Tuesday, October 2, 2018

RF Module Approval Guide - draft

A new draft FCC KDB publication was issued on Sept. 28, 2018. Publication 996369, which answers the “Question: What is the FCC guidance for equipment authorization of transmitter module devices, and equipment that incorporates transmitter modules?

FCC Draft Publications

Tuesday, August 28, 2018

FCC Steps up enforcement

FCC fines LED light suppliers for rule violations. Fines range from $15,000 to $61,000.

In an article posted on Digital Signage Today, it’s reported that the FCC is significantly stepping up enforcement of the radio equipment rules. The article quotes Commissioner Michael O'Reilly as stating that the FCC intends to pursue vigorous enforcement and suggests substantially increasing fines on violators.

While the FCC has been relaxing the requirements, oversight and complexities of the authorization methods for products, they still take violations of the rules very seriously. It is reported that the FCC has recently targeted LED light suppliers and found multiple violations of the rules. Violations that range from improper labeling to marketing and selling without first applying proper FCC equipment authorizations.

Monday, July 16, 2018

New EU EMC and Radio Standards lists published

EMC Directive (2014/30/EU) Harmonized Standards

A new list of EMC Directive (2014/30/EU) Harmonized Standards has been published in the Official Journal of the European Union. This is the first update in two years.

You can find a link to the updated lists on our web site at;

EN 12895:2015 - New
EN 16361:2013+A1:2016  - Mandatory by  Nov. 30, 2018
EN 50121-3-1:2017  - Mandatory by  Nov. 30, 2018
EN 50121-3-2:2016  - Mandatory by  Nov. 30, 2018
EN 50121-4:2016  - Mandatory by  Nov. 30, 2018
EN 50121-5:2017  - Mandatory by  Nov. 30, 2018
EN 50270:2015  - Mandatory by  Nov. 30, 2018
EN 61000-6-5:2015    New

RED (2014/53/EU) Harmonized Standards

No major changes from previous list.
One note is EN 301 893 V2.1.1 clause 4.2.7 is the only option with regard to adaptivity.

Again you can find a link to the updated lists at;

Wednesday, November 1, 2017

4 important FCC authorization rule changes

Significant changes to FCC equipment authorization rules has been in the works for some time. A Notice of Proposed Rule Making (NPRM) in 2015 included proposals to update and streamline the authorization process. The First Report and Order (FCC 17-93) was adopted on July 13, 2017 and is expected to go into effect on November 2, 2017 by publication in the Federal Register. This publication date also marks the date for the opening of the period for reconsideration.

This First Report and Order (See ET Docket No. 15-170) is lengthy and contains a significant number of changes, a summary of four is provided to address the main topics.

  • Adds Self Declaration procedure (SDoC) combining Verification and DoC into one.
  • Extend E-Labeling to both SDoC and Certification.
  • Eliminates customs FCC Form 740.
  • Updates measurement procedures.

The Verification and Declaration of Conformity have been combined into an SDoC procedure. Testing can be performed at any lab capable of performing the tests and does not require accreditation. The product labeling and information to the user requirements have changed and a compliance information statement shall be supplied with each product. The responsible party under the SDoC MUST be located within the United States. This change also allows the responsible party, if desired, to apply for certification for any device subject to the SDoC rules.

E-Labeling has been extended for those devices equipped with a display, or can only operate in conjunction with another device equipped with a display, to provide the FCC ID, warning statements, and compliance statements in a "hardened factory non-alterable" format accessible to the user no more than three steps from the devices setting menu.

An FCC Form 740 is no longer required on importation. Originally intended to aid the FCC and CBP in preventing improperly authorized devices from entry into the United States and serve as an attestation of compliance. The usefulness of this form is questionable and the burden on the importation process significant. Section 2.931 now extends responsibilities previously only applied to parties of certified devices, to the responsible party under an SDoC.

Updates covering measurement procedures include direct reference and a link to the Commission's Knowledge Database within part 2 (§ 2.947 Measurement procedure). Composite systems and measurement procedures are now detailed in part 2.947. ANSI C63.26:2015 for Licensed Radio Services is now codified.

The authorization requirements provide for a one year transition for mandatory compliance starting from the date of publication in the Federal Register. Until that time, either the new or the old authorization rules can be applied.

A Second Report and Order is anticipated that will include updates to the certification requirements for devices assembled from modular components; specify requirements that apply to responsible parties for different types of certified equipment; add provisions to prevent unauthorized modification of software and firmware effecting compliance with FCC rules; address the number of devices that can be imported for personal use.

ET Docket No. 15-170
Review of the Commission’s Equipment Authorization Proceedings - TCBc Training Nov. 1 2017

Monday, April 3, 2017

Can incandescent light bulbs cause interference?

In an article I wrote several years ago, I implied that in our quest for energy efficient lighting solutions, the move from incandescent to alternatives such as LED lighting have introduced some new problems with radio interference that we didn't have with incandescent light bulbs.  Well, actually that wasn't exactly true. We did have interference and the "problems" are not new but, a different manifestation of an old problem.

Recently the European market surveillance authorities (AdCos) on EMC have been investigating the potential of incandescent light bulbs to cause radio interference. The investigation began with reports that some incandescent lights may be the cause of reported interference to FM broadcast reception. The findings show that a specific type of incandescent bulb can interfere with radio reception.  The type is referred to as a 'squirrel cage' Edison bulb in the report.

As an Electromagnetic Compatibility engineer, this came as a bit of a surprise to me. It's been accepted by EMC experts that an incandescent light bulb on its own wouldn't emit radio signals, in fact, the European standard covering interference from lighting states; 
"incandescent lights "are not expected to produce electromagnetic disturbances"  
yet this new data proves otherwise. So what's changed?  After a bit of research I found the answer, nothing, we've just stumbled on an old problem inherent to the once obsolete but now trendy retro vintage style vacuum Edison bulb.

In the United States, the problem was known in the 50s to cause interference with T.V. reception. Although not in production in the U.S. at the time, there were still a number of the straight tungsten-filament Mazda bulbs in use. Tungsten-filament bulbs of the Mazda type were initially more costly than carbon filament bulbs but used less electricity. A direct comparison to the LED vs Incandescent light bulb today

This Popular Science article from 1953 titled "U.S. declares war on static", a campaign of hams and hobbyist sponsored by the FCC shows an example of how to identify T.V. interference from an obsolete light bulb. Today's filament light bulbs use an inert gas and relatively small coiled filament rather than a hard vacuum and a long zigzag filament structure.

An investigation of the science and physics behind the phenomenon indicate this is caused by the filament oscillations coupled with thermionic emissions from the heated filament in a hard vacuum, similar to properties found in vacuum tubes. This post "Rustika lightbulb FM measurements " provides data and analysis and links to other works. 

So in conclusion, if you're having new and strange problems with radio reception, and you've installed one of those vintage light bulbs, try unscrewing it.

Did you find this helpful, or informative? Please leave a comment or like below!

EUANB (17)003 Report from EMC WP 25 (February 2017)
When Technologies Collide! Radio Interference from Light Bulbs (May 2010)

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

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


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 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.