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

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