RED vs FCC

RED vs FCC
Carlo 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)

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)

Structure of CFR 47

15.217 Operation in the band 160-190 kHz
15.223 Operation in the band 1.705-10 MHz
15.225 Operation within the band 13.110-
14.010 MHz
15.227 Operation within the band 26.96-27.28
MHz
MHz
15.231 Periodic operation in the band 40.66-
40.70 MHz and above 70 MHz
15.233 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
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 MHz
15.240 Operation in the band 433.5-434.5 MHz
Intentional Radiators: 47 CFR Part 2 Subpart C
15.242 Operation in the bands 174-216 MHz and
470-668 MHz
15.245 Operation within the bands 902-928 MHz,
2435-2465 MHz, 5785-5815 MHz, 10500-
10550 MHz, and 24075-24175 MHz
2400-2483.5 MHz, and 5725-5850 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 GHz
15.257 Operation within the band 92-95 GHz

Technical Specifications
CFR47
• Part of the
Law
• Compulsory
application
• No changes
ENStandards
• 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
Radio
Part 15
Sub-part C
Other 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

02.12.2016 NEMKO ITALY CUSTOMER SEMINAR16
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
Mobile
No SAR requirements
< 20 cm from the user body
Portable
SAR 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 DoC
and 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 DoC
Declaration 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

30
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Nemko SpA a Socio Unico
Sede Legale, Amministrativa e Operativa:
Via del Carroccio, 4 - 20853 Biassono (MB)
Tel.: +39 039.220.1201 Fax.: +39 039.2201221
segreteria@nemko.com - www.nemko.com

RED vs FCC

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