MultiPoint - Rhein Tech Laboratories, Inc.
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1. addition to the requirements in part 2 of this chapter a device subject to certification or verification shall be labelled as follows 1 Receivers associated with the operation of a licensed radio service e g FM broadcast under part 73 of this chapter land mobile operation under part 90 etc shall bear the following statement in a conspicuous location on the device This device complies with part 15 of the FCC Rules Operation is subject to the condition that this device does not cause harmful interference R amp TTE Questions SS dg a E QUESTI ON Is it permissible within the scope of the R amp TTE Directive Annex Il for a manufacturer to apply only certain parts within a given harmonized standard s if the manufacturer can provide justification for doing so without the aid of an official opinion from a Notified Body NB or must a harmonized standard be applied in its entirely in order for a manufacturer to apply Annex II Self Declaration As an example a harmonized standard provides test suites for both receiving and transmitting apparatus The equipment under test and assessment is intended only for transmission and does not incorporate reception circuitry For such a case can the manufacturer apply the test suites that are relevant only to transmitters supplemented with an exemption statement on the DoC without the requirement to engage an opinion from a Notified Body If a manufacturer and his authorized representative ar2. measurements EN 60079 10 1 2009 3 26 2009 Explosive atmospheres Part 10 1 Classification of areas Explosive gas atmospheres See CENELEC for additional information EU NEW IEC STANDARDS RECENTLY RELEASED This is a shortened list of the new IEC standards published during the past month IEC PAS 61169 18 3 5 2009 Radio frequency connectors Part 18 Sectional specification Radio frequency coaxial connectors of type SSMA IEC PAS 61169 19 3 5 2009 Radio frequency connectors Part 19 Sectional specification for SSMB series R F coaxial connectors IEC PAS 61169 35 3 5 2009 Radio frequency connectors Part 35 Sectional specification Radio frequency coaxial connectors of type 2 92 CISPR 12 3 10 2009 Vehicles boats and internal combustion engines Radio disturbance characteristics Limits and methods of measurement for the protection of off board receivers IEC 62003 3 10 2009 Nuclear power plants Instrumentation and control important to safety Requirements for electromagnetic compatibility testing 1SO LEC 24729 4 3 11 2009 Information technology Radio frequency identification for item management Implementation guidelines Part 4 Tag data security 1SO IEC CASCO CONF 2 3 20 2009 Conformity assessment Laboratories and inspection bodies IEC 60943 3 24 2009 Guidance concerning the permissible temperature rise for parts of electrical equipment in particular for terminals IEC 60601 2 50 3 24 2
3. transmitter whose digital circuitry function is only used to make the transmitter section function as intended is not a FCC Part 15 device Ges Part 15 3 k Part 15 states receivers are authorized based on their use etc As an example a Part 15 receiver used in a licensed transceiver is always verified whereas stand alone receivers for the same type transmitter would Certification or Declaration of Conformity DoC If the receiver operates below 960 MHz then FCC Part 15B Verification is appropriate for the receiver portion whereas scanning receivers are certified devices The digital portion of the device would require FCC Part 15B as well assuming it has a clock and microprocessor See ECC Part 15 101 for Equipment Authorization of unintentional radiators In summary one must look at a device and divide it into all applicable sections The transmitter section falls under FCC Part 27 if the receiver section falls between 30 960 MHz then FCC Part 15 for the receiver section is applicable If the device also contains digital device circuitry or personal computer peripheral interface etc then FCC Part 15 B also applies The definition of receivers under FCC Part 15 does not distinguish between being unlicensed and licensed device To know how and when Part 15 does apply in transceiver devices the labeling of licensed or unlicensed devices under FCC Part 15 19 should be considered FCC Part 15 19 a 1 states the following a In
4. 009 Medical electrical equipment Part 2 50 Particular requirements for the basic safety and essential performance of infant phototherapy equipment See for additional information EU NEW ETSI STANDARDS RELEASED THIS MONTH This is a shortened list of the new ETSI standards published during the past month e ETSI_EN 302 544 1 V1 1 1 February 2009 Broadband Data Transmission Systems operating in the 2 500 MHz to 2 690 MHz frequency band Part 1 TDD Base Stations Harmonized EN covering the essential requirements of article 3 2 of the R amp TTE Directive March 2009 Electromagnetic compatibility and Radio spectrum Matters ERM RFID Plugtests to investigate the interoperability of tags manufactured by different vendors Part 2 Test plan and preliminary tests March 2009 Human Factors HF Guidelines for ICT products and services Design for All ETSI EN 300 440 1 V1 5 1 March 2009 Electromagnetic compatibility and Radio spectrum Matters ERM Short range devices Radio equipment to be used in the 1 GHz to 40 GHz frequency range Part 1 Technical characteristics and test methods March 2009 Electromagnetic compatibility and Radio spectrum Matters ERM Short range devices Radio equipment to be used in the 1 GHz to 40 GHz frequency range Part 2 Harmonized EN covering essential requirements of article 3 2 of the R amp TTE Directive See new ETSI websitd for additional information FCC NEW RULES FOR WIRELESS MEDICAL DEVI CES On
5. 1558 1 2005 A1 2009 3 12 2009 Safety of power transformers power supplies reactors and similar products Part 1 General requirements and tests EN 62369 1 2009 3 13 2009 Evaluation of human exposure to electromagnetic fields from short range devices SRDs in various applications over the frequency range 0 GHz to 300 GHz Part 1 Fields produced by devices used for electronic article surveillance radio frequency identification and similar systems EN 60974 8 2009 3 18 2009 Arc welding equipment Part 8 Gas consoles for welding and plasma cutting systems EN 61557 9 2009 3 18 2009 Electrical safety in low voltage distribution systems up to 1 000 V a c and 1 500 V d c Equipment for testing measuring or monitoring of protective measures Part 9 Equipment for insulation fault location in IT systems EN 61557 11 2009 3 18 2009 Electrical safety in low voltage distribution systems up to 1 000 V a c and 1 500 V d c Equipment for testing measuring or monitoring of protective measures Part 11 Effectiveness of residual current monitors RCMs type A and type B in TT TN and IT systems EN 55015 2006 A2 2009 3 25 2009 Limits and methods of measurement of radio disturbance characteristics of electrical lighting and similar equipment EN 55016 2 1 2009 3 25 2009 Specification for radio disturbance and immunity measuring apparatus and methods Part 2 1 Methods of measurement of disturbances and immunity Conducted disturbance
6. March 17 2009 the FCC adopted a Report and Order FCC 09 23 for advanced wireless medical radiocommunication devices used for human diagnostic and therapeutic purposes The newly adopted rules fall under Part 95 and allocate additional spectrum at 401 406 MHz These rules allow for a variety of devices that are either implanted or body worn and that operate either with listen before talk LBT technologies or at reduced power and low duty cycle FCC PROPOSAL TO PART 95 In addition to the Part 95 rules as stated above on March 20 2009 the FCC released proposing to allocate spectrum and adopt service and technical rules for the utilization of new implanted medical devices that would greatly expand the use of functional electric stimulation to restore sensation mobility and function to paralyzed limbs and organs These implanted neuromuscular microstimulators would function as wireless broadband medical micro power networks MMNs within a patient By eliminating the wires now used to interconnect multiple implanted neuromuscular microstimulators and the external power source for the implants MMNs would greatly reduce the risk of infection and increase patient mobility and system reliability The FCC is reviewing the feasibility of allowing up to 20 megahertz of spectrum in the 413 457 MHz band to be used under the Medical Device Radiocommunication Service MedRadio Service in FCC Part 95 The FCC seeks comment on the allocation of four specific
7. MultiPoint A Rhein Tech EMC Regulatory Update March 2009 EMC Regulatory Update Dear Colleague We have provided typical questions and answers that represent in most cases technical opinions with justification in FCC and CE requirements The particulars of the product for certification must be considered with respect to the applicability of these questions and answers We hope you find our update valuable and welcome your feedback if you have any special needs or questions Call at 703 689 0368 or view archived issues of MultiPoint at our FCC Part 15 and Receivers QUESTION My employer manufactures Part 27 transceivers Our compliance laboratory is insisting that the receiver part of our device must be tested to FCC Part 15 They explained that FCC Part 15 does apply because the device falls under FCC Part 27 transceiver device and the receiver section is subject to FCC rules and regulations We are of the opinion that our laboratory is incorrect We have reviewed the FCC Part 2 rules and searched the FCC s Knowledge Data Base KDB but cannot find any information that specifies the applicability of FCC Part 15 applies states what is needed but not what is not needed Can you shed some light into this issue on our behalf ANSWER While a transmitter can be a licensed device the receiver is not Receivers are FCC Part 15 devices not licensed devices even though they may work with or fit in a licensed device The digital portion of a
8. e not established within the EU community can the manufacturer or his authorized representative sign the DoC or does the Directive require a person established within the EU Community such as the importer to sign the DoC ANSWER For your first question we would say that in general it is OK to only apply the applicable parts of the standard For example most radio standards do contain a transmitter section and a receiver section If the device is a transmitter only then it is permitted to perform the transmitter tests only and to be confident that you have fully applied that standard to your device You would not need a Notified Body to confirm that the receiver section is not required for most devices It would be considered fully applying the standard for a transmitter There are situations where you must be careful For example within the transmitter section there may be tests which appear to apply to certain types of equipment but are in fact mandatory For example EN 300 328 requests that a Medium Access Protocol exists You could not say not applicable because my device does not have a Medium Access Protocol because it is a requirement of the standard You could not exclude certain mandatory transmitter or receiver tests just because your device transmitter or receiver does not support them Similarly there is a UWB standard EN 302 500 where a receive capability is mandatory to fully comply with the standard If a device were a trans
9. follows Focused Not too dark No glare spots Component placement and circuit board traces clearly visible Photo of label and label placement Legible drawing of label and label placement acceptable Further clarification if it is necessary to show component placement on the rear of individual boards then top and bottom view is necessary The FCC s objective of the photographs is to document in compliance folder that the device has not changed To also ensure that basic frequency determining and stabilizing circuitry including clock or data rates frequency multiplication stages basic modulator circuit or maximum power or field strength ratings shall have not changed You are required to show detail only for these boards and component placements and bottom views are only necessary if components are mounted on the bottom For other non RF Boards only photographs illustrating there position and placement in the chassis assembly is necessary INTERNATIONAL UPDATE EU NEW CENELEC STANDARDS RELEASED THIS MONTH This is a shortened list of the CENELEC standards published during the past month EN 61169 38 2009 3 2 2009 Radio frequency connectors Part 38 Sectional specification Radio frequency coaxial connectors model slide in rack and panel applications Characteristic impedance 50 U type TMA 50 U applications EN 60950 1 2006 A11 2009 3 6 2009 Information technology equipment Safety Part 1 General requirements EN 6
10. in the Community must affix the CE marking to each product and draw up a written declaration of conformity It also states the manufacturer must establish the technical documentation and he or his authorized representative established within the Community must keep it for a period ending at least 10 years after the last product has been manufactured at the disposal of the relevant national authorities of any Member State for inspection purposes It also further states where neither the manufacturer nor his authorized representative is established within the Community the obligation to keep the technical documentation available is the responsibility of the person who places the product on the Community market So if the manufacturer is outside of the EU Community then the person responsible for placing the device on the market must have access to the compliance documentation in case it is needed FCC Rules for ee Kit QUESTION We are a manufacturer of wireless products and have recently developed a product that is a developer kit This product is not intended for consumer use but rather for companies who want to test the product feasibility this technology and or for educational purposes The device has a serial and USB port available to control the transceiver an integral antenna and a regular SMA SubMiniature version A connect port The regular SMA connector port is provided so that developers may directly connect the unit to a powe
11. mitter only and attempting to comply with EN 302 500 then it would not be possible to dismiss the receiver requirements without the assistance of a Notified Body because the standard specifically states that a receiver is required in the device In this case you could not exclude the receiver operation and claim to have fully met the standard Regarding your second question it is not essential for the importer or person within the EU Community to sign the DoC The person who is responsible for the compliance of the device should sign the DoC Most typically this is the manufacturer whether they are within the EU Community or outside it However anyone importing a device into the EU Community should consider their actions and check the validity of the DoC If an importer wishes to import a device but no DoC exists then the importer should take responsibility for compliance and would therefore sign the Doc The Directive states the following the manufacturer or the person responsible for placing the apparatus on the market provides information for the user on the intended use of the apparatus together with the declaration of conformity to the essential requirements It further states the manufacturer or his authorized representative established within the Community ensures and declares that the products concerned satisfy the requirements of this Directive that apply to them The manufacturer or his authorized representative established with
12. onent as installed on a specific for evaluation purposes motherboard with a specific antenna and which is considered to operate in mobile RF exposure conditions The FCC identifier applies only for the component marketed and used in that specific board mounted and specific antenna configuration Use of the component itself in any other product requires separate FCC equipment authorization Photos ne a FCC for Intentional Radiators QUESTION Our firm has designed an FCC Part 15 intentional radiator Can you kindly confirm if internal photographs are required to show the top and bottom of each board in a device we are NOT referring to the modular approval process in this case or only the top and bottom view of the RF boards and other boards relating to the transmitter section To our knowledge the FCC has historically required for unintentional radiators that the internal photograph for unintentional radiators views show the top and bottom of all boards Please confirm the current FCC s position on this policy ANSWER FCC Part 15 Equipment authorization for certification intentional or unintentional lists all items required for certifying a radiator under The rules under the aforementioned section requires a sufficient number of photographs to clearly show the exterior appearance the construction the component placement on the chassis and the chassis assembly The FCC issued policy regarding interior and exterior photographs is as
13. r 50 countries ABOUT US ee RTL has provided EMC compliance engineering amp testing services since 1988 and has a superior reputation with both the Federal Communications Commission and others in the industry RTL provides testing services to meet the emissions immunity and safety requirements of the European EMC Directive and the EU R amp TTE Directive all FCC rules and regulations VCCI Japan ACMA Australia and other international standards A special thank you to those who have recommended and contributed articles for our newsletter Please continue to forward new and interesting material to our attention multipoint rheintech com We respect the privacy of our customers and colleagues If you would like to cancel your MultiPoint updates please follow the instructions at the end of this email The information in the MultiPoint update is subject to change without notice email multipoint rheintech com phone 703 689 0368 Last revised March 30 2009 web Rhein Tech Laboratories Inc 360 Herndon Pkwy 1400 Herndon VA 20170
14. r meter or spectrum analyzer to measure the RF performance and RF power etc The SMA connector port is made available by the removal of a resistor My questions are as follows Since the SMA port configuration is not intended for an antenna configuration but rather for RF instrumentation connection which the manual would state would a reverse threaded or non standard connector be required for the SMA port Are there any issues with developers removing components to change the integral antenna configuration to an SMA antenna configuration port If there are instructions in the manual of how the end user can modify the device would the instructions suffice or would the product have to be configured using hardware jumpers that allow the integral antenna or SMA port ANSWER In response to your question the scenario described does not appear to comply with FCC Part 15 203 Furthermore if the preceding FCC Part 15 203 issue is addressed and compliance for different configurations are addressed in your final application filing with the FCC such end user modification may not conflict with FCC Part 2 907 FCC Part 2 908 and FCC Part 2 931 You should also consider the following general remarks below Some transmitter circuit boards can be certified for evaluation or demonstration purposes as long as it is not intended to be used as a module to be evaluated within a host device such as a laptop computer Marketing of the device is not in
15. segments for this purpose 413 419 MHz 426 432 MHz 438 444 MHz and 451 457 MHz Additionally the FCC is seeking comment on the prospective service and technical rules that would govern MMN operations such as transmitter power emission bandwidth duty cycle contention protocols and other operating specifications which generally comport with the framework of the existing MedRadio Service ANADA RELEASE OF RSS 220 On March 27 2009 Industry Canada published Radio Standards S 220 Issue 1 Devices Using Ultra Wideband UWB Technology This standard establishes provisions for short range devices using ultra wideband UWB technology such as vehicular radar devices communication communication measurement location sensing and tracking devices and radar imaging ground penetrating radar GPR in wall radar imaging through wall radar imaging medical radar imaging and radar surveillance devices RSS 220 is in force as of March 28 2009 and there is no transition period CONTACT RHEIN TECH FOR YOUR INTERNATIONAL REGULATORY APPROVALS Rhein Tech Laboratories worldwide homologation services offer the best strategy for gaining product approval in a large number of target countries In addition we reduce the number of emissions immunity and product safety tests required by defining the minimum subset of regulatory standards at the onset thus reducing the time and cost to enter multiple target countries We offer research and approvals in ove
16. tended for the general public Certification of this transmitter circuit board requires appropriate grant conditions and user instructions to limit marketing and use of the device and the user manual must agree with the above The device must comply with FCC Part 15 203 and must not provide user instructions for use and evaluation with unauthorized antennas Transmitter boards used for evaluation in host devices must be modular approved and comply with the modular approval requirements including shielding An FCC Part 15 intentional radiator product marketed without an antenna cannot have an FCC identifier because FCC Part 15 204 b states that an approved transmission system must always be marketed as a complete system In other words an FCC certification for any FCC Part 15 intentional radiator is valid only when a transmitter is marketed INCLUDING one or more approved antennas For marketing as a component please see at least FCC Part 2 803 and available by clicking on the links In general devices sold to a second party for manufacture or fabrication into a device that is subsequently sold or leased to a user does not require equipment authorization What this means is that in general a component may be sold to a second party for further fabrication without having to demonstrate compliance with FCC rules but rather the end product that is sold to a vendor or user is subject to FCC rules An evaluation kit grant covers a transmitter comp
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