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Monday, March 27, 2017

FCC expands AB accreditation of labs in non-MRA countries




On March 23, 2017, the Federal Communication Commission daily digest published the expansion of scope to include accreditation of labs in non-MRA countries for two United States based laboratory accreditation bodies (AB), the National Voluntary Accreditation Program (NVLAP) administered by NIST and the American Association for Laboratory Accreditation (A2LA).

The term MRA stands for Mutual Recognition Agreement. This reciprocal agreement between nations in its simplest form is an agreement to accept one another’s local conformity assessment body’s assessment of local laboratories and inspection bodies for testing and certification to the other country’s requirements. 

In an over-simplified sense, “You accept my test results, we’ll accept yours”. You can find a more thorough explanation and a list of countries with which the United States has an MRA in place on this FCC page.

For non-MRA countries there is no established government to government agreement to accept the other’s compliance assessment, many of these non-MRA countries require an inspection to be carried out by their own domestic labs or by an appointed government department making it far more expensive and time consuming to import into such economies. 

Some non-MRA countries follow other MRA programs such as the ILAC MRA that help to lower the time and costs associated with testing/inspection and facilitate trade.

The largest example, by population, of countries that do not have an MRA with the US, is commonly referred to as “BRICS” which stands for Brazil, Russia, India, China, and South Africa. 

With the expansion of scope for the two US accreditation bodies to include non-MRA countries the FCC opens a path for laboratories in non-MRA countries to test products for import to the US and provides a mechanism for quality control. 

Some have suggested that this may disincentivize non-MRA countries from pursuing a future MRA, which ultimately may have a negative impact on domestic test laboratories and small to medium scale domestic manufacturers.

What are some other considerations, good or bad, on the acceptance of non-MRA country assessments to US requirements?

Me: I work for Compatible Electronics, Inc. an accredited U.S. test lab and product certification body

REF:
https://transition.fcc.gov/Daily_Releases/Daily_Digest/2017/ddtoday.html
https://www.fcc.gov/general/equipment-authorization-mutual-recognition-agreements
https://www.wto.org/english/tratop_e/tbt_e/tbt_e.htm
http://ilac.org/about-ilac/
https://en.wikipedia.org/wiki/BRIC




Monday, December 12, 2016

5 Questions on the new Radio Equipment Directive 2014/53/EU (RED)


Coming into force on June 13, 2016, and half way through the transition period, the Radio Equipment Directive (RED) 2014/53/EU replaces the Radio and Telecommunications Terminal Equipment Directive (R&TTED)  1995/5/EC and over the past few months I've received numerous questions regarding the transition to the new directive. This isn't an all inclusive list or a full transition guide, far from it, I recommend that you consult a RED Notified Body with your specific needs for that. 


Here are the 5 most common questions I receive.



"Do I need to apply the new directive immediately?"
No, the RED came into force on June 13th 2016, however, article 48 gives a transitional provision accepting the old directive for radio equipment covered by the RED until June 12, 2017. That is to say you must apply the RED to covered radio equipment on or after June 13th 2017.


"Should I start testing to the new directive now?"
I get this a lot, and it's a very common misconception. One does not simply "test" to a Directive, you declare compliance to the Directive. 

The directive contains the essential requirements of compliance, among other laws, governing the "making available on the market" of Radio Equipment. Testing is one method for demonstrating compliance with the essential requirements, but the actual test methods are found outside the directive, referred to as "Harmonised Standards" under the directive. 

While in order to use a "Harmonised Standard" for presumption of conformity, it must be published with reference to the RED in the Official Journal, the new directive doesn't change harmonized standards, but it may impose new "essential" requirements that could impact your testing.


"Can I start "declaring" compliance to the new directive?"
Probably not. Article 17 of the RED describes the conformity assessment procedures. There are three annexes describing the available methods. (Annex II Internal Product Control) (Annex III EU-type examination) and (Annex IV Full Quality Assurance).

By far Internal Production Control is the most commonly used conformity assessment method and it's the only method that does not require 3rd party involvement of a Notified Body, but in order to apply Annex II, you must test in full to published harmonized standards. The problem is that the list of harmonized standards published under the new RED is small compared to the R&TTE. Chances are at the moment the particular harmonized standard previously applied has not been adapted and referenced to the RED, but the list is growing. See https://celectronics.com/certification/europe/ for links to the published harmonized standards.

Another issue here is that there is a change, however so slightly, in the requirements from the R&TTE article 3.2. This small change adds a new requirement to be assessed, and that is that the Radio Equipment "supports the efficient use of radio spectrum". New technical standards will need to incorporate this requirement.


"If I can't test in full to published harmonized standards, is there a method to comply with the RED now?"
Yes, there are a couple as mentioned above, Annex III EU-Type examination and Annex IV Full Quality Assurance. Of the two, EU type examination would generally be the most practical for most organisations that don't have the ability or wish to submit to a full quality assurance assessment or the continued surveillance required of that system.

EU-Type examination is a method by which the manufacturer submits an application to a "single" Notified Body of their choice. The Notified Body will review the technical design and verify the equipment complies with the essential requirements of the RED and if so issue an EU-Type examination certificate. This would be combined with the manufacturer's own assessment and the Declaration of Conformity (which will include the Notified Body number). The manufacturer would then affix the CE mark to the equipment (without including the Notified Body number)

 “If I test to the current harmonized standards for the R&TTE and write my declaration to the R&TTE now, what do I need to do June 13th, 2017?”
On or after June 13th 2017, all equipment that falls within the scope of the RED must be assessed to be in compliance with the RED prior to placing on the market in the European Union. This does not apply to equipment already on the market (sold or in the EU), only new shipments being placed on the market. The declaration of conformity must follow the new Model Structure and the manufacturer shall also establish the required technical documentation described in Article 21 of the RED. Also note that in addition to the technical test report the manufacturer is required to provide a risk assessment within their technical documentation.











Friday, April 8, 2016

FCC U-NII Band 5 GHz devices


U-NII rules, Title 47 Part 15 Subpart E, cover devices operating in the 5.15-5.35 GHz, 5.47-5.725 GHz and 5.725-5.85 GHz bands. 

All new applications will be assessed to the new rules. Devices certified under the old rules must meet the new rules on or after June 2, 2016. Devices already in use and installed are grandfathered.

European CE marking

EU has published the updated 'Blue Guide' on the implementation of EU product rules 2016. This is in advance of the coming into force of updated directives.

Directive Transition dates;
  • EMC Directive 2014/30/EU – April 20, 2016
  • Low Voltage Directive 2014/35/EU – April 20, 2016
  • Radio Equipment Directive 2014/53/EU – June 12, 2016

You can find links to these directives and additional information on CE marking at http://celectronics.com/certification/europe/

Wednesday, September 16, 2015

New U-NII requirements postponed

The FCC has waived, until December 2, 2015, the implementation of the new U-NII requirements, Specifically 15.37(h).

This allows 5.8 GHz deices to continue using the DTS rules in 15.247 for approval and certification.

(h) Effective June 2, 2015* devices using digital modulation techniques in the 5725-5850 MHz bands will no longer be certified under the provisions of §15.247. The technical requirements for obtaining certification after this date for digitally modulated devices and the digitally modulated portion of hybrid devices are found in subpart E of this part. The provisions for the frequency hopping spread spectrum portion of hybrid devices will remain in §15.247. Effective June 2, 2016 systems using digital modulation techniques in the 5725-5850 MHz band certified under the provisions of §15.247 may no longer be imported or marketed within the United States.

By this order *June 2, 2015 in the above rule part is in essence replaced with December 2, 2015

REF:

https://www.fcc.gov/document/u-nii-devices-extension-order

Title 47, Part 15.37

Wednesday, August 26, 2015

"update" FCC Proposing significant changes

This is an update to a previous posting regarding an FCC NPRM proposing several changes to the rules governing authorization of radio frequency equipment.
See previous post  FCC Proposing significant changes

"the deadlines for filing comments and reply comments in the above captioned proceedings ARE EXTENDED to October 9, 2015 and November 9, 2015."

Ref:
http://transition.fcc.gov/Daily_Releases/Daily_Business/2015/db0825/DA-15-956A1.pdf

Thursday, August 20, 2015

FCC to be "off-line" early September through Labor Day


The FCC has scheduled an IT infrastructure upgrade starting 6 pm EDT September 2nd, 2015 and running through 8 AM EDT September 8th, 2015.

The result of this upgrade will take most of the Commission's resources off-line. Among the resources that will be unavailable are all electronic filing systems; including the Certification Body (TCB) site used for issuing grants and the Knowledge Database (KDB) system used to provide testing and certification guidance to labs and TCBs.

The FCC web site will be available but with limited content and search capabilities. FCC telephones will work but voicemail systems will not, and most FCC staff will not have access to email.

Ref:
Public Notice DA 15-940