FCC - Validation of test sites for radiated emission testing

Posted Aug. 22, 2024, a Petition for Rule-Making requesting to incorporate the newly adopted ANSI/USEMCSC C63.25.2-2024 standard, rules for the validation of test sites used for radiated emission testing between 30 MHz and 1 GHz., into FCC Title 47 Part 2 and Part 15.

The C63.25 standard series will consolidate site validation methods into a standard series for reference from within various test method standards (i.e. C63.4, C63.10 etc.). The series addresses the appropriate and required site validation for sites used when performing tests related to the applicable frequency range of measurement.

C63.25.1 - Validation Methods for Radiated Emission Test Sites, 1 GHz to 18 GHz

C63.25.2 - Validation Methods for Radiated Emission Test Sites, 30 MHz to 1 GHz

C63.25.3 - Validation Methods for Radiated Emission Test Sites, 18-40 GHz

The content of C63.25.2 consists of the traditional normalized site attenuation methods used for years and the addition of two new methods, a site comparison method (SCM) and delta NSA (DNSA) method. For more information and details on the new methods see reference below or obtain a copy of C63.25.2.

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Ref:

https://www.fcc.gov/ecfs/search/search-filings/filing/108210752429140

FCC Rules update Report & Order

 

FCC updates rules to incorporate new and updated standards that are integral to equipment testing.

Some of the changes incorporated;

• (1)    CISPR 16-1-4:2010-04: “Specification for radio disturbance and immunity measuring apparatus and methods — Part 1-4: Radio disturbance and immunity measuring apparatus — Antennas and test sites for radiated disturbance measurements,” Edition 3.0, 2010-04, IBR approved for § 2.948(d).
  
  
• (2)    ANSI C63.4-2014: “American National Standard for Methods of Measurement of RadioNoise Emissions from Low-Voltage Electrical and Electronic Equipment in the Range of 9 kHz to 40 GHz,” ANSI approved June 13, 2014, Sections 5.4.4 through 5.5, IBR approved for § 2.948(d).
  
  
• (3)    ANSI C63.4a-2017: “American National Standard for Methods of Measurement of RadioNoise Emissions from Low-Voltage Electrical and Electronic Equipment in the Range of 9 kHz to 40 GHz, Amendment 1: Test Site Validation,” ANSI approved October 13, 2017, IBR approved for §2.948(d).
  
  
• (4)    ANSI C63.25.1–2018, “American National Standard Validation Methods for Radiated Emission Test Sites, 1 GHz to 18 GHz,” ANSI approved December 17, 2018, IBR approved for §2.948(d).
  
  
• (5)    ISO/IEC 17011:2004(E), “Conformity assessment — General requirements for accreditation bodies accrediting conformity assessment bodies,” First Edition, 2004-09-01, IBR approved for §§2.948(e), 2.949(b), and 2.960(c).
  
  
• (6)    ISO/IEC 17025:2017(E), “General requirements for the competence of testing and calibration laboratories,” Third Edition, November 2017, IBR approved for §§ 2.948(e), 2.949(b), 2.950(a), and 2.962(c) and (d).
  
  
• (7)    ISO/IEC 17065:2012(E), “Conformity assessment — Requirements for bodies certifying products, processes and services,” First Edition, 2012-09-15, IBR approved for §§ 2.960(b), 2.962(b), (c), (d), (f), and (g).

Transition period – 2 years after effective date of final rule

REF:

FCC 32-14 / ET Docket No. 21-363 

UK product conformity markings "new measures"

UK - Government announces a range of changes to make it simpler for business to apply new conformity markings for products placed on the market in England, Scotland and Whales.

 REF: 

Product Conformity Markings - new measures 

New European Union "Blue Guide" published

 

A new version of the "Blue Guide" on the implementation of EU product rules has been published.

This new version builds on past editions while also reflecting recent changes in EU legislation, in particular, the adoption of new regulations on market surveillance. 

REF:

https://bit.ly/EU-Blue-Guide

EN 55024 date of withdrawal set

Implementing Decision (EU) 2021/455 published March 16, 2021, has set the date of withdrawal of EN 55024 (immunity for Information Technology Equipment) to Sept. 16, 2022. EN 55024 has been superseded by EN 55035 (immunity for Multimedia Equipment).

This publication also sets the date of withdrawal for EN 55103-2 (immunity for Professional Entertainment Lighting and Control), to July 28, 2022.

The date of withdrawal of a European EN is the date by which all superseded standards are withdrawn and cease to give presumption of conformity.

 REF:  

https://eur-lex.europa.eu/eli/dec_impl/2021/455/oj

IEC 60601-1-2 Edition 4.1

September 2020, the EMC Standard for medical devices, IEC 60601-1-2 edition 4.1, has been published. Added to the FDA recognized consensus standards on December 21, 2020 with partial recognition. 

The FDA has designated a 3 year transition period, after which the previous version will not be accepted- REC#19-8 (IEC 60601-1-2:ed4.0 + ANSI AAMI IEC 60601-1-2:2014).

New testing requirements include 

• Testing at minimum and maximum input voltage levels for conducted emissions and voltage dips and short interruptions
• Power frequency magnetic field at either 50 or 60 Hz so long as the frequency is the same as that used to power the equipment
• A new technical reference standard has been added IEC 61000-4-39:2017 
• Magnetic field immunity testing requirements from 9 kHz to 13.56 MHz 

Some of the normative references have been updated to reflect new versions of older base standards updating requirements for emissions and surge and voltage dips. Removal of ISO 7137:1995 procedures for airborne equipment.

The standard includes guidance on the determination of immunity levels and adjustments according to implemented mitigations and intended use. Identification of pass/fail and guidance on risk management for basic safety and essential performance related to electromagnetic compatibility. 

REF:

FDA FR Recognition Number 19-36  http://bit.ly/60601-1-2ed4-1

UKCA Guidance Designated standards: EMC

 The UK has published a list of designated standards for EMC

https://www.gov.uk/government/publications/designated-standards-emc

Additional information regarding UK EMC regulations can be found at https://celectronics.com/training/learning/authorization/UK-EMC-Regulations.html

Canada ICES-003 update

Innovation, Science, and Economic Development Canada (ISED) has published issue 7 of ICES-003. Following are the main changes as published in the standard.

1. Changed title of the standard from Information Technology Equipment (Including Digital Apparatus) — Limits and Methods of Measurement to Information Technology Equipment (including Digital Apparatus) 

2. Added requirements for devices with wireless power transfer functionality (section 1.3) 

3. Removed requirements that are specified in ICES-Gen and referred to ICES-Gen for all general requirements (section 2.2) 

4. Removed the alternative limits (ICES-003 now has only one set of limits), while continuing to allow either the CISPR or ANSI test methods (section 3) 

A copy of the standard can be obtained via the ISED page at ic.gc.ca;

Link - https://www.ic.gc.ca/eic/site/smt-gst.nsf/vwapj/ICES-003-i7-2020-10EN.pdf/$file/ICES-003-i7-2020-10EN.pdf

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:

The new Regulation (EU) 2019/1020 of the European Parliament and of the Council of 20 June 2019 on market surveillance and compliance of products was published in the OJEU on June 25, 2019.

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  

• https://www.consilium.europa.eu/en/press/press-releases/2019/06/14/eu-adopts-regulation-to-keep-unsafe-products-off-the-market/  [June 14, 2019]
• https://www.lexology.com/library/detail.aspx?g=44713a72-3897-4480-86dc-05d57d07563c [June 29, 2019]

Thank you.

Kind regards,

The NIST TEL MRA Team

mra@nist.gov

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

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/

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)

Rustika lightbulb FM measurements

Popular Science April 1953

When Technologies Collide! Radio Interference from Light Bulbs (May 2010)

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?



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

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/

Valuable opportunity for Project managers and Compliance Engineers

Whenever I come across something that could benefit my community i'm compelled to share it.

A new Grassroots Movement has begun on the U.S. west coast to quote "Empower Project Managers and Compliance Engineers with knowledge and tools to guide your company and your team to achieve EMC product compliance, and fix EMC problems minimizing project cost and schedule impact!"

Beginning in September, 2015, EMCmini launches with a series of informative events. This "traveling road show" brings together industry experts and equipment manufacturers to give you the tools and information you need to stay ahead of the competition.

And now for a little "Name-dropping" ;) , some of the prominent speakers involved include;

• Ghery S. Pettit, NCE
• Mark Montrose
• Edward Nakauchi
• Shirish Shah
• Darryl Ray

Make sure to register for this event at least a week ahead! 

REF:

EMCmini.us

FCC will no longer accept applications for equipment certification

The FCC introduced a Report and order just before the new year that among other things, effectively puts them out of the RF device certification business and permits this activity to be performed solely by private Telecommunication Certification Bodies, also known as TCBs,

The big take away is that the FCC will no longer be certifying products, however also included in this report is a new requirement that all testing be done at an “accredited” lab.

A quote from the report and order; 

41. Proposal. In the Notice, the Commission proposed to require that all laboratories that test
equipment subject to Certification or to DoC under any rule part be accredited to ISO/IEC 17025, ending
the “2.948-listing” program for unaccredited labs to test equipment to be certified under Parts 15 and 18
of the rules.

Prior to this order devices subject to certification; such as radio transmitters, could be tested at any listed lab. This listing program is less rigorous and less expensive than full certification. The listing program simply requires that the lab file information with the FCC. In contrast, the accreditation requirement ensures that the the testing laboratory is competent to perform the required work, but it also requires that the laboratory be in a country that is recognized by the FCC, such as one with an established Mutual Recognition Agreement (MRA) with the United States.

Currently, many companies rely on test data suppled by third party test labs that are not accredited or are in countries which do not have an established MRA with the United States. As an example, there are no laboratories in China that are qualified to perform testing for FCC certification or DoC, due to the fact that there is no MRA between China and the United States.

Along with this change the FCC lays out the process for a pre-grant approval procedure to be followed when a TCB is faced with certification of a device based on new technology.

The FCC also makes clear in the report the TCB’s responsibility in performing “post-market” surveillance of products it has certified.

Reference;

http://transition.fcc.gov/Daily_Releases/Daily_Business/2014/db1230/FCC-14-208A1.pdf

New Radio Equipment Directive Published

European Union flag (Photo credit: YanniKouts)

The new Radio Equipment Directive (RED) 2014/53/EU, replacing the R&TTE directive, has been published in the Official Journal of the European Union. The directive enters into force 20 days after publication and shall be transposed and become applicable 24 months after the date of entry into force.

Products have one extra year before they must comply with the new requirements. Products that comply with the current EU R&TTE directive 1999/5/EC can be placed on the market up to 36 months after the date of entry into force.

Publication in the OJEU was on 22nd May 2014.

Ref:

RTTE-CA presentation by the European Commission Unit F5

Directive 2014/53/EU http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=OJ:JOL_2014_153_R_0002&from=EN

New EMC Directive Published

The revised Electromagnetic Compatibility Directive (EMC Directive) has been published in the Official Journal of the European Union (3/29/2014)

A new “Blue Guide”  on the implementation of the EU product rules, 2014 edition, has been published.

Visit http://celectronics.com/europe.htm for links to both documents.

New EMC directive and LVD - NLF (New Legislative Framework) recast

European Commission (Photo credit: tiseb)

Voting has concluded and a number of CE marking directives have undergone a “recast” to align with the European Commission New Legislative Framework (NLF). Among the new directives for electrical products are the Electromagnetic compatibility EMC Directive and Electrical equipment designed for use within certain voltage limits Low Voltage Directive.

The updated directives align them with the legislation laid down within the “NLF”. The NLF, adopted in 2008, is intended to improve market surveillance rules, require traceability within the supply chain, boost the quality of conformity assessment through stronger rules on the requirements imposed on conformity assessment bodies and testing laboratories, and stronger controls on the use of the “CE Mark” to enhance the marking credibility.

REF;

http://europa.eu/rapid/press-release_IP-14-111_en.htm – European Commission Press Release (Feb. 5th 2014)

Radio module integration and R&TTE compliance, EMC evaluation

radio module (Photo credit: ckhamken)

Building on a previous post focusing on radio module integration and the Radio and telecommunications terminal equipment (R&TTE) directive compliance, this article will focus on compliance of the combined apparatus with section 3.1(b) of the R&TTE directive, namely the essential requirements of Electromagnetic Compatibility or EMC.

As a basic primer, the R&TTE directive’s essential requirements are detailed within the directive under article 3, to paraphrase;

3.1 Essential requirements applicable to all apparatus;

       a. Safety requirements of the Low Voltage Directive, with lower limits removed

       b. Electromagnetic compatibility as per EMC directive

3.2 Effective use of radio spectrum

3.3 Construction, protection and accessibility requirements (with a number of specified items)

As posited in a previous post “Radio module integration and R&TTE compliance”, compliant radio modules installed in accordance with a manufacturer’s installation instruction require no further evaluation to article 3.2 of the R&TTE directive. However, an assessment, in most cases, will be necessary for article 3.1(a) and 3.1(b). The combined product will essentially form a new apparatus.

Given that the combined product should be assessed as a new apparatus, a couple questions may arise. What EU directive and standards apply? How do you make an assessment for EMC on the combined product?

When adding a radio to an apparatus, the new combined apparatus now falls within the scope of the R&TTE directive. ETSI EN 301 489-1 annex C gives guidance regarding this combined equipment EMC assessment, and it is based on the ETSI TR 102 070-1 technical report. In accordance with the guidance, for a combined apparatus where all products can operate independently of each other, an evaluation may be made by review of existing assessment of the individual apparatus, and if it is concluded that the combined configuration has been assessed and is representative of the combined apparatus, and, is used in according to its manufacturer’s instructions, it is not necessary to re-assess the apparatus. If there is insufficient information to make an evaluation, or the results of the evaluation are unclear, then an additional assessment shall be performed. Most of the time an assessment for EMC of the combined apparatus will not have been performed, or there is insufficient data to support a declaration of conformity.

Although under the scope of the R&TTE directive, the selection of applicable standards for EMC will be based on the primary function of the newly combined apparatus. The manufacturer shall declare the primary function and identify applicable standards from the EMC directive and/or R&TTE directive. The assessment should be supplemented with test levels and extended frequency ranges to cover both radio and non-radio aspects of the newly combined apparatus (i.e. a worst case representation of applicable levels and limits). See this flow chart from Compatible Electronics for a simplification of the assessment process based on the ETSI guidance.

The declaration of conformity will need to declare compliance with the R&TTE directive, and the party responsible for the completed combined apparatus is the party responsible for ensuring that the final configuration, when used properly, and in accordance with the provided instructions, fulfills ALL essential requirements of the R&TTE directive.

 

REF:

ETSI TR 102 070-1

ETSI EN 301 489-1 annex C

R&TTE CA TGN 01 Rev 5

GUIDELINES ON THE APPLICATION OF DIRECTIVE 2006/95/EC (par. 34)