Government Shutdown impact on FCC certifications

Closed Sign in Yellowstone (Photo credit: bmills)

Preparations are being made at the FCC for the potential of yet another imminent Federal government shutdown if a funding bill agreement can’t be reached by Sept. 30th.

The FCC has indicated that in the unlikely event of a government shutdown, that access to all FCC systems will be suspended.

The Equipment Authorization system, used by the FCC and Telecommunication Certification Bodies (TCB) to process certifications and issue grants of equipment authorizations will be among such systems to go off line, thus having the potential to delay or halt pending product certifications and preventing manufacturers from marketing and selling affected product.

New FCC ID format could make searching IDs difficult

Starting tomorrow, May 1^st, 2013, the FCC will begin issuing new grantee codes as five character codes. Existing 3 character codes will still be valid, but new codes as of tomorrow will be in the 5 character format.  An earlier post describes why the change to the 5 character system. See FCC running out of Grantee codes.

Now that grantee codes could be both 3 character and 5 character, for those who use the Equipment Authorization Database search to lookup FCC IDs, it could be difficult at first getting use to the new system. How do you know if it’s a 3 character code or a 5 character code just by looking at the ID?

Example;

FCC ID: 2AA567SAMPL

FCC ID: G777SAMPLE500

Here’s a tip.

3 or 5 character grantee code? To tell;

1. if it starts with a number, it’s a 5 character code

2. if it starts with a letter, it’s a 3 character code.

The use of 1 and 0 is excluded, to avoid confusion with the letters i and o.

I don’t know if this visual would work the same for you, but what I do is picture a telephone keypad, it kind of looks like a # symbol with the number 5 in the middle;

 

 

# = Number so 5 starts with number. Silly, but it works for me.

So for the example above; 2AA56 is the 5 character code (starts with a #) and G77 is the 3 character code (starts with a letter).

REF:

Released: 04/09/2013. OFFICE OF ENGINEERING AND TECHNOLOGY TO BEGIN ISSUING FIVE-CHARACTER GRANTEE CODES FOR CERTIFIED RADIOFREQUENCY EQUIPMENT. (DA No. 13-669)

http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-13-669A1.pdf

Domestic Unlicensed Modular Radio Approval

Transmitter (Photo credit: Thorius)

What is a modular approval, how does one qualify for one, and what are some of the advantages and disadvantages in selecting to pursue a modular radio approval. I’ve addressed these questions in summary form here, and I provide some links for further reading.

A modular approval allows the approved product to be installed in different host devices, without the need for additional testing or authorization for the transmitter for each host system. Note that the host itself may still require authorization or reauthorization depending on the host, but the transmitter would not need to be recertified for each host.

There are 4 types of modular approvals;

1. Single-Modular transmitter

2. Limited Single-Modular transmitter

3. Split-Modular transmitter

4. Limited Split-Modular transmitter

A single-modular device is a device in a single package, and a split-modular is one where the radio front end and the control elements section may be separate.

The use of the word “Limited” indicates that the device may have certain grant conditions or be reliant on a specific host configuration for compliance. Integrators are cautioned to pay close attention to these limitations.

To qualify for modular approval, the device must comply with 8 specific conditions. For a Single-modular transmitter, the device is a self contained, physically delineated component that can demonstrate compliance independent of the host.

1. Radio circuitry must be shielded

2. Modulation / data inputs must be buffered.

3. Power supply regulation on the module

4. Permanent antenna or unique connector

5. Must demonstrate compliance stand alone (outside host)

6. Labeled with its own permanently fix FCC ID, or have electronic display capability

7. Must comply with applicable rules, and with grantee provided conditions

8. Must comply with applicable RF exposure requirements

A limited modular approval may be granted when a device does not meet all 8 of the conditions, but may rely on a specific host and applicable operating conditions for compliance. For instance, the shielding, buffered I/O or power regulation may be provided by a specific host. In these cases the module would be “Limited” to the specific host providing those requirements.

The first and probably most obvious benefit to a modular approval is that the radio module would not need to be recertified for every host installation, thus saving time and money when incorporating radio functions into multiple host devices. Other advantages may include;

· Changes to the host don’t affect the radio certification (except on “Limited modular”)

· Time to market for a new host is considerably less if the product does not require certification

· Ease of managing the radio certification, one FCC ID instead of many.

· Flexibility with installation within the host (except maybe on “Limited modular”)

· If the module is the product, it’s more attractive for an integrator to use a pre-certified device.

· The radio may be “End-User” replaceable (potential upgrade or repair)

Some items that may be negative points to a modular approval;

· Radio generally more expensive due to shielding, buffered i/o and power regulation

· Depending on host/antenna placement, transmitter power may be less than non-module type

· Integrating multiple transmitters (co-location) within a single host can be problematic

Things to pay attention to when using an already approved module;

· Be aware of the type of module and grant conditions or restrictions

· The term “Modular approval” is specific, if unsure check the FCC ID and look at the grant

· Follow all installation instructions and warnings provided by the grantee

Other things to possibly consider are RF exposure and/or hearing-aid compatibility, for devices with specific antennas, or specific host/enclosure configurations. The FCC has published a “Transmitter Module Equipment Authorization Guide”, KDB 996369, and I recommend reading through the guide if considering the modular approach.

To check a prospective module’s FCC approval, have the FCC ID ready and visit;

https://apps.fcc.gov/oetcf/eas/reports/GenericSearch.cfm

Keep in mind, the first 3 characters of the FCC ID are the Grantee Code, and note that the numbers 1 or 0 will never be part of the grantee code (to avoid confusion with the letters i and o). The grant will clearly indicate “Modular Approval” or “Limited Modular Approval” (LMA) if the device is so approved. At the time of writing this article, the FCC system only searches based on the legacy system of 3 digit grantee codes, however, the FCC is moving to a 5 digit grantee code system real soon – see http://www.emcrules.com/2012/06/fcc-running-out-of-grantee-codes.html

Compliance testing and certification costs of a Single-Modular transmitter are comparative to that of a non-modular approval of the same radio in most cases, in some cases it could be less expensive due to the simplified test setup and configuration of the module. Time and cost of Limited-Modular devices can vary depending on the host.

Of course this all applies to domestic FCC certification, but what about other regions?

Canada has a very similar approach to radio modules, see RSS-Gen, section 3.2.2 for details. In Europe, there is no “Modular Approval” process as the system is based on self-certification, but a somewhat similar approach can be taken, please see my article “Radio module integration and R&TTE compliance” for dealing with radio modules under the R&TTE Directive.

FCC running out of Grantee codes

(Image credit: Getty Images via @daylife)

The availability of new FCC issued grantee codes is critically low, and the FCC will soon run out. Today the Commission voted to expand the code from 3, to 5 digits by amending Sections 2.925 and 2.926.

Each product certified to the FCC rules must carry an FCC ID, as an example look on the back of your electronic device for “FCC ID:xxx1234”. This identifier consists of a grantee code making up the first 3 digits, and an applicant assigned unique product code composed of from 1 to 14 additional alpha-numeric characters, dashes or hyphens.

Each entity seeking to obtain a grant of equipment authorization from the FCC, must first obtain the unique grantee code assigned by the FCC. This three digit format uses alpha numeric characters, excluding 0 and 1 in a way that would provide for over 30,000 unique combinations.

This FCC identifier system was introduced in 1979. In 1999, 440 grantee codes had been issued that year. In 2001, 635 grantee codes were issued, and in 2011 the number had increased to 1275 unique grantee codes issued per year.

Given the rate of grantee code issuance, the FCC will soon run out of unique codes. To extend this deadline, the FCC had been recycling old unused grantee codes, however this was only a temporary solution. Today the Commission approved a vote to extend the code to 5 digits. This will provide approximately 8,000,000 unique combinations.

Entities that currently have a 3 digit grantee code may keep the code, but new applicants will be assigned the new 5 digit grantee code approximately 30 - 60 days from the order’s publication in the federal register.

Ref:
Open Commission Meeting June 13, 2012