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Tuesday, July 16, 2019

Market Surveillance and Compliance of Products

New EU Regulation (EU) 2019/1020 on Market surveillance and product compliance.

Original news posted by NIST. As mentioned in the NIST TEL MRA team release

"The new regulations will impact most manufacturers/economic operators placing products on the market in the EU."

Given that most readers of my posts will be impacted I have copied the release for re-circulation here.

ORIGINAL NIST TEL MRA MEMORANDUM ;


Dear Colleagues:


Important Dates:
  • Enters into force on July 16, 2019 (20 days after publication in the OJEU)
  • Clauses regarding the establishment of the “Network” and funding apply as of January 1, 2021
  • Remaining clauses apply as of July 16, 2021

The new regulations will impact most manufacturers/economic operators placing products on the market in the EU.  

Key Provisions

  • Establishes a new Union Product Compliance Network (Article 29) (referred to as the “Network”) that will coordinate Member States enforcement authorities and market surveillance authorities – Article 29
  • Gives the Commission the ability to designate Union Testing Facilities of its own or in a Member State - for testing of products – (48) and Article 21
  • Requires Member States to establish a single market surveillance liaison office – Article 10 (3)
  • Requires Member States to ensure that their market surveillance authorities have the right resources and powers
  • Allows Member States to give their market surveillance authorities power to require access to embedded software, reverse engineer products (and other powers) – Article 14 (4a and 4j)
  • Brings the “fulfillment service providers” into the list of economic operators – Article 3 (11)
  • For some products, requires that there be an economic operator established in the EU – this can be the manufacturer, the importer, an authorized rep, or the fulfilment service provider  – See Article 4  
    • In such cases,  specific information must to be included on or with the product, including the contact details of the economic operator – Article 4 (4)
    • This does apply for products covered under the RED and EMCD  – Article 4 (5)
  • Requires that “information society service providers” cooperate with market surveillance authorities for products being sold on-line - Article 7 (2)
  • Requires that the MS authorities take account of test reports or certificates issued by CABS accredited in accordance with 765/2008  as part of “checks”: - Article 11 (5)
  • Requires that Member States give economic operators at least 10 working days to be heard before a measure is taken if possible  – Article 18 (3)
  • Gives Commission ability to approve of specific pre-export control systems established by third countries if there is “official” verification done by the third country – Article 35 (3) and (7)

See the attached document (or the link above) for further details. 

In the News  

Thank you.

Kind regards,

The NIST TEL MRA Team

Thursday, February 21, 2019

Electronic Device Retailers FCC Issues Warning



February 15, 2019, the Federal Communication Commission issued an enforcement advisory warning electronic device retailers, yes, those selling devices not just making them, of potential fines if devices are in violation of the applicable FCC authorization requirements. Fines could total more than $150,000 per violation.

This is of significant importance as many retailers and distributors assume that the device manufacturer shoulders the burden for regulatory compliance, and accepts that if a product manufacturer claims compliance then that is all that is required, often retailers and distributors are unaware of the authorization requirements but this advisory opens the door for retailers and distributors to face penalties if the products are not in compliance with the required FCC authorization methods found under part 15 of Title 47 Code of Federal Regulations.

Specifically, this advisory is addressing those products that fall under the "Suppliers Declaration of Conformity" or SDoC authorization rules. A non-exhaustive list of examples of the types of products covered can be found in C.F.R. 47 §15.101(a) and §18.203.

For a basic guide and to understand what the SDoC authorization encompasses, please visit https://celectronics.com/training/learning/authorization/FCC-SDoC-Guide.html

REF:
https://docs.fcc.gov/public/attachments/DA-19-91A1.pdf

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?




Ref:
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;
https://celectronics.com/certification/europe/

Summary   
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;
https://celectronics.com/certification/europe/
 

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.

REF:
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!

REF:
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.