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

New R&TTE and EMC Standards List Published in OJ

New Harmonized standards lists have been published in the Official Journal of the European Union for the Radio and Telecommunication Terminal Equipment(R&TTE) Directive and the EMC Directive.

R&TTE Directive Standards List

EMC Directive Standards List

2011 market surveillance report EU –are tablet PCs a target for 2012?

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Bundesnetzagentur (Federal Network Agency) of Germany, for Electricity, Gas, Telecommunications, Post and Railway has the responsibility to carry out the market surveillance under the EMC and R&TTE Directives.

The agency published a summary of the 2011 market surveillance campaign on its web site. The campaign’s primary focus in 2011 was with the EMC directive and in particular, LED lighting equipment. The report also combines results from the 2010 and 2011 campaigns to give a summary overall and to achieve a low error probability due to the larger sample size.

For some background on emissions concerning LED product, see July 2011 post “Radio interference from LED lighting”.

The surveillance looked at administrative conformity, such as marking, documentation and declarations, as well as the technical aspects of the directive namely compliance with the emissions and immunity requirements. A total of 168 products were sampled in 2011.

On the administrative side, the surveillance found that 76.8% of the samples were compliant with the CE marking requirements, while only 39.9% were compliant with the Declaration of Conformity (DoC) requirements.

For the technical assessment, 61.5% of product complied with the radio emissions requirement, and 91.3% were found immune to specific interference phenomenon, out of 46 products tested overall.

In total, only 17.3% of LED lighting equipment was found to be fully compliant.

For the “reactive market surveillance”, the overall rate of non-compliance for electromagnetic compatibility (EMC) was 38.9%. For radio and telephone terminal equipment (R&TTE) a majority, 65.5%, was found non-compliant according to the report, but most concerning was that 75.6% of the R&TTE products checked were non-compliant with the safety and health measurement requirements.

The 2011 surveillance resulted in 90 EMC sales bans, 177 R&TTE sales bans, 353 “memoranda of understanding” between the two directives, and total revenues of €1,046,000

The report details some objectives for 2012 indicating supporting the revision of the EMC and R&TTE directives and transposition into national law, including harmonizing product assessment for market surveillance, and increasing cooperation with European market surveillance and customs authorities as well as adapting the national database for market surveillance results, to the European ICSMS database.

Two product group targets were mentioned for 2012, one a coordinated German/Dutch campaign targeting tablet PCs focused on the R&TTE directive, and another targeting “Ready-made connecting devices”, or laptop power supplies.

 

ref;

Market surveillance statistics 2011

New EMC Directive

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I thought I would include this in my Q&A series.  I have been receiving these questions often,

“Do you expect that a new EMC directive will be coming ?”

and

“What impact may it have on my current test plan or program ?” 

The answer  to part one is yes, and it could be very soon. As part of  the “Goods package”, the current EMC directive, 204/108/EC, is being amended in what is called an alignment with the New Legislative Framework of the European Union (or NLF). The EMC directive is part of what is called an “Alignment Package”. Eight other directives will also be processed in this alignment.

On the second question, the first thing to note is that the new approach directives are not technical in nature, but rather legal documents. Think of them as the “Law” of the land on the topics they cover. How you comply with the laws are another matter. The technical aspects are primarily addressed by Harmonised Standards or “EN” specifications. So, the EMC technical requirements, i.e. your testing, should not be impacted by this amendment to the EMC directive. While it is expected that the scope of the EMC directive will remain essentially the same, anytime that a directive comes up for amendment, interested parties look at it as an opportunity to address issues they may want included, see for example my post on cables being proposed: http://www.emcrules.com/2011/12/ready-made-connecting-devices-cables.html

The areas that would see significant change are;

• your documents (Declaration of Conformity) will change.
• A new directive number may require documents be modified, such as test reports, however there should be a reasonable transition period.
• Traceability requirements and product labeling, with specific identifying information on each product.
• Economic operators must keep records of supplier and distributor (already required for consumer goods)
• New supply chain duties, harmonized across the EU.
• Enforcement authority will be able to target more directly those infringing due to supply chain reporting requirements.
• Expectation is that Post market surveillance activities could increase substantially (this is one of the main points of the “Goods Package”)

If not already, please subscribe to updates of the EMCrules blog. The blog is helpful in providing timely information on rule changes, and other topical news, that may affect our broad clientele. Comments are welcome.

 

ref;

EMC directive at EUR-Lex -  32004L0108

/* COM/2011/0763 final */  (Alignment of ten technical harmonisation directives to Decision No 768/2008/EC)

Marketing of products - CE conformity marking

New Legislative Framework (NLF) Alignment Package

Proposals to Align Nine Directives with the New Legislative Framework – Published by BIS Department for Business Innovation & Skills

Single market for goods New Legislative Framework

Industry Canada publishes new / updated Radio standards

On January 28th Industry Canada published the following radio standards; (Link to IC web site)

• Radio Standards Specification RSS-111, Issue 4: Broadband Public Safety Equipment Operating in the Band 4940-4990 MHz, which sets out the requirements for certification of radio transmitters and receivers in the band 4940-4990 MHz for public safety applications;

• Radio Standards Specification RSS-182, Issue 5: Maritime Radio Transmitters and Receivers in the Band 156-162.5 MHz, which sets out the requirements for certification of radio transmitters and receivers in the maritime service in the band 156-162.5 MHz; and

• Radio Standards Specification RSS-288, Issue 1: Global Maritime Distress and Safety System (GMDSS), which sets out the requirements for certification of the shipborne radiocommunication equipment that meets the requirements of the GMDSS.

 

In addition Industry Canada announced changes to RSS-Gen and RSS-310 , effective immediately , via notice NOTICE 2012-DRS0126. These changes modify section 2.2 of RSS-Gen covering Receivers, and noted that section 3.1 from RSS-310 is no longer required.

RSS-Gen section ‘ 2.2 Receivers ’ clarifies that ;

“Only radiocommunication receivers operating in stand-alone mode within the band 30 MHz to 960 MHz and scanner receivers are subject to Industry Canada requirements”

and

“All other receivers are excluded from any Industry Canada certification, testing, labeling and reporting requirements.”

Ready-Made Connecting devices (cables) under EMC directive?

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During the revision of the EMC directive 89/336/EEC, back in 2003, one of the most controversial proposals was the inclusion of “Ready-made connecting devices” within the scope of the EMC directive.

Ready-made connecting devices would encompass passive product, typically 3rd party in nature, designed to interconnect and be connected to apparatus covered within the scope of the directive, in effect classifying such connecting devices as apparatus themselves within the scope of the directive.

Products such as network cables, Audio / Video cables, and other interconnecting cables and adaptors would come under such classification and be subject to the protection requirements of the EMC directive (to paraphrase; must not interfere with others and must operate in the presence of interference without significant loss of performance) , thus requiring testing and marking as any other apparatus would.

It was argued that the term, “Ready-made connecting devices”, itself was ambiguous and unclear. Eventually it was decided that the devices represented no major interference potential, and because of the costs manufactures would incur for testing and marking, it was removed from the scope of the directive.

With the current revision and alignment of the EMC Directive with New Legislative Framework (NLF), the EMC directive 204/108/EC once again is subject to modification, and potential scope expansion. One such change being circulated for inclusion is that ready-made connecting devices be considered again and brought under the regime of the EMC directive.

In a proposal from the German Administration (BNetza), it is argued that in light of experience gained since 2003, the non interference claims argument cannot be maintained. The proposal claims there is no longer any serious doubt that insufficiently shielded connecting devices greatly increase the interference potential of TV and Cable networks in particular. The proposal cites several reports with data supporting this conclusion. One such report shows a  peak 30dB difference in screening effectiveness between two types tested, from most to least shielding, and notes that cable connectors can contribute around 10 dB of difference. See   ”The Concise Report of the CENELEC/ETSI Joint Working Group on the digital dividend" of 12 August 2010 (section 7.3)

The proposal suggests  that the following requirement be added to the new EMC directive;

Ready-made connecting devices, although incapable of generating electromagnetic disturbance in isolation, may generate or transmit electromagnetic disturbance when connected to an apparatus and should therefore be considered to be apparatus for the purposes of this Directive.

With ready-made connecting devices being defined as;

ready-made connecting devices' intended for connection to an apparatus by an end user for the transmission of signals, which are placed on the market separately from such apparatus, and which are liable to generate or transmit electromagnetic disturbance when connected to it.

This addition would then subject cables and connectors to the same technical requirements as any other product under the EMC directive, regardless of the component’s active or passive nature.

EN 55013 modified and draft going for vote

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EN 55013 is the EMC emissions standard for broadcast receivers and associated equipment. The standard is aligned with the European Union’s EMC directive as published in the official journal. The EMC directive is a CE marking directive, and compliance with this directive is compulsory for most electrical / electronic products prior to placing on the European market.

Previously reported in a post back in the summer of 2009, EN 55013, QP vs RMS, it was noted that the EU commission was holding off publishing reference to the newest edition of EN 55013, 2009, in the Official Journal.

The CENELEC technical committee, CLC/TC 210, had decided that the standard should not be published, without the link to the EMC Directive, and accordingly has set up a task force to seek a resolution.

It was agreed that the new draft common modifications should be circulated under UAP. The current project name is EN 55013:201X

The CLC/TC 210 Secretary proposed that the following explanation appear in the forward to the draft common modifications, furthermore this is not to be included in the final publish standard, should the draft be accepted:

“The text of CISPR/I/296/FDIS, the future CISPR 13 ed 5.0, received a positive vote in CENELEC, but was not ratified due to technical objections raised by the EMC Consultant. These would have prevented the listing of the standard in the Official Journal of the European Union as a harmonised standard providing a presumption of conformity with the protection requirements of the EMC Directive 2004/108/EC. The following draft includes common modifications to address these objections, and they have been agreed by the EMC Consultant and the responsible committee, TC210. It is submitted to UAP.”

It is expected that in light of the upcoming CISPR 32, perhaps appearing within a couple years, that EN 55013 will then be deleted. At that time, the use of the QP detector will have become obsolete and replaced by the RMS/Average detector.

It should be noted that the UK is not in favor of issuing the document under UAP, nor is Italy. The UK proposes to wait and see what happens with CISPR 32. The draft will be submitted under UAP none the less.

The last word on Power Line telecom (PLT) in the EU, EN 55022:2006 applies in full, maybe….

Image by Sigfrid Lundberg via Flickr

Power Line communication devices continue to be a controversial subject, with respect to the Electromagnetic Compatibility of such devices. We have been following this subject for both the United States, and for Europe. The latest round comes from across the pond with the rejection (negative vote) of the European Norm targeted to cover the testing of these devices, prEN 50561-1:201X. For background on this topic, see my past article “An update on PLT, Power Line Telecommunications, in Europe”.

Due to the negative vote on prEN 50561-1:201X, and a lack of a specific standard covering the emissions testing for PLT devices, EN 55022:2006 applies in full for these devices as of October 1st. It should be noted that many newer high speed advanced PLT devices cannot pass the requirements of EN 55022:2006 at this time.

This conclusion will be confirmed by a note published in the Official Journal reference to harmonized standards under the EMC directive.

CENELEC may offer a second vote, indicating that the choice is between EN 50561-1 and EN 55022. If this vote fails, no further option exists.

What does this mean for product on the market? Are recalls required for non compliant devices? What about new product placed on the market? The Commission is expected to accept a reasonable Date of Withdrawal (DoW) as proposed by working group 11, and until that date, manufacturers should still be able to continue placing product on the market using the Declaration of Conformity and Notified Body TCF path. The EU market authorities are “encouraged” to accept this.

The group of European Notified Bodies are meeting to discuss, and will consider the Technical Guidance Note (TGN) on the matter, after the meeting. Is this the end of the debate? Time will only tell, and we’ll continue to post when we learn more.

European Harmonized standards list update

The list of harmonized standards for the following directives have been updated.

updated 8/19/11. Council Directive 93/42/EEC of 14 June 1993 concerning medical devices. Other language copies can be found here

Updated 8/31/11Directive 2006/95/EC of the European Parliament and of the Council of 12 December 2006 on the harmonisation of the laws of Member States relating to Electrical Equipment designed for use within certain voltage limits. Other language copies can be found here

As always copies of the newest lists for EMC, R&TTE, LVD and Medical Devices can also be found at http://celectronics.com/europe.htm

By: J Klinger

Spectrum Sharing agreements with Canada and Mexico, announced by the FCC

The FCC reached agreements with Canada and Mexico for sharing commercial wireless broadband spectrum in the 700MHz band along the respective boarders, additionally, an arrangement has been made with Canada for sharing spectrum in the 800MHz band.

The goal of these arrangements is to further the deployment of commercial wireless broadband services near the boarder, with an aim to providing consumers additional options for 4G high speed mobile broadband access in these areas.

The arrangements made with respect to the 800MHz band on the northern boarder are inline with the 800MHz rebanding efforts by U.S. public safety and ESMR (Enhanced Specialized Mobile Radio) i.e. Nextel. Specifically the allotment of channels between the US and Canada, technical operational parameters within 87 miles of the boarder, and setting the schedule for transitioning facilities from US channels to complete the rebanding along the U.S.-Canadian border.

Read the FCC Press release at http://transition.fcc.gov/Daily_Releases/Daily_Business/2011/db0801/DOC-308822A1.pdf

By: J Klinger

Do you mind turning off your RF device please?

Image by James Provost via Flickr

According to a Parliamentary Assembly of the Council of Europe (PACE) report issued May 6, 2011, “waiting for high level scientific and clinical proof that electromagnetic fields emanating from high frequency sources such as radar, telecommunications and mobile phones may lead to very high health and economic costs”.
PACE will be meeting in Kyiv on May 27th, and hold a debate, and intends to adopt a resolution on the issues raised in the report.
The report invokes heath concerns, in particular using examples of asbestos, lead, and tobacco, as mistakes made in the past when dealing with unknown health risks. The report also likens the potential consequences on the environment by electromagnetic fields with licensing of medication, chemicals, pesticides, heavy metals and genetically modified organisms.
The report recommends that an “as low as reasonably achievable” approach be adopted when setting standards or threshold values for emissions of electromagnetic fields of all types and frequencies. The report urges that particular attention should be given to protecting children, and “electrosensitive” persons suffering from a syndrome of intolerance to EM fields with a call to protect them from the unknown effects of electromagnetic waves by the creation of “Wave-free” areas not covered by wireless networks.
Mobile phones, DECT phones, WiFi, WLAN and WIMAX come under focus in the reports, with the call for microwave long-term exposure thresholds of not to exceed 0.6 v/m and in the medium term reduced to 0.2 v/m. The report also makes recommendations to; undertake risk-assessments prior to licensing new types of devices, calls for additional labeling and indications of health risks, produce warnings and recommendations to use a wired alternative due to the “unknown” dangers of electromagnetic fields..
The report proposes the ban of all mobile phones and wireless networking devices from schools and classrooms.

By: J Klinger

US Mexico MRA

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A new US-Mexico Telecom MRA was signed May 26th 2011, indicated in a press release from the United States Trade Representative.

The agreement is for the recognition of testing laboratories and acceptance of test reports. Mexico will only recognize 3rd party labs. The agreement does not cover recognition of certification bodies. The agreement includes a transition period. Seven accepted  technical regulations (NOMS) are listed in Annex I of the MRA text.

EMC List of Harmonized standards published

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An updated list of harmonized standards under 2004/108/EC, the EMC directive, has been published in the Official Journal of The European Union.

Find a copy of this list, along with updated lists for the R&TTE Directive 1999/5/EC, Low Voltage Directive 2006/95/EC, Medical Device Directive 93/42/EEC, and ERC Recommendation 70-03 relating to the use of Short Range Devices, at http://www.celectronics.com/europe.htm

Harmonized Standards List Updated 3/2010 – EMCD & LVD

New lists of harmonized standards for the EMC Directive and the Low Voltage Directive have been published in the Official Journal of the European Union.
Of note, this revision now includes inline explanatory comments. Brief explanations have been added to certain line items, line items that could prove to be confusing without them, an example of one is for EN 55022, which reads;

" Each of the four following standards provide presumption of conformity until 1.10.2011: EN 55022:1998, EN 55022:1998 + A1:2000, EN 55022:1998 + A2:2003, EN 55022:1998 + A1:2000 + A2:2003"

It's refreshing to see that these clarifications are being added. This will hopefully make interpreting which harmonized standards are applicable much easier, for the average compliance engineer. Although, nothing is ever perfect and one should contact an expert if in doubt.
By the way, for those of you reading this on the West side of the "Pond", the date in the above quote is October 1st, 2011 and not January 10th, 2011.
Copies of the new lists can be found  in the European Conformity Assessment section of the Compatible Electronics, Inc. conformity assessment web page.

IECEE Battery Ruling

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An issue was brought to the attention of the IECEE regarding CB Certificates for products containing secondary cells (Lithium Ion Battery cells) that are certified to UL 1642 as well as Secondary Battery Packs certified to UL 2054.
These UL standards are not harmonized with the IEC 62133 – “Secondary Cells And Batteries Containing Alkaline Or Other Non- Acid Electrolytes - Safety Requirements For Portable Sealed Secondary Cells, And For Batteries Made From Them, For Use In Portable Applications.”
After deliberation the IECEE issued a ruling indication that a CB Certificate could not be issued for products containing secondary cells that were not in compliance with IEC 62133. However as most secondary cells are currently certified only to UL standards, a phase in period was established.
At the time of this writing, the phase in time table is as follows;
Currently

• CB Certificates can stand as issued. Note that CB Certificates need to be renewed every 3 years.

New certificates, Until June 2010

• CB Certificates can continue to be issued using the UL standards for secondary cell certification.

New certificates, June 2010 thru June 2011

• CB Certificates can be issued using the UL standards for secondary cell certification, if additional testing is conducted on the secondary cells to show compliance to IEC 62133.

After June 2011

• Secondary cells must have a CB Certificate showing compliance with IEC 62133 to be accepted in an end product evaluation for CB Certification.

There is a good possibility that this time table will be adjusted to allow battery manufacturers time to get secondary cells tested and CB Certification issued.
UL has indicated that they will start the process to harmonize there requirements with IEC 62133.

What does this mean to you and me?
The real effect on most of us is that we will need to move to have our battery suppliers get third party certification on the secondary cells we are using. Otherwise we cannot self certify to the Harmonized EN Standard (EN60950-1, EN61010-1, EN60335-1, EN60065, EN60204-1, etc.) and it will become increasingly difficult to get our products NRTL Listed.

Article by Ercell Bryant, please visit Compatible Electronics on the web.

VCCI 1 year grace period for 1 GHz+ testing

The VCCI Council posted a notice on its web site at http://www.vcci.jp/vcci_e/topics/new091211.html detailing the planed implementation of the 1 GHz+ radiated emissions requirements. These requirements are based on CISPR22 Edition 5.

While the VCCI Council will begin enforcement of the new requirements on October 1, 2010, manufacturers will have the option of applying the old requirements until September 2011. The VCCI Council requests however that manufactures proceed with conformity to the new requirements on the original 2010 deadline date.

The VCCI Council gives justification for its decision based on the publication, August 21, 2009, in the Official Journal of the European Union, that extended the date of withdrawal of EN55022:1998 until September 30, 2011. EN55022:1998 is based on CISPR22 Edition 3, and does not contain requirements for testing above 1 GHz.

It is interesting to note that for product sold in the United States, testing above 1 GHz has been required for many years. In fact, Part 15.33 calls out that unintentional radiators can be required to be tested up to as high as 40 GHz.

What has been a major point of contention for some, is that no agreed method for site validation has been published for above 1 GHz for FCC testing. That being said, no significant reports of interference above 1 GHz from properly tested unintentional radiators have made the headlines either.

EN 55012:2007

As of 9/1/2010, the following specification replaces any previous version.

EN 55012:2007
Vehicles, boats and internal combustion engines — Radio disturbance characteristics
— Limits and methods of measurement for the protection of off-board
receivers
(CISPR 12:2007)

R&TTE Directive 1999/5/EC HS Corrigendum

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A new and amended list of Harmonized Standards for the Radio and Telecommunications Terminal Equipment Directive, replacing the one issued 12/2/09, has been publish in the official journal of the European Union.

Please visit http://celectronics.com/pdf/OJlistRTTE121509.pdf for a copy of the OJ list.

R&TTE updated list of harmonized standards

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A new list of harmonized standards for the Radio and Telephone Terminal Equipment directive (R&TTE) has been published in the official journal.

Get a copy of the list here.

Visit our European Conformity Assessment page for this and other lists of harmonized standards updated regularly.

This information can be found at the EUR-Lex web site providing access to European Union law.

ISN for ITE telecom line testing

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On November 11^th, 2009, the VCCI Council of Japan issued notice describing the restrictions on the use of Impedance Stabilization Network (ISN) to be used for the measurement of telecommunication ports conducted EMI. Although this information is published in the current CISPR standard, the VCCI Council will only begin to deal with the filing of reports on telecommunication port conducted emission from April 2010. Currently, a great deal of confusion abounds on the proper selection of the ISN for telecom measurements. This notice helps to clear up some of that confusion.

As implied, the document describes the acceptable types of ISN, suitable for the measurement of telecom line conducted EMI. Most notably, the document comes with warning notes about using certain types of ISNs with certain quantity of balanced pairs. Get a copy of the notice.