FCC certification

FCC vs REDCarlo Casati

Milan, 30 June 2017

US Legal System

30.06.20172 WORKSHOP UN MONDO SENZA FILI: RED & FCC

Aquis

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)

02.12.2016 NEMKO ITALY CUSTOMER SEMINAR4

• 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)

02.12.2016 RED SALES TRAINING5

Fair packaging and Labelling Program

15 U.S. Code § 1452 - Unfair and deceptive packaging and labeling; scope of prohibition(a) Nonconforming labelsIt shall be unlawful for any person engaged in the packaging or labeling of any consumer commodity for distribution in commerce, or for any person engaged in the distribution in commerce of any packaged or labeled consumer commodity, to distribute or to cause to be distributed in commerce any such commodity if such commodity is contained in a package, or if there is affixed to that commodity a label, which does not conform to the provisions of this chapter and of regulations promulgated under the authority of this chapter.

�

Labels are construed as claims; therefore everything on the label must be able to be substantiated.

Claiming conformity to or compliance with a standard, code or regulation must be substantiated.

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 � �


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)


• Certification is the most rigorous approval process for RF Devices with the greatest potential to cause harmful interference. It is an equipment authorization issued by a recognized TCB (Telecommunication Certification Body) based on an application and test data submitted by the responsible party (e.g., the manufacturer or importer). The testing is done by an accredited testing laboratory recognized by the Commission as approved for performing such work. A TCB examines the test data and supporting documentation to determine whether the testing followed appropriate protocols and the data demonstrates technical and operational compliance with all pertinent rules. Technical parameters and other descriptive information for all certified equipment submitted in an application for Certification are published in a Commission-maintained public database.

• Examples of devices subject to certification include, but are not limited to, mobile phones; wireless local area networking equipment, remote control transmitters; land mobile radio transmitters; wireless medical telemetry transmitters; cordless telephones; and walkie-talkies

CERTIFICATION (47 CFR Section 2.907)


• Declaration of Conformity (DoC) is a procedure that requires the party responsible for compliance to use an accredited testing laboratory that follows established measurement protocols to ensure that the equipment complies with the appropriate technical standards. The responsible party is not required to file an equipment authorization application with the Commission or a TCB, and equipment authorized under the DoC procedure is not listed in any Commission database. However, the responsible party must provide a test report and other information demonstrating compliance with the rules upon request by the Commission.

• Examples of devices subject to a DoC include personal computers and peripherals, consumer ISM equipment such as microwave ovens and RF light bulbs, radio receivers and TV interface devices.

Declaration of Conformity (47 CFR 2.906)


• Verification is a procedure that requires the party responsible for compliance to rely on measurements that it or another party makes on its behalf to ensure that the equipment complies with the appropriate technical standards. The responsible party is not required to use an accredited testing laboratory. It is not required to file an application with a TCB, and equipment authorized under the verification procedure is not listed in any Commission database. However, the responsible party must provide a test report and other information demonstrating compliance with the rules upon request by the Commission.

• Examples of devices subject to verification include non-consumer ISM equipment; TV and FM receivers; and business computer equipment. Devices subject to verification must be uniquely identified in a format which cannot be confused with the FCC identifier required on certified equipment.

VERIFICATION (47 CFR Section 2.902)


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.


Approval

• Verification• The responsible party, as specified in the

rules, warrants that each unit of equipment complies with the applicable FCC rules.

• The responsible party maintains all of the required documentation demonstrating compliance with the applicable FCC rules.

• Declaration of Conformity• The responsible party prepares a compliance

information statement to be supplied with the product at the time of marketing.

• The responsible party maintains all of the required documentation demonstrating compliance with the applicable FCC rules.


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


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.


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.) These devices can be sold by a manufacturer (responsible party) to other equipment manufacturers or used in the original manufacturer’s products. When a certified modular is used inside a host, the host equipment can take advantage of the certification already granted to the module. This may reduce some of the tests for the host, compared to using a transmitter that has not been previously certified. 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. The alternative, using a non-certified transmitter, requires DoC or Certification as a Class B computer, and in addition full certification of 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. The module’s OEM manual must provide clear instructions explaining to the host integrator the labelling requirements, options and OEM user manual instructions that are required (see next paragraph).

Certified Transmitter Modules


Requirements FCC RED

Safety No requirements Device Safety + Module Safety

EMC FCC Part 15 Subpart B Relevant ETSI EN Standard

Radio No TestsSubset Additional Tests

No Tests (only for RED modules)Subset Additional TestsFormer «Delta Type» Approval

Labelling All FCC-ID CE

Intentional Radiators


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 Radiators47 CFR Part 2 Subpart C


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 Radiators47 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


Mobile and Portable DevicesSafety Requirements

> 20 cm from the user bodyMobile

No SAR requirements

< 20 cm from the user bodyPortable

SAR requirements


A. Determine if device requires authorization under Verification; Declaration of Conformity (DoC) or Certification.

B. Test measurements of equipment regulated under Parts 15 and 18 are required for authorization to import/market in the U.S.

C. Obtain an FCC Registration Number for a device requiring Certification (either through the FCC or a TCB).

D. For a device requiring Certification (either through the FCC or a TCB) and if an Applicant/Grantee Code has not been previously assigned, obtain a Code from Applicant/Grantee Code ’.

E. For a device requiring Certification through the FCC submit an Application for Equipment Authorization, FCC Form 731.

F. For a device requiring certification through a TCB contact a Telecommunications Certification Body.

Application for Equipment Authorization


• An FRN, or FCC registration number, is a 10-digit number that is assigned to a business or individual registering with the FCC. This unique FRN is used to identify the registrant’s business dealings with the FCC. The FCC will use the FRN to determine if all of a registrant's fees have been paid.

• Each individual or organization doing business with the FCC is required to provide and maintain a current official contact address.

• A filer, licensee, certificate holder, or any entity sending payments to the FCC is considered to be doing business with the FCC and must therefore have an FRN

FCC Registration Number


• 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

• 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


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

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