FCC vs RED: Comparing US and EU Equipment Authorization

FCC vs RED
Carlo Casati
Milan, 30 June 2017

US Legal System
30.06.20172 WORKSHOP UN MONDO SENZA FILI: RED & FCC

Aquis
30.06.2017 WORKSHOP UN MONDO SENZA FILI: RED & FCC3
U.S. Code (Common Law)
(U.S. Congress)
UE Treaty - Constitution
(EU Members)
Code of Federal Regulations
(Federal Agencies)
Community Acquis
(European Council and
Parliament)
State Laws
(Local governments)
National Codes
(EU Member Governments)
Sentences on similar cases
(Great importance)
Sentences on similar cases
(Minor importance)

02.12.2016 NEMKO ITALY CUSTOMER SEMINAR4
• USC = Code of the United
States of America (U.S. Code)
• CFR = Code of Federal
Regulations
• Title
• Volume
• Chapter
• Part
• Subpart
• Section
15 USC 1452 = U.S. Code Title 15 Section 1452
(Chapter 39)
47 CFR 15 Subpart C = Code of Federal Regulations
Title 47 Part 15 Subpart C (from section 15.201 to
15.257)

02.12.2016 RED SALES TRAINING5
Fair packaging and Labelling Program
15 U.S. Code § 1452 - Unfair and deceptive packaging and
labeling; scope of prohibition
(a) Nonconforming labels
It shall be unlawful for any person engaged in the packaging
or labeling of any consumer commodity for distribution in
commerce, or for any person engaged in the distribution in
commerce of any packaged or labeled consumer commodity,
to distribute or to cause to be distributed in commerce any
such commodity if such commodity is contained in a package,
or if there is affixed to that commodity a label, which does not
conform to the provisions of this chapter and of regulations
promulgated under the authority of this chapter.
Labels are construed as claims; therefore everything on the
label must be able to be substantiated.
Claiming conformity to or compliance with a standard, code or
regulation must be substantiated.

Equipment Authorization

Determine FCC Rules that Apply
• Determine if device is a Radio Frequency
(RF) device subject to the FCC rules.
• Determine all applicable technical and
administrative rules that apply to the device
requiring an equipment authorization.
• The technical requirements are generally
specified in the applicable FCC rule parts
and the administrative rules are specified in
Part 2, Subpart J.
Requirement RED FCC
Safety - OSHA (NRTL)
EMC
Radio

Identical defined (Part 2 Subpart J Sect 2.908)
• As used in this subpart, the term
identical means identical within
the variation that can be expected
to arise as a result of quantity
production techniques.
• No extensions by
technical
documentation is
permitted under
FCC regulations

Equipment Authorization Procedures
• If a device is subject to FCC rules, determine the
specific type of equipment authorization that applies
to the device. Become familiar with all the basic
marketing, equipment authorization, and importation
rules. In some instances, a device may have different
functions resulting in the device being subject to
more than one type of approval procedure.
Certification
(by Certification Bodies) EU Declaration of
Conformity
(for some products it has to
be substantiated by Notified
Bodies)
CE certification
Declaration of Conformity
(by Manufacturer)
Verification
(Label data must be
substantiated)

• Certification is the most rigorous approval process for RF Devices with the
greatest potential to cause harmful interference. It is an equipment
authorization issued by a recognized TCB (Telecommunication Certification
Body) based on an application and test data submitted by the responsible
party (e.g., the manufacturer or importer). The testing is done by an
accredited testing laboratory recognized by the Commission as approved
for performing such work. A TCB examines the test data and supporting
documentation to determine whether the testing followed appropriate
protocols and the data demonstrates technical and operational compliance
with all pertinent rules. Technical parameters and other descriptive information
for all certified equipment submitted in an application for Certification are
published in a Commission-maintained public database.
• Examples of devices subject to certification include, but are not limited to,
mobile phones; wireless local area networking equipment, remote control
transmitters; land mobile radio transmitters; wireless medical telemetry
transmitters; cordless telephones; and walkie-talkies
CERTIFICATION (47 CFR Section 2.907)

• Declaration of Conformity (DoC) is a procedure that requires the party
responsible for compliance to use an accredited testing laboratory that
follows established measurement protocols to ensure that the equipment
complies with the appropriate technical standards. The responsible party is
not required to file an equipment authorization application with the
Commission or a TCB, and equipment authorized under the DoC procedure is
not listed in any Commission database. However, the responsible party must
provide a test report and other information demonstrating compliance with the
rules upon request by the Commission.
• Examples of devices subject to a DoC include personal computers and
peripherals, consumer ISM equipment such as microwave ovens and RF light
bulbs, radio receivers and TV interface devices.
Declaration of Conformity (47 CFR 2.906)

• Verification is a procedure that requires the party responsible for compliance
to rely on measurements that it or another party makes on its behalf to ensure
that the equipment complies with the appropriate technical standards. The
responsible party is not required to use an accredited testing laboratory. It is
not required to file an application with a TCB, and equipment authorized
under the verification procedure is not listed in any Commission database.
However, the responsible party must provide a test report and other
information demonstrating compliance with the rules upon request by the
Commission.
• Examples of devices subject to verification include non-consumer ISM
equipment; TV and FM receivers; and business computer equipment. Devices
subject to verification must be uniquely identified in a format which cannot be
confused with the FCC identifier required on certified equipment.
VERIFICATION (47 CFR Section 2.902)

Compliance Testing
• Declaration of Conformity: Equipment approved
using the DoC procedure is required to be tested
by an FCC Recognized Accredited Testing
Laboratory. The Commission maintains a list of
the FCC Recognized Accredited Testing
Laboratories.
• Certification: Equipment approved under the
Certification procedure is required to be tested by
an FCC Recognized Testing Laboratory as
follows:
• Prior to July 13, 2017, either a Section 2.948 Listed
Laboratory or an FCC Recognized Accredited Testing
Laboratory.
• After July 13, 2017, all types of equipment approved
under the Certification procedure are required to be
tested by an FCC Recognized Accredited Testing
Laboratory.

Approval
• Verification
• The responsible party, as specified in the
rules, warrants that each unit of equipment
complies with the applicable FCC rules.
• The responsible party maintains all of the
required documentation demonstrating
compliance with the applicable FCC rules.
• Declaration of Conformity
• The responsible party prepares a compliance
information statement to be supplied with the
product at the time of marketing.
• The responsible party maintains all of the
required documentation demonstrating
compliance with the applicable FCC rules.

The responsible party, typically the manufacturer, obtains an FCC Registration
Number (FRN) for a device requiring Certification. The FRN is a 10-digit number
used to identify the individual or organization doing business with the FCC. The
same FRN will be used for future approvals.
After obtaining an FRN, the responsible party obtains a Grantee Code from the
Commission by applying at the Grantee Registration website. A grantee code is
required the first time a party applies for certification, and can be used for all future
approvals.
The responsible party files with a Telecommunication Certification Body (TCB) an
application for a grant of certification. An application for equipment authorization
requires submission of information about the product, as listed in Section 2.1033.
The applicant must submit the required information to a TCB for review as part of
the certification process.
The TCB assess all of the information and evaluation results to determine if the
product complies with the FCC requirements.
Once the TCB makes a decision to certify the product the supporting information is
uploaded to the FCC Equipment Authorization Electronic Filing System (EAS)
A grant of certification is issued by the TCB on the FCC EAS.
Certification

FCC CE
Grantee Code (Company Registration)
FCC Registration Number (Device Registration)
TCB Application NB Application
TCB Grant EU Type Certificate
FCC Equipment Electronic Filing System
(public)
EU Member Database
(Private)
FCC-ID Number on device

Multiple Authorization Procedures
• A device subject to multiple authorization
procedures requires appropriate testing
and labelling for each of the respective
authorization procedures. As a general rule,
the DoC text statement supersedes any
Verification statement. For devices subject
to DoC and Verification, or Certification and
Verification, the labelling requirements for
DoC or Certification need only apply. When
a device is authorized under both the DoC
and Certification procedures, the DoC logo
and FCC ID (or FCC IDs if applicable) are
required.

Certified transmitter modules (CTM) are distinctive assemblies containing a transmitter
that can be installed inside a host device (i.e. computer, wireless security controller, etc.)
These devices can be sold by a manufacturer (responsible party) to other equipment
manufacturers or used in the original manufacturer’s products. When a certified modular
is used inside a host, the host equipment can take advantage of the certification already
granted to the module. This may reduce some of the tests for the host, compared to
using a transmitter that has not been previously certified. The host containing a certified
modular (for example a laptop with WiFi) may only require testing for DoC or
Certification as a Class B computer, and possibly a subset of additional tests associated
with the transmitter. The alternative, using a non-certified transmitter, requires DoC or
Certification as a Class B computer, and in addition full certification of the transmitter.
Any additional testing, conditions of use and limitations associated with the certified
module must be provided in the module instruction manual by the manufacturer of the
module, to the Other Equipment Manufacturer (OEM) marketing the host.
A certified modular has the option to use a permanently affixed label, or an electronic
label. All modules without an integrated display on the module must be labelled with a
module’s FCC ID - Section 2.926. The module’s OEM manual must provide clear
instructions explaining to the host integrator the labelling requirements, options and
OEM user manual instructions that are required (see next paragraph).
Certified Transmitter Modules

Requirements FCC RED
Safety No requirements Device Safety + Module Safety
EMC FCC Part 15 Subpart B Relevant ETSI EN Standard
Radio No Tests
Subset Additional Tests
No Tests (only for RED modules)
Subset Additional Tests
Former «Delta Type» Approval
Labelling All FCC-ID CE

Intentional Radiators

a) Intentional radiators operated as carrier current systems,
devices operated under the provisions of §15.211,
15.213, and 15.221, and devices operating below 490
kHz in which all emissions are at least 40 dB below the
limits in 15.209 shall be verified pursuant to the
procedures in Subpart J of part 2 of this chapter prior to
marketing.
b) Except as otherwise exempted in paragraph c) of this
section and in 15.23 of this part, all intentional radiators
operating under the provisions of this part shall be
certificated by the Commission pursuant to the
procedures in subpart J of part 2 of this chapter prior to
marketing.
47 CFR Part 2 Subpart C

15.217 Operation in the band 160-190 kHz
15.223 Operation in the band 1.705-10 MHz
15.225 Operation within the band 13.110-
14.010 MHz
15.227 Operation within the band 26.96-27.28
MHz
MHz
15.231 Periodic operation in the band 40.66-
40.70 MHz and above 70 MHz
15.233 Operation within the bands 43.71-44.49
MHz, 46.60-46.98 MHz, 48.75-49.51 MHz
and 49.66-50.0 MHz
MHz
15.237 Operation in the bands 72.0-73.0 MHz,
74.6-74.8 MHz and 75.2-76.0 MHz
15.239 Operation in the band 88-108 MHz
15.240 Operation in the band 433.5-434.5 MHz
47 CFR Part 2 Subpart C
15.242 Operation in the bands 174-216 MHz and
470-668 MHz
15.245 Operation within the bands 902-928 MHz,
2435-2465 MHz, 5785-5815 MHz, 10500-
10550 MHz, and 24075-24175 MHz
2400-2483.5 MHz, and 5725-5850 MHz
2400-2483.5 MHz, 5725-5875 MHZ, and 24.0-
24.25 GHz
15.250 Operation of wideband systems within the
band 5925-7250 MHz
15.251 Operation within the bands 2.9-3.26 GHz,
3.267-3.332 GHz, 3.339-3.3458 GHz, and
3.358-3.6 GHz
15.252 Operation of wideband vehicular radar
systems within the bands 16.2-17.7 GHz and
23.12-29.0 GHz
15.253 Operation within the bands 46.7-46.9 GHz
and 76.0-77.0 GHz
15.255 Operation within the band 57-64 GHz
15.257 Operation within the band 92-95 GHz

Mobile and Portable Devices
Safety Requirements
> 20 cm from the user body
Mobile
No SAR requirements
< 20 cm from the user body
Portable
SAR requirements

A. Determine if device requires authorization under Verification;
Declaration of Conformity (DoC) or Certification.
B. Test measurements of equipment regulated under Parts 15 and 18
are required for authorization to import/market in the U.S.
C. Obtain an FCC Registration Number for a device requiring
Certification (either through the FCC or a TCB).
D. For a device requiring Certification (either through the FCC or a TCB)
and if an Applicant/Grantee Code has not been previously assigned,
obtain a Code from Applicant/Grantee Code ’.
E. For a device requiring Certification through the FCC submit an
Application for Equipment Authorization, FCC Form 731.
F. For a device requiring certification through a TCB contact a
Telecommunications Certification Body.
Application for Equipment Authorization

• An FRN, or FCC registration number, is a 10-digit number
that is assigned to a business or individual registering with
the FCC. This unique FRN is used to identify the
registrant’s business dealings with the FCC. The FCC will
use the FRN to determine if all of a registrant's fees have
been paid.
• Each individual or organization doing business with the
FCC is required to provide and maintain a current official
contact address.
• A filer, licensee, certificate holder, or any entity sending
payments to the FCC is considered to be doing business
with the FCC and must therefore have an FRN
FCC Registration Number

• RF, EMC and Safety reports as appropriate
• Block Diagram
• Schematic Diagrams
• Photographs showing the external and internal
construction of the product
• User Manual
• Operating Description
• Power of Attorney
• In country representative details
(required for some countries)
TCB Documentation Requirements

Type Information Example
FCC ID Equipment displaying this label should be
in FCC database
XXXABC123
FCC DoC
Declaration of
Conformity
Equipment displaying this label would not
be in FCC database. The FCC would not
have any record of this equipment. It is
declared to comply with FCC regulations
by the manufacturer or importer.
FCC Reg. #
Registration
Number
Equipment displaying this label would only
be in FCC database if it also has an FCC
ID: label. (e.g. older modems) The FCC
Registration Number itself would never
appear in this database.
FCC ID XZZYYNNNNN
Grantee Code if (X is
Numeric) Grantee code is
XZZYY else XZZ
Equipment Product
Code NNNNN
Labels

29
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Via del Carroccio, 4 - 20853 Biassono (MB)
Tel.: +39 039.220.1201 Fax.: +39 039.2201221
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