FCC Rules Seminar
Taipei, Taiwan April 2004
www.atcb.com
atcb.com
AmericanTCB Taiwan
• AmericanTCB, Inc.
3F, 201, Ti Ding Avenue, Sec.2,
• Neihu 114 Taipei, Taiwan
• Major Chen
Sales Manager
• Phone: 886-2-2658-5152 ext 311
• Tim Johnson: +886 092039926
www.atcb.com
atcb.com
WELCOME
and Thank You to our Sponsors
• Trivet Industrial Corporation
• Richtec Instruments Co., Ltd
• Training Research Corporation
(TRC)
• EMI&EMC (Item Publications)
atcb.com
Seminar Schedule and Overview
•
Introduction & Overview of FCC Rules
– Bill Graff: 1: 00-1:45
•
Latest NPRMs and Rules Changes
– Tim Johnson: 1:45-2:30
•
New requirements for Specific Absorption Rate (SAR) Testing
– Bill Graff, ATCB: 2:30-3:15
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Break: 3:15-3:30
Feature Presentation by Sponsors
– Jones Yen, Trivet Industrial Corporation
– Frank Tsai, TRC: 3:30-4:00
– P.H. Yuan, Richtech: 3:30-4:30
•
European Update
– Mike Violette, ATCB: 4:30-5:00
•
Q&A
– 5:00-5:30
•
Reception
– 5:30-7:30
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Fundamental Rules Seminar
William H. Graff, AmericanTCB
atcb.com
USA Compliance
• US: Federal Communications Commission
– Title 47 Code of Federal Regulations
– Product approvals can be performed by FCC or
Telecommunications Certification Bodies
– TCBs are able to perform “routine” evaluations only
using FCC recognized industry standard methods
– New technologies or technologies where there is no
industry consensus are excluded.
atcb.com
FCC 47 CFR Regulations
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Part 2 General Requirements
Part 5 Experimental Radio Service
Part 15 Subpart C, D, and E Unlicensed
Low Power Transmitters (802.11a/b/g,
Bluetooth, etc.)
Part 20 Common Carrier
Part 21 Domestic Public Service
Part 22 Public Mobile Service
Part 24 Licensed PCS
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FCC 47 CFR Regulations
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Part 25 Satellite Communication Services
Part 26 General Wireless Services
Part 27 Miscellaneous Wireless Services
Part 68 Telecom Services
Part 73 Education Services
Part 74 Television Broadcast
Part 80 Maritime Service
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FCC 47 CFR Regulations
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Part 87 Aviation
Part 90 Private Land Mobile
Part 95 Personal Radio Service
Part 97 Amateur Radio
Part 101 Fixed Microwave
atcb.com
FCC 47 CFR Regulations
• FCC does not regulate
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safety (except RF Exposure)
susceptibility
product performance
atcb.com
Certification
– Used for most “Equipment Authorizations”
Formerly called “Type Acceptance”.
– Is more than just a “test report” – actually a
legal document
– Requires a detailed list of “Exhibits”
• See 2.1033 for complete detail
– Test Report should be designed to show
transmitter is “well-behaved”
atcb.com
Licensed Radio Services Test Parameters
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2.1046 - Power Output
2.1047 - Modulation
Characteristics
2.1049 - Occupied Bandwidth
2.1051 - Antenna Terminal
Spurious Emissions
2.1053 - Radiated Spurious
Emissions
2.1055 - Frequency Stability for
Temperature and Voltage
Variations
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Licensed Radio Services Test Parameters
•In most cases - the actual Radio Service
rules have special or unique requirements
and additional testing parameters.
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Licensed Radio Services Test Parameters
•In addition to the Part 2 rules addressing test
parameters the FCC also recognizes the test
methods contained in ANSI/TIA/EIA-603-1992
document
•***Reference test procedures in report
atcb.com
Licensed Radio Services Test Parameters
•Remember that the purpose of performing the
measurements required and submitting
interpretations is to establish compliance with the
technical requirement contained in the Radio
Service Rules.
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Licensed Radio Services Test Parameters
•Power Output: 2.1046
•For any special case as sighted in the
specific rules compliance to 2.1046 test
method is accepted provided the specific
Rule is addressed as part of the
information.
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Licensed Radio Services Test Parameters
•Where sections of the recommended
standard EIA-603 differ from Part 2
requirements - the Part 2 test method must
be used for testing purposes.
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Licensed Radio Services Test Parameters
•Modulation Characteristics 2.1047
•Test requirements of this section differ from
EIA-603 requirements.
•Compliance to Part 2 requirements is
mandatory.
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Licensed Radio Services Test Parameters
•Example: EIA 603 differs from Part 2.1047
regarding the range which the audio frequency
response is to be measured.
– Part 2.1047 requirement of 100 - 5000 Hz should
be used for this test.
•General Test Setup
Transmitter
Under
Test
Power
Attenuator
Power Measuring
Receiver/Spectrum
Analyzer
Modulating
Signal
Generator
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Licensed Radio Services Test Parameters
•Occupied Bandwidth 2.1049
•While this test is identified as “Occupied Bandwidth”
which is defined as that portion where 99% of the
emitted energy (with the remaining 0.5% above & 0.5%
below the occupied band), the results are mainly used
to compare modulated spectrum with emissions masks
•OBW @ 10 Log (0.01) = -20 dBc
•Other rule sections may call out -23 or -26 dBc
atcb.com
Licensed Radio Services Test Parameters
•In addition to meeting the emission mask, the occupied
bandwidth may not exceed the authorized bandwidth as
listed in the Radio Service Rules.
•This test should be performed for each kind of
emission to be listed on the FCC Grant.
•Note: the emission mask is normally applied with 0 dB
equal to the level of the unmodulated carrier.
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Emissions Mask Example
Analog Modulation
Mask
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Emissions Mask Example
Digital Modulation
Mask
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Licensed Radio Services Test Parameters
•2.1049 does not cover Occupied Bandwidth tests
for amplifiers or similar units since these devices
are intended to reproduce the modulated signal.
•Amplifiers designed to handle multiple channels
should be tested with multiple channels for each
emission to show intermodulation products.
•Tests for power amplifiers still should include
“gozinto” and “gozouta” plots for each modulation
desired.
atcb.com
Licensed Radio Services Test Parameters
•Intermodulation is considered a spurious
emission by the FCC and are covered by the
general emission limitations (masks) in each
radio service.
•This specifically refers to the IM products
produced by transmitters / amplifiers carrying
two or more signals.
atcb.com
Licensed Radio Services Test Parameters
•Antenna Terminal Spurious Emissions
2.1051
•(Otherwise know as Conducted Emissions)
•View levels of harmonic emissions.
•An extension of the occupied bandwidth test
showing the emission up to the highest
frequency as specified in Section 2.1057
[usually 10th harmonic].
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Licensed Radio Services Test Parameters
•If the unit does not have a detachable
antenna or an antenna output terminal then
the test data is collected at the base of the
antenna.
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Licensed Radio Services Test Parameters
•Field Strength of Spurious Emissions 2.1053
– ERP/EIRP Spurious Measurement
•This test includes those emissions radiated from the
cabinet, chassis, and associated wiring. The specification is
the same emission mask under the Radio Service rules
extended to the highest frequency specified in 2.1057.
•Substitution method described in TIA/EIA 603 required test
procedure. Be sure to account for SWR when using
broadband antennas !
atcb.com
Licensed Radio Services Test Parameters
•Frequency Stability 2.1055
•Done over temperature [-30 C to +50 C] and operating
voltage [+/- 15%] specifications.
•Battery operated devices should also include B.E.P
[Battery End Point]
•Usually defined in ppm but other units such as Hz, % are
accepted as defined in specific rule section.
•Differs some from methodology described in
•TIA/EIA 603
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Licensed Radio Services Test Parameters
•Reference Standards:
•TIA/EIA 603 Land Mobile FM or PM
Communications Equipment Measurement and
Performance Standards
•TIA/EIA Telecommunications System Bulletin
TSB102 (Digital C4FM/CQPSK Transceivers
Measurement Method
atcb.com
Licensed Radio Services Test Parameters
•Emission Designator: Determined from the
Occupied bandwidth and the modulation scheme
used
•Classic equations described in Part 2
•Required as part of submittal
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Common Part 22 H Cellular
Emission Designators
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40K0F8W – AMPS Cellular voice &
signaling tone
40K0F1D – AMPS Cellular wideband data
1M25F9W – CDMA (IS 95/98)
30K0DXW - North American digital cellular
- TDMA
300KGXW – GSM
300KG7W - EDGE
atcb.com
Emission Designator
Calculation
• Emission Designator
– 40K0F8W - Voice & SAT signal
• Voice (M=2.5k, D=12k), SAT (M=6k, D=2k)
• Pick highest frequency and add deviations and
apply Carson’s Rule 2M+2D
• 2(6k) + 2(12k+2k) = 12+28 = 40 kHz
– 40K0F8W - Signaling Tone (ST) & SAT
• ST (M=10k, D=8k), SAT (M=6k, D=2k)
• 2(10k) + 2(8k+2k) = 20+20 = 40 kHz
– 40K0F1D - Wideband Data
• Data (M=10k, D=8k), SAT (M=6k, D=2k)
• 2(10k) + 2(8+2) = 20+20 = 40 kHz
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Example Part 22 H Grant
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Certification Checklist for Licensed
Services
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Applicant Name Correct
Test Firm
FCC ID: number
Equipment Functional Description
Equipment Class
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Certification Checklist for Licensed
Services
•Confidentiality Request Letter
– Letter with details to be included with
confidentiality.
– Commonly only Block Diagram, Schematics,
Parts List and Tune-up are eligible for
confidential treatment
– Manuals, photos, test reports, SAR reports never
allowed confidentiality
– Date of letter
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Certification Checklist for Licensed
Services
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Technical Information
Rule Part(s)
Frequency Range
Power Output
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Certification Checklist for Licensed
Services
• Antenna Port
– (Real Connection or Integral antenna?)
• Frequency Tolerance
• Emissions
• Necessary Bandwidth Values Justified
• Emission Type Justified
atcb.com
Certification Checklist for Licensed
Services
• RF Exposure Information
• Description: Purpose, Use and Users
• Instruction Manual
• DC Voltages and Currents Listed
• Tune Up Procedure
• Circuit Diagram \ Block Diagrams
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Certification Checklist for Licensed
Services
• Photos (Internal & External) Technical Report
• Power Output
– (ERP/EIRP or Conducted? Peak or Average?)
• Audio Frequency Response
• Modulation Limiting
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Certification Checklist for Licensed
Services
• Frequency Stability vs Voltage
+ 15% and Battery end point
• Frequency Stability vs Temperature
-30C to +50C
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Required Exhibits for Licensed
Services
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Agent Authorization Letter
Confidentiality Request
Schematics
Block Diagram
RF Exposure Evaluation
Operational Description
Tune Up Procedure
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Required Exhibits for Licensed
Services
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External Photographs
Internal Photographs
Sample Label with FCC ID:
Label Location
Test Setup Photographs
Users Manual
Test Report
atcb.com
Recent FCC Clarifications,
Latest NPRM’s and Rules Changes
Timothy R. Johnson, American TCB
atcb.com
Presentation Overview
•Part 15 Recent Interpretation Issues,
Reminders, and Application Concerns
•Part 15 Rulemaking updates
– NPRM’s, Report and Orders, etc.
atcb.com
Multiple Modulation Capabilities in
One Device
•One familiar example, 802.11(g)
incorporates the following modulation
capabilities.
• BPSK modulation at 1 and 2 Mb/s
• CCK modulation at 5.5 and 11 Mb/s
• OFDM modulation at 54 Mb/s
•The FCC expects each of these modes and
•modulations to be evaluated (i.e. pretest, etc.)
atcb.com
Multiple Modulation Capabilities in
One Device – Cont.
•Justification for worse case results
reported or modes reported should be
included in the test report
•As a minimum, it is suggested that an
802.11g test report should include:
– Data for BPSK/CCK. Due to similar
waveforms, only worse case data needs
to be shown for these 2 modulations
– Data for OFDM
atcb.com
AC Line Conducted Emissions for
Part 15 Modules
•Section 15.207(a) requires test data
unless the device is battery powered with
no provision for receiving power directly
or indirectly from an AC source.
•Any application granted for battery
power only will be listed as a
condition on the grant of
authorization.
atcb.com
AC Line Conducted Emissions for
Part 15 Modules – Cont.
•
Battery powered examples:
–
The transmitter is powered by an on-board battery.
 Transmitter has a battery connector/compartment
–
The transmitter is only intended for battery powered
applications and installed by OEM.
 Device is conditioned only for battery powered applications and a
limited module approval is issued
 Any new non-battery application requires a new authorization (new
FCC ID)
–
The transmitter is installed only in the
manufacturers equipment that will be battery
powered
 Grant is conditioned accordingly and a LMA is issued
atcb.com
CISPR AC Line Conducted Limits
for All Transmitters
•Since December 3, 2002, all Part 15 and
18 devices required to be tested for AC
Line conducted emmissions must have
either Note Code ’05’ or ‘CE’ listed on the
grant of equipment authorization.
atcb.com
CISPR AC Line Conducted Limits
for All Transmitters – Cont.
•"05" NOTE- The manufacture and importation of this
device must cease on July 10, 2005 pursuant to 15.37(j)
or 18.123 transition provisions adopted under FCC
02-157 (ET Docket 98-80).
•"CE" NOTE - This device has shown compliance with
the conducted emissions limits in 15.107, 15.207, or
18.307 adopted under FCC 02-157 (ET Docket 98-80) and
may be marketed after July 11, 2005 and is not affected
by the 15.37(j) or 18.123 transition provisions.
atcb.com
CISPR AC Line Conducted Limits
for All Transmitters – Cont.
•Currently the ’05’ note has been used on
all devices that meet the older FCC line
conducted regulations and not the new
CISPR limits. This will only be allowed up
until July 11, 2004. After this time TCBs
and the Commission will no longer use the
’05’ note code.
atcb.com
CISPR AC Line Conducted Limits
for All Transmitters – Cont.
•The ‘CE’ note is used on all devices that are
tested and comply with the new CISPR
requirements and are granted before July 12,
2004. On July 12, 2004, all new approvals must
meet the new CISPR limits. TCBs and the
Commission will not use the “CE” note after
July 11, 2004.
•All devices (both new and previously
approved) marketed after July 11, 2005
must meet the new CISPR AC Line
Conducted Limits.
atcb.com
CISPR AC Line Conducted Limits
for All Transmitters – Cont.
•To update a Part 15 grant that was approved
using the previous Part 15 limits, a Class II
permissive change filing should be submitted
showing compliance with the CISPR AC line
conducted limits.
atcb.com
CISPR AC Line Conducted Limits
for All Transmitters – Cont.
•Special Note:
•The policies for filing Class II permissive changes are
different for some Part 18 devices because certain
types of Part 18 devices had no AC line conducted
emissions limits before the FCC adopted the CISPR
limits.
– Example Microwave ovens - for a detailed description
see link:
http://hraunfoss.fcc.gov/eas_public/SilverStream/Pages/pg_html_fts_res.html?letter=1344
atcb.com
CISPR AC Line Conducted Limits
for All Transmitters – Cont.
•Special Note 2:
•Part 18 RF lighting devices were excluded from the
new CISPR AC line conducted limits by the last
sentence in Paragraph 22 of the Report and Order (ET
Docket No. 98-80; FCC 02-157). Therefore, RF lighting
devices will not have a Note Code 05 or CE on a grant
of Certification.
atcb.com
Vehicular Battery Chargers (VBC) for
Cellular Phones
•There have been recent questions
regarding whether a battery charger intended
for use only in a vehicle requires FCC
Certification.
atcb.com
Vehicular Battery Chargers (VBC) for
Cellular Phones – Cont.
•Exempted per Section 15.103(a)
– The VBC is not promoted for applications
other than use within a vehicle, Section
15.103(a) exempts digital devices used
exclusively in transportation vehicles
– Classified as a digital device under Part 15 of
the FCC rules
– Subject only to non-interference
provisions (Sections 15.5 and 15.29)
– Certification not required
atcb.com
Part 15 Water Meter Transceivers In Ground
Testing Guidance
•FCC has recently issued a special guidance regarding
this issue. See link:
•http://hraunfoss.fcc.gov/eas_public/SilverStream/Pages/Fpg_html_fts_res.html?letter=1366
– This guidance allows testing in ground as opposed to an open area
test site (OATS)
– This gives the manufacturer more flexability to measure “system”
vs. stand-alone configurations. Allows manufacture to tune power
to meet their installation requirements
– Professional installation is required
– Instructions must provide appropriate details for the
installation of the transmitter in the pits and must
specify the types of pits
– Grant will contain conditions accordingly
 Professional installation and specific types of pits
atcb.com
Part 15 Water Meter Transceivers In Ground
Testing Guidance – Cont.
•Special Guidance:
– Use mast. Do not use a tripod with fixed height
– Section 8.1 in ANSI C63.4 should be
consulted. Frequency scans of the EUT field
strength with both polarities of the measuring
– antenna shall be made at a minimum of 16
azimuth angles (nominally 22.5
degrees) around the EUT
atcb.com
15.407(d) Integral Antenna Requirement
for 5.2 GHz UNII Devices
•The integral antenna rule requires that the
antenna is permanent or not removable.
atcb.com
15.407(d) Integral Antenna Requirement
for 5.2 GHz UNII Devices – Cont.
•Acceptable methods:
– Antenna and/or antenna connectors are
soldered together
– Permanent Loctite or industrial strength epoxy
can be used
– A locking connector that cannot be removed,
even with a special tool
Must be locked prior to shipment
atcb.com
15.407(d) Integral Antenna Requirement
for 5.2 GHz UNII Devices – Cont.
– An antenna and/or connectors inside of a nonaccessible (there is no need for the user to ever
open the case)
Note that it is assumed that users will open desktop
computers.
atcb.com
15.407(d) Integral Antenna Requirement
for 5.2 GHz UNII Devices – Cont.
•Exceptions:
•For a 5.15-5.25 GHz UNII mini-PCI card installed
in a notebook computer with built-in antennas
– Bios locking feature satisfies the rule
•Antenna with embedded code.
– Code ensures that the proper antenna is used
•Reminder: 5.15 – 5.25 GHz is for indoor
use only. No outdoor antennas.
atcb.com
15.407(d) Integral Antenna Requirement
for 5.2 GHz UNII Devices – Cont.
•Unacceptable Methods:
– A unique connector is not sufficient
– Bios lock with external antenna
– A locking connector that can be removed
with a special tool does not satisfy the
requirement
– Heatshrink
– User Warnings
atcb.com
User Selectable Frequencies
•End user selectable frequencies for non USA
frequencies are not allowed.
– User selectable options must be disabled
– This must be clear in all exhibits within the filing. For
example user manual or descriptions for these options
•Section 15.15(b) prohibits adjustments of any control by
the user that will cause operation of a device
in violation of the regulations.
atcb.com
Configuration of Antennas for
Testing
•The FCC has recently developed 2
concerns regarding test configurations
for the antennas of a modular approval.
atcb.com
Configuration of Antennas for
Testing – Cont.
•1) Antenna positioning in test setup
should represent typical final product
configuration
•2) DO NOT LAY ANTENNAS ON WOOD
TABLETOP
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Configuration of Antennas for
Testing – Cont.
atcb.com
Configuration of Antennas for
Testing – Cont.
•In this example the
monopole antennas
should be supported in
vertical position, e.g.,
using foamed-polystyrene
blocks
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Configuration of Antennas for
Testing – Cont.
•Note that this also applies to antennas such as
PIFA. The antennas shown on the following page
should not be placed in contact with the table top
during test. Additionally, the positioning should be
justified in the report.
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Configuration of Antennas for
Testing – Cont.
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Configuration of Antennas for
Testing – Cont.
•The FCC has seen that the matching of the
antenna changes when placed too closely to the
table top, which affects the radiation pattern.
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Co-located Transmitters, i.e. Laptop
w/ LAN & Bluetooth – Cont.
•Co-Location is typically defined as when
2 transmitter antennas are located < 20 cm
apart from each other, and both
transmitters may be active at the same
time.
•Each radio must be tested
individually and appropriate test
data submitted with the application
atcb.com
Co-located Transmitters, i.e. Laptop
w/ LAN & Bluetooth – Cont.
•The application must also include tests
for simultaneous transmission when the
end use device may function with both
transmitters active at the same time
atcb.com
Co-located Transmitters, i.e. Laptop
w/ LAN & Bluetooth – Cont.
•Special care should be taken to
investigate bandedge and intermodulation
products
•Submit antenna conducted
measurements with both transmitters on,
if transmitters share an antenna
atcb.com
Co-located Transmitters, i.e. Laptop
w/ LAN & Bluetooth – Cont.
– If radiated data for simultaneous
transmission is no worse (no new intermod,
spurs or increased levels) than individual
tests, then also submit statement that
simultaneous transmission was
investigated and no new emissions were
found
– If new emissions were found during
simultaneous tests, provide data
and indicate the worst case
condition
atcb.com
Cordless Phones
•Cordless phones under Part 15 have typically
been approved under several sections of the
FCC rules such as 15.233, 15.247, and 15.249.
atcb.com
Cordless Phones – Cont.
•The FCC has just released an interpretation that
requires a cordless telephone that operates on
two different frequency bands to be approved
under two separate FCC ID numbers, one for the
base and one for the handset.
•For detailed information, refer to FCC
Interpretation Data Base Posting
200009-13-004
atcb.com
NPRM’s
•NPRM – Notice of Proposed Rule Making
•This is a term used to denote a document that
is published for public comment. The changes
shown in the document are proposals only
which may or may not actually become new
rules and/or regulations.
atcb.com
NPRM Modification of Parts 2
and 15
•Proposal to make changes to Parts 2 and 15
may be found in ET Docket No. 03-201, FCC 03223
– http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-03-223A1.doc
•Published December 10, 2003
– Public comments were due February 7, 2004
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NPRM Modification of Parts 2
and 15 – Cont.
• 1) Work to clarify the rules for advanced antenna
technologies
– (i.e. phased array/steerable beam systems) in 2.4 GHz band
• 2) Modify the rules on replacement of Part 15 antennas
• 3) Modify the rules on configuring transmission
systems
– No need to obtain separate authorization for every combination of
system components. i.e. adding amplifiers
• 4) Harmonize the measurement procedures for digital
modulation systems under the Spread
Spectrum and UNII rules
atcb.com
NPRM Modification of Parts 2
and 15 – Cont.
• 5) Modify the channel spacing requirements for
hoppers in the 2.4 GHz band to allow wider bandwidth
hoppers
• 6) Clarify and change modular approval requirements
• 7) Make other changes to update or correct Parts 2
and 15 of the rules
atcb.com
NPRM on Interference Temperature
•Proposal in ET Docket No. 03-237, FCC 03-289
–
–
–
–
–
Adopted: November 13, 2003
Released: November 28, 2003
Published January 21, 2004
Comments due April 5, 2004
Reply Comments due May 5, 2004
– http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-03-289A1.doc
•News Release
– http://hraunfoss.fcc.gov/edocs_public/attachmatch/DOC-241226A1.doc
atcb.com
NPRM on Interference Temperature-Cont.
•RM seeks comments on “Interference Temperature”
approach to quantify and manage interference between
different services.
•Interference temperature model takes into account the
cumulative radiofrequency (RF) energy from
transmissions of spectrum-based devices and would set
a maximum cap on the aggregate of the transmissions.
– Current interference management approach is based on specifying and
limiting transmit powers of individual spectrum based
devices
atcb.com
NPRM for Access Broadband Over Power
Line Systems
• Proposal to make changes to Part 15 may be found in
ET Docket No. 03-104 & 04-37, FCC 04-29
– http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-04-29A1.pdf
• 1) Access broadband operational requirements
• 2) Equipment authorization and measurement
guidelines
atcb.com
Report and Order
•Report and Order (R&O)
•This is a term used to denote a document
that includes adopted rules, provides
background on reason for adoption and
Effective Date. Requires publication in
Federal Register
atcb.com
2nd R&O and MO&O Part 15
Deregulation
•New Rules in ET Docket No. 01-278, FCC 03-149
– Effective date: January 8, 2004
– http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-03-149A1.doc
atcb.com
2nd R&O and MO&O Part 15
Deregulation – Cont.
• 1) Change emission levels in the restricted bands
above 38.6 GHz
• 2) Allow data transmission in 15.231
• 3) Modify the FS limits for 13 MHz RF ID systems
• 4) Simplify the labeling requirement for self
authorized equipment (DOC)
– Removed “For Home or Office Use” and statement that a complete
device was tested for compliance
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2nd R&O and MO&O Part 15
Deregulation – Cont.
•
5) Other changes to update and correct FCC rules.
– Incorporate the ANSI C63.17 test procedure for UPCS devices into the
rules
– Provide exemption for certain low power devices <490 kHz and FS is less
than 40 dB below Part 15 limits
– Allow user manual information on CD-ROM or on internet if manual is
provided likewise
– FRS transmitters tested -20 to+50 degrees C for frequency stability tests
– Accredited labs do not have to file description of measurement facilities
with the Commission. However, Certain information is still required.
Name, address, contact info, accrediting body’s name, designation
number and date of renewal
– Miscellaneous rule corrections and deletions
atcb.com
R&O UNII Devices
•New Rules in ET Docket No. 03-122
–
–
–
–
Effective date, February 19, 2004
http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-03-287A1.doc
Adds 255 MHz of spectrum 5.47-5.725 GHz to current UNII bands
Dynamic Frequency Selection (DFS) for devices in the 5.25-5.35 GHz
band and 5.47-5.725 GHz band
– Interim DFS Test procedure is in the Appendix of the Rules.
– Transmit power control (TPC) 5.47-5.725 GHz band
– According to the FCC only a statement that the device has TPC is
required to be submitted in the filing. No test required
atcb.com
R&O UNII Devices – Cont.
•DFS and TPC are considered new technology
– TCB cannot approve any device operating under the
new rules
•Test procedure will be updated in the near
future
– Currently this is considered a complex test which
requires specialized equipment and software
atcb.com
R&O UNII Devices – Cont.
•Class II permissive change for existing
equipment to add DFS & TPC
– Allowed only for software change
– Any hardware change requires NEW AUTHORIZATION
•Transition dates; equipment operating in 5.255.35 GHz
– 1 year, Certification filings must comply
w/ new rules by February 19, 2005
– 2 years, All devices imported and marketed
must comply by February 19, 2006
atcb.com
Additional References
•FCC Interpretation Database:
•https://svartifoss2.fcc.gov/prod/oet/cf/ri/FccEasRi.cfm
atcb.com
RF Exposure Tutorial
William H. Graff, AmericanTCB
atcb.com
Portable vs. Mobile
• Specific definitions for RF exposure
– Mobile – Greater than 20 cm
– Portable – Less than 20 cm
atcb.com
What is SAR?
• Close field phenomenon which occurs
when an electromagnetic wave interacts
with a biological medium
• Occurs at less than ¼ wavelength
• E and H fields are at relative maximums
atcb.com
MPE calculation
• MPE calculations assume a linear planewave field.
• Considered an overestimate of maximum
field density
• Not applicable to distances under 20cm
• Cannot predict interaction with nearby
structures
atcb.com
SAR measurement
• Requires isotropic power measurement
systems
• Typically use 3 axis probes in a biological
“soup”
• Soup has electrical characteristics nearly
identical to tissue at specified frequency
atcb.com
Example Systems
SPEAG
IndexSAR
Aprel/IDX
atcb.com
P1528 §1.4.2 Positioning
Rationale
LE
RE
M
LE
M
LE
RE
RE
LE
RE
M
RE
LE
M
LE
LE
M
LE
M
15o
LE
(Source: based on IEEE SCC-34/SC-2, P1528
Draft)
•RE
•
RE
Tilt
Touch/cheek
2 pos. intended
toLEencompass normal use, may not be worst-case
LE
2 pos. are subset of 4 from ES 59005:1998 (CENELEC), where experiences
M
M 2 pos. are
15 enough for conservative
showed
that
LE
Touch position is most repeatable since it relies on two- or more point
contact with phantom; accounts for RF current densities in device case
regions
Tilt position accounts for RF current densities in external antennas and
antenna feed-regions at top of handset
o
•
•
(Source: based on IEEE SCC-34/SC-2, P1528
Draft)
atcb.com
SAR Mapping Systems
1)
2)
3)
4)
5)
6)
7)
8)
control and data capture unit
field-probe readout electronics
dosimetric E-field probe
probe positioner
unwanted ambient fields
phantom shell with tissueequivalent liquid,
device-under-test
device holder/positioner.
coarse scan over device
outline to locate hot-spots
54.7 0
D- beam 3-axis
E-field probe
HIGH-RESISTANCE LINES
DETECTOR
DIODE
RESISTIVE
DIPOLE
atcb.com
Head Phantom
• SCC-34/SC-2 head model - SAM
F
+30
LE ERP
F
RE (ERP)
B
0
B
-30
15 mm
+20 0
N
-60
M
M
10 mm square
EEP
N
ERP - ear reference point
EEP - entrance to ear canal
(Source: IEEE SCC-34/SC-2, P1528 Draft)
atcb.com
SAR Test Positions
+30
F
B
0
vertical
center line
RE (ERP)
-30
wt/2 wt/2
horizontal
line
wt/2 .wt/2
+20 0
.
horizontal
line
N
-60
10 mm square
A
B
acoustic
output
vertical center
line
A
M
acoustic
output
bottom of
handset
B
bottom of
handset
wb/2 wb/2
wb/2 wb/2
•
•
•
•
point A is “test device reference point”
align point A to ERP on head model
align vertical center line to M-B
align horizontal line to N-F
atcb.com
Limitations of P1528
• Does not address all body worn
configurations
• Does not address methodologies above
3GHz
• Does not address non-standard ear-held
devices which do not conform to M to LE
or RE line
atcb.com
SAR Limits
• Experiments with laboratory rats
• Scaled up to humans using known models
borrowed from pharmaceutical industry
atcb.com
Supplement C: Exposure Limits
(A) Limits for Occupational/Controlled Exposure
Frequency
Range
(MHz)
Electric Field
Strength (E)
(V/m)
Magnetic Field
Strength (H)
(A/m)
Power Density
(S)
2
(mW/cm )
Averaging Time
2
2
|E| , |H| or S
(minutes)
0.3-3.0
3.0-30
30-300
300-1500
1500-100,000
614
1842/f
61.4
---
1.63
4.89/f
0.163
---
(100)*
2
(900/f )*
1.0
f/300
5
6
6
6
6
6
(B) Limits for General Population/Uncontrolled Exposure
Frequency
Range
(MHz)
Electric Field
Strength (E)
(V/m)
Magnetic Field
Strength (H)
(A/m)
Power Density
(S)
2
(mW/cm )
Averaging Time
2
2
|E| , |H| or S
(minutes)
0.3-1.34
1.34-30
30-300
300-1500
1500-100,000
614
824/f
27.5
---
1.63
2.19/f
0.073
---
(100)*
2
(180/f )*
0.2
f/1500
1.0
30
30
30
30
30
f = frequency in MHz
*Plane-wave equivalent power density
NOTE 1: See Section 1 for discussion of exposure categories.
NOTE 2: The averaging time for General Population/Uncontrolled exposure to fixed transmitters is not applicable for mobile and
portable transmitters. See 47 CFR §§2.1091 and 2.1093 on source-based time-averaging requirements for mobile and
portable transmitters.
atcb.com
Supplement C: SAR Limits
(A) Limits for Occupational/Controlled Exposure (W/kg)
Whole-Body
Partial-Body
Hands, Wrists, Feet and Ankles
0.4
8.0
20.0
(B) Limits for General Population/Uncontrolled Exposure (W/kg)
Whole-Body
Partial-Body
Hands, Wrists, Feet and Ankles
0.08
1.6
4.0
NOTE 1: See Section 1 for discussion of exposure categories.
NOTE 2: Whole-Body SAR is averaged over the entire body, partial-body SAR is averaged over any 1 gram of
tissue defined as a tissue volume in the shape of a cube. SAR for hands, wrists, feet and ankles is
averaged over any 10 grams of tissue defined as a tissue volume in the shape of a cube.
NOTE 3: At frequencies above 6.0 GHz, SAR limits are not applicable and MPE limits for power density should
be applied at 5 cm or more from the transmitting device.
NOTE 4: The time averaging criteria for field strength and power density do not apply to general population
SAR limit of 47 CFR §2.1093.
atcb.com
Controlled vs. Uncontrolled
• End users which have a knowledge of
radio waves and can limit their exposure
can use Controlled limits
• End users which may have no knowledge
of the limits must use Uncontrolled limits
atcb.com
Differences in Limits
• Limit for Controlled exposure in the head =
4W/kg (4mW/g)
• Limit for Uncontrolled exposure in the
head = 1.6W/kg (1.6mW/g)
atcb.com
When is SAR testing required?
• FCC maintains two threshold limits – one
for itself and another for TCBs.
• TCBs must always follow TCB Exclusion
List of July 17, 2002
atcb.com
Portable PTT
• Part 80, 90, 95
• FCC – SAR data required for PTT above
1W radiated or conducted
• TCB – 60mW/f(GHz)
atcb.com
Portable 15.247 and 15.407
• Below 3GHz
– FCC – SAR data if above 50-100mW
– TCB – 60mW/f(GHz)
• Above 3GHz
– FCC – SAR data if above 50mW
– TCB – cannot do
– ***By law, SAR data required for all portable
UNII devices regardless of Pout
atcb.com
Modules
• No such thing as RF category “Portable”
modular approval. (Same FCC or TCB)
• Full modular approvals are only permitted
for RF category “Mobile” modules
atcb.com
LMA and SAR
• Limited Modular Approvals are permitted
but only for carefully defined host
platforms.
• Hosts must have similar mechanical
constructions.
atcb.com
Three Host Method
• RF category “Portable” modules are
permitted under specific circumstances
and specific hosts.
• Testing to be performed in three each
portable devices (i.e. notebook PC, PDA,
etc.)
• Unlimited “Portable” modular approvals
never permitted
atcb.com
Simultaneous Transmission
• If radiating structures <20cm then
simultaneous transmission may be of
concern.
• FCC evaluates co-located devices with
simultaneous transmission
• TCB cannot per TCB Exclusion List if
second non-dominate transmitter above
5mw
atcb.com
Above 3GHz
• IEEE P1528 does not yet define a
methodology for SAR testing above 3GHz,
therefore all SAR evaluation above 3GHz
must go to FCC
• Expect approvals from FCC to take 90
days
atcb.com
RF Safety Documents for
Issues with Human Exposure
•
•
•
•
•
•
•
ANSI C95.1
OET 65
OET 65-C
FCC Part 1.1037
FCC Part 2.1091 Mobile Devices
FCC Part 2.1093 Portable Devices
TCB Exclusion List
atcb.com
Future Provisions
• Additional guidance on body-worn
configurations
• Release of procedure for TCBs to evaluate
SAR above 3GHz
– Likely to be timed with release of DFS
procedure to TCBs
atcb.com
Questions?
atcb.com
R&TTE Directive
Michael Violette, P.E.
www.atcb.com
atcb.com
European R&TTE Directive
atcb.com
European R&TTE Market
• R&TTE equipment: 58 b € /year in the EU
– Machinery market: >250 b € /year
– Telecommunication Services: 200 b € /year
• Diverse industry
– Big Companies (Nokia, Ericsson, Motorola, Siemens, Philips,
Alcatel, Nortel)
– Many SMEs in e.g. Short Range Radio markets
• Before R&TTE Directive: Many different requirements
– > 1000 national regulations, around 30 harmonised EU regulations
– fragmentation of spectrum
• After R&TTE Directive: less fragmented
• Total sectors covered by EMC Directive: 250 b€
atcb.com
EU Market
• May 1st 2004 Members of EU:
• Austria, Belgium, Denmark, Finland, France,
Germany, Greece, Ireland, Italy, Luxembourg,
The Netherlands, Portugal, Spain, Sweden,
United Kingdom, Cyprus, Czech Republic,
Estonia, Hungary, Latvia, Lithuania, Malta,
Poland, Slovakia, Slovenia
atcb.com
R&TTE
• For wired and wireless
telecommunications equipment
• Covers the following aspects:
– Efficient use of spectrum
– EMC
– Safety
• Includes EMC and Low Voltage
Requirements
atcb.com
R&TTE Approval Process
• CE Marking by manufacturer is allowed
• Self-Declaration for many products
• Reduced approval procedures and
processes
• Harmonized standards developed
• Faster, cheaper, more market coverage for
SME
atcb.com
Annexes
• Annex I: Things NOT covered
– Cables, Receive-only broadcast, Kits, Aviation and
Air Traffic, marine
• Annex II: Internal Production Control
– Basis for all Annexes (good documentation!)
• Annex III: Annex II + Testing
– Type testing
• Annex IV: TCF
– Notified Body (for new technologies)
• Annex V: Full QA
– Accredited Quality Assurance System
atcb.com
R&TTE Testing
• No longer requires involvement of
accredited test house
• Test to harmonized standards
– DoC
– CE Marking
– Ship
• Non-harmonized frequencies:
– Notification to Governments
– Alert Signal (Equipment Class Identifier)
– Restricted Geographical Area
atcb.com
TCF & NB Opinion
•For new technologies WITHOUT
harmonized standards
•Notified Body or Conformity Assessment
Body opinion
atcb.com
TCF Documentation
• Product description
• Conceptual design and manufacturing drawings such as
schematics and subassembly drawings
• A description and explanation of the drawings,
schematics, and operation of the product
• A list of all standards that were applied, in full or in part,
to show compliance.
– If standards were not used or do not exist, then a description and
explanation of the solutions used to meet the essential
requirements of the directive must be included
• Results of design calculations and examinations
• Test reports
• A copy of the DoC
atcb.com
Self Certification
(ALL Harmonized)
atcb.com
Self Certification
(Standard Harmonized,
Frequency NOT harmonized
Notification required)
atcb.com
Standard NOT Harmonized,
Notified Body
atcb.com
Which way to go?
atcb.com
Harmonized Frequencies
(Short Range Devices)
• Document CEPT 70-03
– Lists frequencies and usage in different European
countries
• Published by: European Conference of Postal
and Telecommunications Administrators
• Available at:
http://www.atcb.com/techlib/index.asp
• European Radiocommunications Office link to
National Frequency Plans:
– http://www.ero.dk/EEE33BA9-9EE9-4252-AD6C-BE7EFB81898.W5Doc
atcb.com
Examples from CEPT 70-03
http://www.atcb.com/techlib/index.asp
atcb.com
Notification
• Applies to radio equipment using a nonharmonized frequency
• If non-harmonized frequency band, the
manufacturer must determine if the
frequency is available for use in a
particular member state
• Notify each member state where the
equipment is to be sold
atcb.com
Notification
• Notify the Spectrum Authorities in each
member state
• Must be made 4 weeks prior to the
equipment being offered for sale.
atcb.com
Identify Requirements
• Market (Countries)
• Restrictions (CEPT 70-03)
• Harmonized Standards? (Official
Journal)
• TCF/Notified Body
• Test Suite
atcb.com
Example ETSI/EN Standards
• Available from www.etsi.org (free!)
• Telecom, EMC & Radio Matters
• EN 300 386:
– Electromagnetic compatibility and Radio spectrum Matters (ERM);
Telecommunication network equipment; ElectroMagnetic Compatibility
(EMC) requirements
• ETS 300 328:
– Radio Equipment and Systems (RES); Wideband transmission systems;
Technical characteristics and test conditions for data transmission
equipment operating in the 2,4 GHz ISM band and using spread spectrum
modulation techniques
atcb.com
Getting the CE Marking
Procedure for Harmonized Standard
• Look in ERC Report 70-03 for Country
Restrictions and Harmonized Standard
• Test product to standard
• Notify Spectrum Authorities
• Prepare final documentation
• Label device
• Ship
atcb.com
Classification
• Class 1: equipment, which can freely move and
be switched on in the Community (wired
equipment, GSM, Receive-only equipment, etc.)
• Class 2: equipment, for which this is not the
case (transmitters, which are to be licensed)
– Marking: simple marking scheme agreed between
Member States:
• CE mark only for class 1 equipment (+ NB Numbers)
• CE mark +
for class 2 equipment (+ NB Numbers)
atcb.com
Examples
• Short Range Device (SRD) Operating at
433 MHz
• Spread Spectrum WLAN/RLAN operating
at 2.4 GHz
• GSM phone operating at 900 MHz band
atcb.com
Example 1:
Short Range Device (SRD)
• Equipment Parameters:
– 433.92MHz
– Low power <2.5mW
– Modulation: FSK
– Duty Cycle: <1%
– Integral Antenna
– Battery Powered
– “Non-Specific Short Range Device”
atcb.com
Example 1 SRD:
ERC 70-03 Restrictions
atcb.com
Example 1 SRD:
ERC 70-03 Technical Restrictions
atcb.com
Example 1 SRD:
ERC 70-03 Standards to Apply
atcb.com
Example 1 SRD:
ERC 70-03 Standards to Apply
atcb.com
Example 1 SRD:
Full R&TTE Requirements
• Compliance test requirements
– Radio: EN 300 220-3
• Radio and Spectral Matters
– LVD: EN 60065
– EMC EN 301 489-3 (SRD)
• Emissions
• Immunity
atcb.com
Example 1 SRD: Documentation
•
Requirements
1.
2.
3.
4.
Equipment complies: Test report/TCF
Generates and signs DOC
Labels equipment
Notifies countries before marketing (Only if
frequencies are not harmonized)
atcb.com
Example 2:
Spread Spectrum WLAN/RLAN
• Equipment Parameters:
– 2400-2483.5 MHz
– Power <100mW EIRP
– Duty Cycle: No Restriction
atcb.com
Example 2 RLAN:
ERC 70-03 Restrictions
atcb.com
Example 2 RLAN:
ERC 70-03 Technical Restrictions
atcb.com
Example 2: ERC 70-03
Standard to Apply
atcb.com
Example 2: Standard to Apply
atcb.com
Example 2 RLAN:
Full R&TTE Requirements
• Compliance test requirements
– Radio: EN 300 328
• Radio and Spectral Matters
– LVD: EN 60950
– EMC EN 301 489-17 (RLAN)
• Emissions
• Immunity
atcb.com
Example 3: GSM Phone
atcb.com
Example 3 GSM Phone:
Harmonized Standard for BS
atcb.com
Example 3 GSM Phone:
Harmonized Standards for Handsets
atcb.com
RF Exposure
• Harmonised Standards for
Electromagnetic Fields
• EN50360 & EN50361 for handsets
atcb.com
Labeling Summary
Route to
Compliance
Frequency
Allocation
Notified
Body Used
No
Harmonized
Yes
Marking
CE mark
CE mark
NB number
Standards route
No
CE mark
ECI
Yes
CE mark
NB number
ECI
Yes
CE mark
NB number
Nonharmonized
Yes
CE mark
NB number
ECI
Harmonized
Yes
CE mark
NB number
Nonharmonized
Yes
CE mark
NB number
ECI
Nonharmonized
Harmonized
Technical
construction
file route
Full quality
assurance route
atcb.com
R&TTE Labeling Example
NAME OF A COMPANY
MODEL NUMBER
SERIAL NUMBER
FREQUENCY
BAND
nnnn
The Notified Body Number: used when either annex III, IV or V have been used
Alert symbol used when frequency is not harmonized
atcb.com
Conclusions
• Much simpler than in years past
• CE Marking allows access to multiple
markets
• Frequencies increasingly harmonized
• Good access to ETSI/EN standards
• Worldwide product designs possible for
many types of products.
atcb.com
Thank You!
atcb.com