red vs fcc

RED vs FCCCarlo Casati

Milan, 27 September 2017

Formal Requirements

30.06.20172 WORKSHOP UN MONDO SENZA FILI: RED & FCC

Regulations

30.06.2017 WORKSHOP UN MONDO SENZA FILI: RED & FCC3

U.S. Code (Common Law)

(U.S. Congress)

UE Treaty - Constitution

(EU Members)

Code of Federal Regulations(Federal Agencies)

Community Acquis

(European Council and Parliament)

State Laws

(Local governments)

National Codes

(EU Member Governments)

Sentences on similar cases (Great importance)

Sentences on similar cases (Minor importance)

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• USC = Code of the United States of America (U.S. Code)

• CFR = Code of Federal Regulations

• Title

• Volume

• Chapter

• Part

• Subpart

• Section

� 15 USC 1452 = U.S. Code Title 15 Section 1452

(Chapter 39)

� 47 CFR 15 Subpart C = Code of Federal Regulations

Title 47 Part 15 Subpart C (from section 15.201 to

15.257)


Structure of CFR 47

15.217 Operation in the band 160-190 kHz15.219 Operation in the band 510-1705 kHz15.221 Operation in the band 525-1705 kHz15.223 Operation in the band 1.705-10 MHz15.225 Operation within the band 13.110-

14.010 MHz15.227 Operation within the band 26.96-27.28

MHz15.229 Operation within the band 40.66-40.70

MHz15.231 Periodic operation in the band 40.66-

40.70 MHz and above 70 MHz15.233 Operation within the bands 43.71-44.49

MHz, 46.60-46.98 MHz, 48.75-49.51 MHz and 49.66-50.0 MHz

15.235 Operation within the band 49.82-49.90 MHz

15.237 Operation in the bands 72.0-73.0 MHz, 74.6-74.8 MHz and 75.2-76.0 MHz

15.239 Operation in the band 88-108 MHz15.240 Operation in the band 433.5-434.5 MHz15.241 Operation in the band 174-216 MHz

Intentional Radiators: 47 CFR Part 2 Subpart C

15.242 Operation in the bands 174-216 MHz and 470-668 MHz

15.243 Operation in the band 890-940 MHz15.245 Operation within the bands 902-928 MHz,

2435-2465 MHz, 5785-5815 MHz, 10500-10550 MHz, and 24075-24175 MHz

15.247 Operation within the bands 902-928 MHz, 2400-2483.5 MHz, and 5725-5850 MHz

15.249 Operation within the bands 902-928 MHz, 2400-2483.5 MHz, 5725-5875 MHZ, and 24.0-24.25 GHz

15.250 Operation of wideband systems within the band 5925-7250 MHz

15.251 Operation within the bands 2.9-3.26 GHz, 3.267-3.332 GHz, 3.339-3.3458 GHz, and 3.358-3.6 GHz

15.252 Operation of wideband vehicular radar systems within the bands 16.2-17.7 GHz and 23.12-29.0 GHz

15.253 Operation within the bands 46.7-46.9 GHz and 76.0-77.0 GHz

15.255 Operation within the band 57-64 GHz15.257 Operation within the band 92-95 GHz



Technical SpecificationsC

FR

47 • Part of the

Law

• Compulsory application

• No changes

EN

Sta

nd

ard

s • External specifications

• Voluntary application

• Updates

Equipment Authorization



Determine FCC Rules that Apply

• Determine if device is a Radio Frequency (RF) device subject to the FCC rules.

• Determine all applicable technical and administrative rules that apply to the device requiring an equipment authorization.

• The technical requirements are generally specified in the applicable FCC rule parts and the administrative rules are specified in Part 2, Subpart J.

Requirement RED FCC

Safety � � - OSHA (NRTL)

EMC � �

Radio � �


EMC and Radio

FCC

CFR 47

Part 2

Sub-part J

EMC

Part 15

Sub-part B

RadioPart 15

Sub-part COther relevant

Parts

Unintentional Radiators

Intentional Radiators

Radio Spectrum


Identical defined (Part 2 Subpart J Sect 2.908)

• As used in this subpart, the term

identical means identical within

the variation that can be expected

to arise as a result of quantity

production techniques.

• No extensions by technical documentation is permitted under FCC regulations


Equipment Authorization Procedures

• If a device is subject to FCC rules, determine the

specific type of equipment authorization that applies

to the device. Become familiar with all the basic

marketing, equipment authorization, and importation

rules. In some instances, a device may have different

functions resulting in the device being subject to

more than one type of approval procedure.

Certification

(by Certification Bodies) EU Declaration of Conformity

(for some products it has to

be substantiated by Notified

Bodies)

CE certification

Declaration of Conformity

(by Manufacturer)

Verification

(Label data must be

substantiated)


Compliance Testing

• Declaration of Conformity: Equipment approved using the DoC procedure is required to be tested by an FCC Recognized Accredited Testing Laboratory. The Commission maintains a list of the FCC Recognized Accredited Testing Laboratories.

• Certification: Equipment approved under the Certification procedure is required to be tested by an FCC Recognized Testing Laboratory as follows:

• Prior to July 13, 2017, either a Section 2.948 Listed

Laboratory or an FCC Recognized Accredited Testing

Laboratory.

• After July 13, 2017, all types of equipment approved

under the Certification procedure are required to be

tested by an FCC Recognized Accredited Testing

Laboratory.

a) Intentional radiators operated as carrier current systems, devices operated under the provisions of §15.211, 15.213, and 15.221, and devices operating below 490 kHz in which all emissions are at least 40 dB below the limits in 15.209 shall be verified pursuant to the procedures in Subpart J of part 2 of this chapter prior to marketing.

b) Except as otherwise exempted in paragraph c) of this section and in 15.23 of this part, all intentional radiators operating under the provisions of this part shall be certificated by the Commission pursuant to the procedures in subpart J of part 2 of this chapter prior to marketing.

Intentional Radiators

47 CFR Part 2 Subpart C



• The US Federal Communications Commission has recently amended the

rules governing the authorization of radio frequency equipment.

Amongst other, the rule changes mean that two authorization procedures,

Declaration of Conformity (DoC) and Verification, have been combined into one procedure called Supplier’s Declaration of Conformity (SDoC). There was previously some confusion for many devices whether fitting into

the Verification or DoC category. Combining these categories simplifies the

authorization process for products that are not subject to Certification.

One significant change is that test results from an accredited test laboratory is

no longer a must. The SDoC process includes the requirement for a

compliance statement in the product documentation that identifies for

consumers who is responsible for the compliance of the device. The

responsible party must be located in the United States.

The FCC logo currently used for the DoC process is no longer required, but

the FCC will allow manufacturers to continue using the logo at their option.

Amended US rules for RF equipment

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The responsible party, typically the manufacturer, obtains an FCC Registration

Number (FRN) for a device requiring Certification. The FRN is a 10-digit number

used to identify the individual or organization doing business with the FCC. The

same FRN will be used for future approvals.

After obtaining an FRN, the responsible party obtains a Grantee Code from the

Commission by applying at the Grantee Registration website. A grantee code is

required the first time a party applies for certification, and can be used for all future

approvals.

The responsible party files with a Telecommunication Certification Body (TCB) an

application for a grant of certification. An application for equipment authorization

requires submission of information about the product, as listed in Section 2.1033.

The applicant must submit the required information to a TCB for review as part of

the certification process.

The TCB assess all of the information and evaluation results to determine if the

product complies with the FCC requirements.

Once the TCB makes a decision to certify the product the supporting information is

uploaded to the FCC Equipment Authorization Electronic Filing System (EAS)

A grant of certification is issued by the TCB on the FCC EAS.

Certification

• RF, EMC and Safety reports as appropriate

• Block Diagram

• Schematic Diagrams

• Photographs showing the external and internal construction of the product

• User Manual

• Operating Description

• Power of Attorney

• In country representative details

(required for some countries)

TCB Documentation Requirements


Mobile and Portable Devices

Safety Requirements

> 20 cm from the user body

MobileNo SAR requirements

< 20 cm from the user body

PortableSAR requirements


• The FCC ID consists of two elements, a grantee code and an equipment product code. The FCC ID is assigned for Equipment Authorization under various Title 47 rules including but not limited to Parts 15, 90, and 101.

• The Grantee code is a three character alphanumeric string representing the Grantee/Applicant. The Grantee Code always begins with an alphabetic character and does not contain the numbers one and/or zero. The Grantee Code is assigned by the Commission permanently to a company for authorization of all radio frequency equipment.

• The Product Code is the non-grantee code portion of the FCC ID that begins after the first three characters. The Product Code may include hyphens and/or dashes (-).

Product Details and FCC ID



FCC-ID vs EU Type Certificate

FCC CE

Grantee Code (Company Registration)

FCC Registration Number (Device Registration)

TCB Application NB Application

TCB Grant EU Type Certificate

FCC Equipment Electronic Filing System

(public)

EU Member Database

(Private)

FCC-ID Number on device


Multiple Authorization Procedures

• A device subject to multiple authorization procedures requires appropriate testing and labelling for each of the respective authorization procedures. As a general rule, the DoC text statement supersedes any Verification statement. For devices subject to DoC and Verification, or Certification and Verification, the labelling requirements for DoC or Certification need only apply. When a device is authorized under both the DoCand Certification procedures, the DoC logo and FCC ID (or FCC IDs if applicable) are required.

• FCC (EMC) + FCC (Radio)

Type Information Example

FCC ID Equipment displaying this label should be

in FCC database XXXABC123

FCC DoCDeclaration of Conformity

Equipment displaying this label would not

be in FCC database. The FCC would not

have any record of this equipment. It is

declared to comply with FCC regulations

by the manufacturer or importer.

FCC Reg. #Registration Number

Equipment displaying this label would only

be in FCC database if it also has an FCC

ID: label. (e.g. older modems) The FCC

Registration Number itself would never

appear in this database.

FCC ID XZZYYNNNNN

� Grantee Code if (X is

Numeric) Grantee code is

XZZYY else XZZ

� Equipment Product

Code NNNNN

Labels


Modular Approval



Certified Transmitter Modules

• Certified transmitter modules (CTM) are distinctive assemblies containing a transmitter that can be installed inside a host device (i.e. computer, wireless security controller, etc.).

• When a certified modular is used inside a host, the host equipment can take advantage of the certification already granted to the module. The host containing a certified modular (for example a laptop with WiFi) may only require testing for DoC or Certification as a Class B computer, and possibly a subset of additional tests associated with the transmitter.

• Any additional testing, conditions of use and limitations associated with the certified module must be provided in the module instruction manual by the manufacturer of the module, to the Other Equipment Manufacturer (OEM) marketing the host.

• A certified modular has the option to use a permanently affixed label, or an electronic label. All modules without an integrated display on the module must be labelled with a module’s FCC ID - Section 2.926.


FCC-ID on CTM’s

FCC-ID xxxxxxxxxx


Modular Approval

• Single-modular transmitter: A complete RF transmission sub-assembly, designed to be incorporated into another device, that must demonstrate compliance with FCC rules and policies independent of any host;

• Limited single-modular transmitter: A single-modular transmitter that complies with the § 15.212 modular rules, only when constrained to specific operating host(s) and/or associated grants condition(s);

• Split-modular transmitter: An RF transmission system that complies with the requirements for a single modular transmitter, that is separated into a radio front-end section and a control-element section, and can demonstrate compliance for a range of similar type hosts;

• Limited split-modular transmitter: A split-modular transmitter that complies with the definition and technical rules for split modules only when constrained to specific operating host(s), and/or associated grant condition(s).


Permissive Change

• Changes from a non-modular to modular certification, and

from a full modular to a limited modular certification, are

permitted if the changes meet the requirements for a

permissive change in § 2.1043.

• The original grantee may submit new test data to modify

the existing limitations of the grant as permitted under the

permissive change rules (§ 2.1043). Evaluation

requirements include:

• a) All transmitters must have the required simultaneous

transmission test data;

• b) Simultaneous transmission evaluation requirements for RF

exposure.


Authorization options for host manufacturers


CTM and «Delta Type Approval»

Requirements FCC RED

Safety No requirements Device Safety + Module Safety

EMC FCC Part 15 Subpart B Relevant ETSI EN Standard

Radio No Tests

Subset Additional Tests

No Tests (only for RED modules)

Subset Additional Tests

Former «Delta Type» Approval

Labelling All FCC-ID CE

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