN products operating in 2400 – 2483.5 MHz is increased from 100 mW to 200 mW.
  2. For UHF RFID, the band 920-925 MHz is changed to 918-923 MHz.*
  3. Wireless charging technology is permitted on the following frequency bands: 9 - 148.5 kHz, 326.5 kHz, 340 kHz, 6.765 - 6.795 MHz.
  4. 924-925 MHz is no longer available for Cordless Telephones.
  5. A new band of 4200-4800 MHz is allocated to ultra-wide band devices.
  6. New bands are allocated to frequency alerting and detecting devices.
  7. New bands are allocated to wireless audio devices for hearing assistance.
  8. New bands are allocated to Equipment Automatic Identification (AIS).
  9. New bands are allocated to Automatic identification equipment development report for search and rescue (AIS-SART).

All RFID products currently approved for and using the band 920-925 MHz are allowed to be continuously imported, distributed and used in Vietnam until the expiration dates of their respective Type Approval certificates.  There is no impact on existing Type Approval certificates issued based on current Circular 03. For new applications, Type Approval certificates will be granted based on the Circular 46.

Indonesia’s Direktorat Jenderal Sumber Daya dan Perangkat Pos dan Informatika (SDPPI) recently indicated that a new policy is under consideration whereby paperwork only will be required for Indonesia’s Type Approval process. This new policy is expected to run in parallel with the current Type Approval process in place whereby local testing is conducted. Manufacturers will then have the option to proceed with either the new paperwork-only process or the existing local testing process. This new policy has not yet been published or released, but is expected to come into force in 2017.

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