FCC requirements to protect the nation’s networks and supply chains from certain equipment

August 28, 2024 - FCC publishes a revision to Knowledge Database (KDB) document titled “Protecting Against National Security Threats to the Communications Supply Chain through the Equipment Authorization Program.” The document provides staff-level authorization guidance on how FCC 22-84 affects the equipment authorization process.

Changes include adding new guidance item 2a, “How should TCBs address applications for authorization of equipment that includes cybersecurity and anti-virus software produced or provided by Kaspersky Lab, Inc. or any of its successors and assignees?” as well as removing obsolete data from the introduction, and adding clarifying language to item 1.a.ii.

Ref:

KDB 986446 D01 Covered Equipment Guidance v03

FCC Amends Equipment Authorization Program

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

FCC policy and procedure updates, it’s a big one

Logo of the United States Federal Communications Commission, used on their website and some publications since the early 2000s. (Photo credit: Wikipedia)

The Knowledge Database section of the Office of Engineering and Technology (OET) web site has a significant number of new publications today. The new updates impact technical requirements such as software defined radios, RF safety and Digital Transmission Systems (DTS) measurement procedures. Other updates cover administrative issues as well as  guidance and policy for Telecommunication Certification Bodies.

While the FCC continually updates these policies and procedures as needed, we tend to see the most significant changes going into the spring and fall seasons. Part of the reason for this is the TCB council holds regular training workshops in the spring and fall. The FCC is generally in attendance, and uses the opportunity to update the community on policy matters and technical issues. The training workshops become sort of a deadline for publication in this way. We also see a number of updates just following the training workshops as questions and comments begin to hit the FCC.

You can visit the OET KDB site at https://apps.fcc.gov/oetcf/kdb/index.cfm. Below is a categorized summary with excerpts of the updates for your convenience. If these issues are important to you, I suggest regular checks of the FCC KDB publications to stay current with the rules.

1. Administrative

a. Permissive Change Policy

i. 10/24/2012: D01 Permissive Change Policy v05r02 has been changed to 178919 D01 Permissive Change Policy v05r03 to allow TCBs to approve third party software upgrades as PBA. Permissive changes and RF exposure considerations has been changed to reference the published RF exposure KDB procedures.

b. Permit But Ask List

i. 10/24/2012: 388624 D02 Permit But Ask List v11 replaces 388624 D02 Permit But Ask List v10 Several changes have been made to the document to clarify the types of devices subject to the PBA review process.

c. Software Defined Radio Application Guide

i. 10/24/2012 442812 D01 SDR Apps Guide v02 has been changed to 442812 D01 SDR Apps Guide v02r01. Removed the requirement for non-SDR to file a Class II permissive change directly with the Commission.

d. TCB Exclusion List

i. 10/25/2011 628591 D01 TCB Exclusion List v12r02 replaces 628591 D01 TCB Exclusion List v12r01. Removed Access Broadband over Power Line (BPL) devices (Part 15 Subpart G);

ii. 10/24/2012 D01 TCB Exclusion List v13 replaces 628591 D01 TCB Exclusion List v12r02. Clarified requirements for devices subject to RF Exposure requirements; removed non-SDR Class II permissive change applications for certain types of devices.

e. SAR Listings on Equipment Authorization Grants

i. 10/24/2012: 690783 D01 SAR Listings on Grants v01r01 has been changed to 690783 D01 SAR Listings on Grants v01r02 to reflect changes made to RF exposure guidance.

2. Technical

a. Mobile and Portable Devices RF Exposure Procedures and Equipment Authorization Policies

i. 10/24/2012: 447498 D01 General RF Exposure Guidance v04 has been changed to 447498 D01 General RF Exposure Guidance v05. The new version (v05) is a major revision to version 04.

b. Guidance for Performing Compliance Measurements on Digital Transmission Systems (DTS) Operating Under §15.247

i. 10/04/2012: 558074 D01 DTS Meas Guidance v01 has been changed to 558074 D01 DTS Meas Guidance v02. V02 is a major change to the v01 guidance with additional measurement options.

c. Restrictions on Software Configuration for devices not approved as Software Defined Radios

i. 10/24/2012 Publication: 594280 D01 Software Configuration Control v01r01 has been changed to 594280 D01 Software Configuration Control v01r02 Removed for Non SDR the requirement to file a Class II permissive change directly with the Commission.

d. SAR Evaluation Considerations for Laptop, Notebook, Netbook and Tablet Computers

i. 10/24/2012: 16217 D04 SAR for laptop and tablets v01 replaced previous guidance:616217 D01 SAR for Laptop with Screen Ant v01r01, 616217 D02 SAR Policy Laptop with Screen Ant v01r01and 16217 D03 SAR Supp Note and Netbook Laptop v01

e. SAR Evaluation Considerations for Wireless Handsets

i. 10/24/2012: 6648474 D04 SAR Handsets Multi Xmiter and Ant v01 replaces 48474 D01 SAR Handsets Multi Xmiter and Ant v01r05 and 648474 D02 SAR Polcy Handsts Multi Xmiter Ant v01r01

f. Emissions Testing of Transmitters with Multiple Outputs in the Same Band (e.g., MIMO, Smart Antenna, etc)

i. 10/25/2011: 662911 D01 Multiple Transmitter Output v01 changed to 662911 D01 Multiple Transmitter Output v01r01 to add references to new attachment 662911 D02 in the second paragraph of the document and in the INTRODUCTION section. The referenced attachment identifies an exception to the requirement for summing emissions across outputs in certain cases involving devices that drive cross-polarized antennas and identifies the need to sum radiated emissions across polarizations in certain other cases.

g. MIMO with Cross-Polarized Antenna

i. NEW POLICY AND PROCEDURE

h. Guidelines for Compliance Testing of Unlicensed National Information Infrastructure (U-NII) Devices Part 15, Subpart E

i. Too many to list, see KDB

i. SAR Evaluation Considerations for LTE Devices

i. 10/24/2012 941225 D05 SAR for LTE Devices v02 replaces 941225 D05 SAR for LTE Devices v01. Version v02 represents a major revision to version v01.

REF:

Office of Engineering and Technology Laboratory Division Knowledge Database (KDB)