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1 FCC Rules Seminar Taipei, Taiwan April 2004

2 AmericanTCB Taiwan AmericanTCB, Inc. 3F, 201, Ti Ding Avenue, Sec.2, Neihu 114 Taipei, Taiwan Major Chen Sales Manager Phone: 886-2-2658-5152 ext 311 Tim Johnson: +886 092039926

3 WELCOME and Thank You to our Sponsors Trivet Industrial Corporation Richtec Instruments Co., Ltd Training Research Corporation (TRC) EMI&EMC (Item Publications)

4 Seminar Schedule and Overview Introduction & Overview of FCC Rules –Bill Graff: 1: 00-1:45 Latest NPRMs and Rules Changes –Tim Johnson: 1:45-2:30 New requirements for Specific Absorption Rate (SAR) Testing –Bill Graff, ATCB: 2:30-3:15 Break: 3:15-3:30 Feature Presentation by Sponsors –Jones Yen, Trivet Industrial Corporation –Frank Tsai, TRC: 3:30-4:00 –P.H. Yuan, Richtech: 3:30-4:30 European Update –Mike Violette, ATCB: 4:30-5:00 Q&A –5:00-5:30 Reception –5:30-7:30

5 Fundamental Rules Seminar William H. Graff, AmericanTCB

6 USA Compliance US: Federal Communications Commission –Title 47 Code of Federal Regulations –Product approvals can be performed by FCC or Telecommunications Certification Bodies –TCBs are able to perform “routine” evaluations only using FCC recognized industry standard methods –New technologies or technologies where there is no industry consensus are excluded.

7 FCC 47 CFR Regulations Part 2 General Requirements Part 5 Experimental Radio Service Part 15 Subpart C, D, and E Unlicensed Low Power Transmitters (802.11a/b/g, Bluetooth, etc.) Part 20 Common Carrier Part 21 Domestic Public Service Part 22 Public Mobile Service Part 24 Licensed PCS

8 FCC 47 CFR Regulations Part 25 Satellite Communication Services Part 26 General Wireless Services Part 27 Miscellaneous Wireless Services Part 68 Telecom Services Part 73 Education Services Part 74 Television Broadcast Part 80 Maritime Service

9 FCC 47 CFR Regulations Part 87 Aviation Part 90 Private Land Mobile Part 95 Personal Radio Service Part 97 Amateur Radio Part 101 Fixed Microwave

10 FCC 47 CFR Regulations FCC does not regulate safety (except RF Exposure) susceptibility product performance

11 Certification –Used for most “Equipment Authorizations” Formerly called “Type Acceptance”. –Is more than just a “test report” – actually a legal document –Requires a detailed list of “Exhibits” See 2.1033 for complete detail –Test Report should be designed to show transmitter is “well-behaved”

12 Licensed Radio Services Test Parameters 2.1046 - Power Output 2.1047 - Modulation Characteristics 2.1049 - Occupied Bandwidth 2.1051 - Antenna Terminal Spurious Emissions 2.1053 - Radiated Spurious Emissions 2.1055 - Frequency Stability for Temperature and Voltage Variations

13 Licensed Radio Services Test Parameters In most cases - the actual Radio Service rules have special or unique requirements and additional testing parameters.

14 Licensed Radio Services Test Parameters In addition to the Part 2 rules addressing test parameters the FCC also recognizes the test methods contained in ANSI/TIA/EIA-603-1992 document ***Reference test procedures in report

15 Licensed Radio Services Test Parameters Remember that the purpose of performing the measurements required and submitting interpretations is to establish compliance with the technical requirement contained in the Radio Service Rules.

16 Licensed Radio Services Test Parameters Power Output: 2.1046 For any special case as sighted in the specific rules compliance to 2.1046 test method is accepted provided the specific Rule is addressed as part of the information.

17 Licensed Radio Services Test Parameters Where sections of the recommended standard EIA-603 differ from Part 2 requirements - the Part 2 test method must be used for testing purposes.

18 Licensed Radio Services Test Parameters Modulation Characteristics 2.1047 Test requirements of this section differ from EIA-603 requirements. Compliance to Part 2 requirements is mandatory.

19 Licensed Radio Services Test Parameters Example: EIA 603 differs from Part 2.1047 regarding the range which the audio frequency response is to be measured. –Part 2.1047 requirement of 100 - 5000 Hz should be used for this test. General Test Setup Transmitter Under Test Power Attenuator Power Measuring Receiver/Spectrum Analyzer Modulating Signal Generator

20 Licensed Radio Services Test Parameters Occupied Bandwidth 2.1049 While this test is identified as “Occupied Bandwidth” which is defined as that portion where 99% of the emitted energy (with the remaining 0.5% above & 0.5% below the occupied band), the results are mainly used to compare modulated spectrum with emissions masks OBW @ 10 Log (0.01) = -20 dBc Other rule sections may call out -23 or -26 dBc

21 Licensed Radio Services Test Parameters In addition to meeting the emission mask, the occupied bandwidth may not exceed the authorized bandwidth as listed in the Radio Service Rules. This test should be performed for each kind of emission to be listed on the FCC Grant. Note: the emission mask is normally applied with 0 dB equal to the level of the unmodulated carrier.

22 Emissions Mask Example Analog Modulation Mask

23 Emissions Mask Example Digital Modulation Mask

24 Licensed Radio Services Test Parameters 2.1049 does not cover Occupied Bandwidth tests for amplifiers or similar units since these devices are intended to reproduce the modulated signal. Amplifiers designed to handle multiple channels should be tested with multiple channels for each emission to show intermodulation products. Tests for power amplifiers still should include “gozinto” and “gozouta” plots for each modulation desired.

25 Licensed Radio Services Test Parameters Intermodulation is considered a spurious emission by the FCC and are covered by the general emission limitations (masks) in each radio service. This specifically refers to the IM products produced by transmitters / amplifiers carrying two or more signals.

26 Licensed Radio Services Test Parameters Antenna Terminal Spurious Emissions 2.1051 (Otherwise know as Conducted Emissions) View levels of harmonic emissions. An extension of the occupied bandwidth test showing the emission up to the highest frequency as specified in Section 2.1057 [usually 10 th harmonic]. 0

27 Licensed Radio Services Test Parameters If the unit does not have a detachable antenna or an antenna output terminal then the test data is collected at the base of the antenna.

28 Licensed Radio Services Test Parameters Field Strength of Spurious Emissions 2.1053 –ERP/EIRP Spurious Measurement This test includes those emissions radiated from the cabinet, chassis, and associated wiring. The specification is the same emission mask under the Radio Service rules extended to the highest frequency specified in 2.1057. Substitution method described in TIA/EIA 603 required test procedure. Be sure to account for SWR when using broadband antennas !

29 Licensed Radio Services Test Parameters Frequency Stability 2.1055 Done over temperature [-30 C to +50 C] and operating voltage [+/- 15%] specifications. Battery operated devices should also include B.E.P [Battery End Point] Usually defined in ppm but other units such as Hz, % are accepted as defined in specific rule section. Differs some from methodology described in TIA/EIA 603

30 Licensed Radio Services Test Parameters Reference Standards: TIA/EIA 603 Land Mobile FM or PM Communications Equipment Measurement and Performance Standards TIA/EIA Telecommunications System Bulletin TSB102 (Digital C4FM/CQPSK Transceivers Measurement Method

31 Licensed Radio Services Test Parameters Emission Designator: Determined from the Occupied bandwidth and the modulation scheme used Classic equations described in Part 2 Required as part of submittal

32 Common Part 22 H Cellular Emission Designators 40K0F8W – AMPS Cellular voice & signaling tone 40K0F1D – AMPS Cellular wideband data 1M25F9W – CDMA (IS 95/98) 30K0DXW - North American digital cellular - TDMA 300KGXW – GSM 300KG7W - EDGE

33 Emission Designator Calculation Emission Designator –40K0F8W - Voice & SAT signal Voice (M=2.5k, D=12k), SAT (M=6k, D=2k) Pick highest frequency and add deviations and apply Carson’s Rule 2M+2D 2(6k) + 2(12k+2k) = 12+28 = 40 kHz –40K0F8W - Signaling Tone (ST) & SAT ST (M=10k, D=8k), SAT (M=6k, D=2k) 2(10k) + 2(8k+2k) = 20+20 = 40 kHz –40K0F1D - Wideband Data Data (M=10k, D=8k), SAT (M=6k, D=2k) 2(10k) + 2(8+2) = 20+20 = 40 kHz

34 Example Part 22 H Grant

35 Certification Checklist for Licensed Services Applicant Name Correct Test Firm FCC ID: number Equipment Functional Description Equipment Class

36 Certification Checklist for Licensed Services Confidentiality Request Letter –Letter with details to be included with confidentiality. –Commonly only Block Diagram, Schematics, Parts List and Tune-up are eligible for confidential treatment –Manuals, photos, test reports, SAR reports never allowed confidentiality –Date of letter

37 Certification Checklist for Licensed Services Technical Information Rule Part(s) Frequency Range Power Output

38 Certification Checklist for Licensed Services Antenna Port –(Real Connection or Integral antenna?) Frequency Tolerance Emissions Necessary Bandwidth Values Justified Emission Type Justified

39 Certification Checklist for Licensed Services RF Exposure Information Description: Purpose, Use and Users Instruction Manual DC Voltages and Currents Listed Tune Up Procedure Circuit Diagram \ Block Diagrams

40 Certification Checklist for Licensed Services Photos (Internal & External) Technical Report Power Output –(ERP/EIRP or Conducted? Peak or Average?) Audio Frequency Response Modulation Limiting

41 Certification Checklist for Licensed Services Frequency Stability vs Voltage + 15% and Battery end point Frequency Stability vs Temperature -30C to +50C

42 Required Exhibits for Licensed Services Agent Authorization Letter Confidentiality Request Schematics Block Diagram RF Exposure Evaluation Operational Description Tune Up Procedure

43 Required Exhibits for Licensed Services External Photographs Internal Photographs Sample Label with FCC ID: Label Location Test Setup Photographs Users Manual Test Report

44 Timothy R. Johnson, American TCB Recent FCC Clarifications, Latest NPRM’s and Rules Changes

45 Presentation Overview Part 15 Recent Interpretation Issues, Reminders, and Application Concerns Part 15 Rulemaking updates –NPRM’s, Report and Orders, etc.

46 Multiple Modulation Capabilities in One Device One familiar example, 802.11(g) incorporates the following modulation capabilities. BPSK modulation at 1 and 2 Mb/s CCK modulation at 5.5 and 11 Mb/s OFDM modulation at 54 Mb/s The FCC expects each of these modes and modulations to be evaluated (i.e. pretest, etc.)

47 Justification for worse case results reported or modes reported should be included in the test report As a minimum, it is suggested that an 802.11g test report should include: –Data for BPSK/CCK. Due to similar waveforms, only worse case data needs to be shown for these 2 modulations –Data for OFDM Multiple Modulation Capabilities in One Device – Cont.

48 AC Line Conducted Emissions for Part 15 Modules Section 15.207(a) requires test data unless the device is battery powered with no provision for receiving power directly or indirectly from an AC source. Any application granted for battery power only will be listed as a condition on the grant of authorization.

49 AC Line Conducted Emissions for Part 15 Modules – Cont. Battery powered examples: –The transmitter is powered by an on-board battery.  Transmitter has a battery connector/compartment –The transmitter is only intended for battery powered applications and installed by OEM.  Device is conditioned only for battery powered applications and a limited module approval is issued  Any new non-battery application requires a new authorization (new FCC ID) –The transmitter is installed only in the manufacturers equipment that will be battery powered  Grant is conditioned accordingly and a LMA is issued

50 CISPR AC Line Conducted Limits for All Transmitters Since December 3, 2002, all Part 15 and 18 devices required to be tested for AC Line conducted emmissions must have either Note Code ’05’ or ‘CE’ listed on the grant of equipment authorization.

51 CISPR AC Line Conducted Limits for All Transmitters – Cont. "05" NOTE- The manufacture and importation of this device must cease on July 10, 2005 pursuant to 15.37(j) or 18.123 transition provisions adopted under FCC 02-157 (ET Docket 98-80). "CE" NOTE - This device has shown compliance with the conducted emissions limits in 15.107, 15.207, or 18.307 adopted under FCC 02-157 (ET Docket 98-80) and may be marketed after July 11, 2005 and is not affected by the 15.37(j) or 18.123 transition provisions.

52 CISPR AC Line Conducted Limits for All Transmitters – Cont. Currently the ’05’ note has been used on all devices that meet the older FCC line conducted regulations and not the new CISPR limits. This will only be allowed up until July 11, 2004. After this time TCBs and the Commission will no longer use the ’05’ note code.

53 CISPR AC Line Conducted Limits for All Transmitters – Cont. The ‘CE’ note is used on all devices that are tested and comply with the new CISPR requirements and are granted before July 12, 2004. On July 12, 2004, all new approvals must meet the new CISPR limits. TCBs and the Commission will not use the “CE” note after July 11, 2004. All devices (both new and previously approved) marketed after July 11, 2005 must meet the new CISPR AC Line Conducted Limits.

54 CISPR AC Line Conducted Limits for All Transmitters – Cont. To update a Part 15 grant that was approved using the previous Part 15 limits, a Class II permissive change filing should be submitted showing compliance with the CISPR AC line conducted limits.

55 CISPR AC Line Conducted Limits for All Transmitters – Cont. Special Note: The policies for filing Class II permissive changes are different for some Part 18 devices because certain types of Part 18 devices had no AC line conducted emissions limits before the FCC adopted the CISPR limits. –Example Microwave ovens - for a detailed description see link:

56 CISPR AC Line Conducted Limits for All Transmitters – Cont. Special Note 2: Part 18 RF lighting devices were excluded from the new CISPR AC line conducted limits by the last sentence in Paragraph 22 of the Report and Order (ET Docket No. 98-80; FCC 02-157). Therefore, RF lighting devices will not have a Note Code 05 or CE on a grant of Certification.

57 Vehicular Battery Chargers (VBC) for Cellular Phones There have been recent questions regarding whether a battery charger intended for use only in a vehicle requires FCC Certification.

58 Vehicular Battery Chargers (VBC) for Cellular Phones – Cont. Exempted per Section 15.103(a) –The VBC is not promoted for applications other than use within a vehicle, Section 15.103(a) exempts digital devices used exclusively in transportation vehicles –Classified as a digital device under Part 15 of the FCC rules –Subject only to non-interference provisions (Sections 15.5 and 15.29) –Certification not required

59 Part 15 Water Meter Transceivers In Ground Testing Guidance FCC has recently issued a special guidance regarding this issue. See link: –This guidance allows testing in ground as opposed to an open area test site (OATS) –This gives the manufacturer more flexability to measure “system” vs. stand-alone configurations. Allows manufacture to tune power to meet their installation requirements –Professional installation is required –Instructions must provide appropriate details for the installation of the transmitter in the pits and must specify the types of pits –Grant will contain conditions accordingly  Professional installation and specific types of pits

60 Part 15 Water Meter Transceivers In Ground Testing Guidance – Cont. Special Guidance: –Use mast. Do not use a tripod with fixed height –Section 8.1 in ANSI C63.4 should be consulted. Frequency scans of the EUT field strength with both polarities of the measuring –antenna shall be made at a minimum of 16 azimuth angles (nominally 22.5 degrees) around the EUT

61 15.407(d) Integral Antenna Requirement for 5.2 GHz UNII Devices The integral antenna rule requires that the antenna is permanent or not removable.

62 15.407(d) Integral Antenna Requirement for 5.2 GHz UNII Devices – Cont. Acceptable methods: –Antenna and/or antenna connectors are soldered together –Permanent Loctite or industrial strength epoxy can be used –A locking connector that cannot be removed, even with a special tool  Must be locked prior to shipment

63 15.407(d) Integral Antenna Requirement for 5.2 GHz UNII Devices – Cont. –An antenna and/or connectors inside of a non- accessible (there is no need for the user to ever open the case) Note that it is assumed that users will open desktop computers.

64 15.407(d) Integral Antenna Requirement for 5.2 GHz UNII Devices – Cont. Exceptions: For a 5.15-5.25 GHz UNII mini-PCI card installed in a notebook computer with built-in antennas –Bios locking feature satisfies the rule Antenna with embedded code. –Code ensures that the proper antenna is used Reminder: 5.15 – 5.25 GHz is for indoor use only. No outdoor antennas.

65 15.407(d) Integral Antenna Requirement for 5.2 GHz UNII Devices – Cont. Unacceptable Methods: –A unique connector is not sufficient –Bios lock with external antenna –A locking connector that can be removed with a special tool does not satisfy the requirement –Heatshrink –User Warnings

66 User Selectable Frequencies End user selectable frequencies for non USA frequencies are not allowed. –User selectable options must be disabled –This must be clear in all exhibits within the filing. For example user manual or descriptions for these options Section 15.15(b) prohibits adjustments of any control by the user that will cause operation of a device in violation of the regulations.

67 Configuration of Antennas for Testing The FCC has recently developed 2 concerns regarding test configurations for the antennas of a modular approval.

68 Configuration of Antennas for Testing – Cont. 1) Antenna positioning in test setup should represent typical final product configuration 2) DO NOT LAY ANTENNAS ON WOOD TABLETOP

69 Configuration of Antennas for Testing – Cont.

70 Configuration of Antennas for Testing – Cont. In this example the monopole antennas should be supported in vertical position, e.g., using foamed-polystyrene blocks

71 Configuration of Antennas for Testing – Cont. Note that this also applies to antennas such as PIFA. The antennas shown on the following page should not be placed in contact with the table top during test. Additionally, the positioning should be justified in the report.

72 Configuration of Antennas for Testing – Cont.

73 Configuration of Antennas for Testing – Cont. The FCC has seen that the matching of the antenna changes when placed too closely to the table top, which affects the radiation pattern.

74 Co-located Transmitters, i.e. Laptop w/ LAN & Bluetooth – Cont. Co-Location is typically defined as when 2 transmitter antennas are located < 20 cm apart from each other, and both transmitters may be active at the same time. Each radio must be tested individually and appropriate test data submitted with the application

75 Co-located Transmitters, i.e. Laptop w/ LAN & Bluetooth – Cont. The application must also include tests for simultaneous transmission when the end use device may function with both transmitters active at the same time

76 Co-located Transmitters, i.e. Laptop w/ LAN & Bluetooth – Cont. Special care should be taken to investigate bandedge and intermodulation products Submit antenna conducted measurements with both transmitters on, if transmitters share an antenna

77 Co-located Transmitters, i.e. Laptop w/ LAN & Bluetooth – Cont. –If radiated data for simultaneous transmission is no worse (no new intermod, spurs or increased levels) than individual tests, then also submit statement that simultaneous transmission was investigated and no new emissions were found –If new emissions were found during simultaneous tests, provide data and indicate the worst case condition

78 Cordless Phones Cordless phones under Part 15 have typically been approved under several sections of the FCC rules such as 15.233, 15.247, and 15.249.

79 Cordless Phones – Cont. The FCC has just released an interpretation that requires a cordless telephone that operates on two different frequency bands to be approved under two separate FCC ID numbers, one for the base and one for the handset. For detailed information, refer to FCC Interpretation Data Base Posting 200009-13-004

80 NPRM’s NPRM – Notice of Proposed Rule Making This is a term used to denote a document that is published for public comment. The changes shown in the document are proposals only which may or may not actually become new rules and/or regulations.

81 NPRM Modification of Parts 2 and 15 Proposal to make changes to Parts 2 and 15 may be found in ET Docket No. 03-201, FCC 03- 223 – Published December 10, 2003 –Public comments were due February 7, 2004

82 NPRM Modification of Parts 2 and 15 – Cont. 1) Work to clarify the rules for advanced antenna technologies –(i.e. phased array/steerable beam systems) in 2.4 GHz band 2) Modify the rules on replacement of Part 15 antennas 3) Modify the rules on configuring transmission systems –No need to obtain separate authorization for every combination of system components. i.e. adding amplifiers 4) Harmonize the measurement procedures for digital modulation systems under the Spread Spectrum and UNII rules

83 NPRM Modification of Parts 2 and 15 – Cont. 5) Modify the channel spacing requirements for hoppers in the 2.4 GHz band to allow wider bandwidth hoppers 6) Clarify and change modular approval requirements 7) Make other changes to update or correct Parts 2 and 15 of the rules

84 NPRM on Interference Temperature Proposal in ET Docket No. 03-237, FCC 03-289 –Adopted: November 13, 2003 –Released: November 28, 2003 –Published January 21, 2004 –Comments due April 5, 2004 –Reply Comments due May 5, 2004 – News Release –

85 NPRM on Interference Temperature-Cont. RM seeks comments on “Interference Temperature” approach to quantify and manage interference between different services. Interference temperature model takes into account the cumulative radiofrequency (RF) energy from transmissions of spectrum-based devices and would set a maximum cap on the aggregate of the transmissions. –Current interference management approach is based on specifying and limiting transmit powers of individual spectrum based devices

86 NPRM for Access Broadband Over Power Line Systems Proposal to make changes to Part 15 may be found in ET Docket No. 03-104 & 04-37, FCC 04-29 – 1) Access broadband operational requirements 2) Equipment authorization and measurement guidelines

87 Report and Order Report and Order (R&O) This is a term used to denote a document that includes adopted rules, provides background on reason for adoption and Effective Date. Requires publication in Federal Register

88 2nd R&O and MO&O Part 15 Deregulation New Rules in ET Docket No. 01-278, FCC 03-149 –Effective date: January 8, 2004 –

89 2nd R&O and MO&O Part 15 Deregulation – Cont. 1) Change emission levels in the restricted bands above 38.6 GHz 2) Allow data transmission in 15.231 3) Modify the FS limits for 13 MHz RF ID systems 4) Simplify the labeling requirement for self authorized equipment (DOC) –Removed “For Home or Office Use” and statement that a complete device was tested for compliance

90 2nd R&O and MO&O Part 15 Deregulation – Cont. 5) Other changes to update and correct FCC rules. –Incorporate the ANSI C63.17 test procedure for UPCS devices into the rules –Provide exemption for certain low power devices <490 kHz and FS is less than 40 dB below Part 15 limits –Allow user manual information on CD-ROM or on internet if manual is provided likewise –FRS transmitters tested -20 to+50 degrees C for frequency stability tests –Accredited labs do not have to file description of measurement facilities with the Commission. However, Certain information is still required. Name, address, contact info, accrediting body’s name, designation number and date of renewal –Miscellaneous rule corrections and deletions

91 R&O UNII Devices New Rules in ET Docket No. 03-122 –Effective date, February 19, 2004 – –Adds 255 MHz of spectrum 5.47-5.725 GHz to current UNII bands –Dynamic Frequency Selection (DFS) for devices in the 5.25-5.35 GHz band and 5.47-5.725 GHz band –Interim DFS Test procedure is in the Appendix of the Rules. –Transmit power control (TPC) 5.47-5.725 GHz band –According to the FCC only a statement that the device has TPC is required to be submitted in the filing. No test required

92 R&O UNII Devices – Cont. DFS and TPC are considered new technology –TCB cannot approve any device operating under the new rules Test procedure will be updated in the near future –Currently this is considered a complex test which requires specialized equipment and software

93 R&O UNII Devices – Cont. Class II permissive change for existing equipment to add DFS & TPC –Allowed only for software change –Any hardware change requires NEW AUTHORIZATION Transition dates; equipment operating in 5.25- 5.35 GHz –1 year, Certification filings must comply w/ new rules by February 19, 2005 –2 years, All devices imported and marketed must comply by February 19, 2006

94 Additional References FCC Interpretation Database:

95 RF Exposure Tutorial William H. Graff, AmericanTCB

96 Portable vs. Mobile Specific definitions for RF exposure –Mobile – Greater than 20 cm –Portable – Less than 20 cm

97 What is SAR? Close field phenomenon which occurs when an electromagnetic wave interacts with a biological medium Occurs at less than ¼ wavelength E and H fields are at relative maximums

98 MPE calculation MPE calculations assume a linear plane- wave field. Considered an overestimate of maximum field density Not applicable to distances under 20cm Cannot predict interaction with nearby structures

99 SAR measurement Requires isotropic power measurement systems Typically use 3 axis probes in a biological “soup” Soup has electrical characteristics nearly identical to tissue at specified frequency

100 Example Systems SPEAG IndexSARAprel/IDX

101 P1528 §1.4.2 Positioning Rationale Touch/cheek Tilt 2 pos. intended to encompass normal use, may not be worst-case 2 pos. are subset of 4 from ES 59005:1998 (CENELEC), where experiences showed that 2 pos. are enough for conservative Touch position is most repeatable since it relies on two- or more point contact with phantom; accounts for RF current densities in device case regions Tilt position accounts for RF current densities in external antennas and antenna feed-regions at top of handset

102 SAR Mapping Systems 1)control and data capture unit 2)field-probe readout electronics 3)dosimetric E-field probe 4)probe positioner 5)unwanted ambient fields 6)phantom shell with tissue- equivalent liquid, 7)device-under-test 8)device holder/positioner. coarse scan over device outline to locate hot-spots

103 Head Phantom SCC-34/SC-2 head model - SAM (Source: IEEE SCC-34/SC-2, P1528 Draft) ERP EEP - entrance to ear canal 15 mm M B LE F ERP - ear reference point EEP M B -30 N F +30 0 +20 0 -60 RE (ERP) 10 mm square N

104 SAR Test Positions M B -30 N F +30 0 +20 0 -60 RE (ERP) 10 mm square. w b /2 vertical center line horizontal line bottom of handset acoustic output w t /2 A B. w b /2 acoustic output horizontal line vertical center line bottom of handset A B point A is “test device reference point” align point A to ERP on head model align vertical center line to M-B align horizontal line to N-F

105 Limitations of P1528 Does not address all body worn configurations Does not address methodologies above 3GHz Does not address non-standard ear-held devices which do not conform to M to LE or RE line

106 SAR Limits Experiments with laboratory rats Scaled up to humans using known models borrowed from pharmaceutical industry

107 Supplement C: Exposure Limits

108 Supplement C: SAR Limits

109 Controlled vs. Uncontrolled End users which have a knowledge of radio waves and can limit their exposure can use Controlled limits End users which may have no knowledge of the limits must use Uncontrolled limits

110 Differences in Limits Limit for Controlled exposure in the head = 4W/kg (4mW/g) Limit for Uncontrolled exposure in the head = 1.6W/kg (1.6mW/g)

111 When is SAR testing required? FCC maintains two threshold limits – one for itself and another for TCBs. TCBs must always follow TCB Exclusion List of July 17, 2002

112 Portable PTT Part 80, 90, 95 FCC – SAR data required for PTT above 1W radiated or conducted TCB – 60mW/f(GHz)

113 Portable 15.247 and 15.407 Below 3GHz –FCC – SAR data if above 50-100mW –TCB – 60mW/f(GHz) Above 3GHz –FCC – SAR data if above 50mW –TCB – cannot do –***By law, SAR data required for all portable UNII devices regardless of Pout

114 Modules No such thing as RF category “Portable” modular approval. (Same FCC or TCB) Full modular approvals are only permitted for RF category “Mobile” modules

115 LMA and SAR Limited Modular Approvals are permitted but only for carefully defined host platforms. Hosts must have similar mechanical constructions.

116 Three Host Method RF category “Portable” modules are permitted under specific circumstances and specific hosts. Testing to be performed in three each portable devices (i.e. notebook PC, PDA, etc.) Unlimited “Portable” modular approvals never permitted

117 Simultaneous Transmission If radiating structures <20cm then simultaneous transmission may be of concern. FCC evaluates co-located devices with simultaneous transmission TCB cannot per TCB Exclusion List if second non-dominate transmitter above 5mw

118 Above 3GHz IEEE P1528 does not yet define a methodology for SAR testing above 3GHz, therefore all SAR evaluation above 3GHz must go to FCC Expect approvals from FCC to take 90 days

119 RF Safety Documents for Issues with Human Exposure ANSI C95.1 OET 65 OET 65-C FCC Part 1.1037 FCC Part 2.1091 Mobile Devices FCC Part 2.1093 Portable Devices TCB Exclusion List

120 Future Provisions Additional guidance on body-worn configurations Release of procedure for TCBs to evaluate SAR above 3GHz –Likely to be timed with release of DFS procedure to TCBs

121 Questions?

122 R&TTE Directive Michael Violette, P.E.

123 European R&TTE Directive

124 European R&TTE Market R&TTE equipment: 58 b € /year in the EU –Machinery market: >250 b € /year –Telecommunication Services: 200 b € /year Diverse industry –Big Companies (Nokia, Ericsson, Motorola, Siemens, Philips, Alcatel, Nortel) –Many SMEs in e.g. Short Range Radio markets Before R&TTE Directive: Many different requirements –> 1000 national regulations, around 30 harmonised EU regulations –fragmentation of spectrum After R&TTE Directive: less fragmented Total sectors covered by EMC Directive: 250 b€

125 EU Market May 1 st 2004 Members of EU: Austria, Belgium, Denmark, Finland, France, Germany, Greece, Ireland, Italy, Luxembourg, The Netherlands, Portugal, Spain, Sweden, United Kingdom, Cyprus, Czech Republic, Estonia, Hungary, Latvia, Lithuania, Malta, Poland, Slovakia, Slovenia

126 R&TTE For wired and wireless telecommunications equipment Covers the following aspects: –Efficient use of spectrum –EMC –Safety Includes EMC and Low Voltage Requirements

127 R&TTE Approval Process CE Marking by manufacturer is allowed Self-Declaration for many products Reduced approval procedures and processes Harmonized standards developed Faster, cheaper, more market coverage for SME

128 Annexes Annex I: Things NOT covered –Cables, Receive-only broadcast, Kits, Aviation and Air Traffic, marine Annex II: Internal Production Control –Basis for all Annexes (good documentation!) Annex III: Annex II + Testing –Type testing Annex IV: TCF –Notified Body (for new technologies) Annex V: Full QA –Accredited Quality Assurance System

129 R&TTE Testing No longer requires involvement of accredited test house Test to harmonized standards –DoC –CE Marking –Ship Non-harmonized frequencies: –Notification to Governments –Alert Signal (Equipment Class Identifier) –Restricted Geographical Area

130 TCF & NB Opinion For new technologies WITHOUT harmonized standards Notified Body or Conformity Assessment Body opinion

131 TCF Documentation Product description Conceptual design and manufacturing drawings such as schematics and subassembly drawings A description and explanation of the drawings, schematics, and operation of the product A list of all standards that were applied, in full or in part, to show compliance. –If standards were not used or do not exist, then a description and explanation of the solutions used to meet the essential requirements of the directive must be included Results of design calculations and examinations Test reports A copy of the DoC

132 Self Certification (ALL Harmonized)

133 Self Certification (Standard Harmonized, Frequency NOT harmonized Notification required)

134 Standard NOT Harmonized, Notified Body

135 Which way to go?

136 Harmonized Frequencies (Short Range Devices) Document CEPT 70-03 –Lists frequencies and usage in different European countries Published by: European Conference of Postal and Telecommunications Administrators Available at: European Radiocommunications Office link to National Frequency Plans: –

137 Examples from CEPT 70-03

138 Notification Applies to radio equipment using a non- harmonized frequency If non-harmonized frequency band, the manufacturer must determine if the frequency is available for use in a particular member state Notify each member state where the equipment is to be sold

139 Notification Notify the Spectrum Authorities in each member state Must be made 4 weeks prior to the equipment being offered for sale.

140 Identify Requirements Market (Countries) Restrictions (CEPT 70-03) Harmonized Standards? (Official Journal) TCF/Notified Body Test Suite

141 Example ETSI/EN Standards Available from (free!) Telecom, EMC & Radio Matters EN 300 386: –Electromagnetic compatibility and Radio spectrum Matters (ERM); Telecommunication network equipment; ElectroMagnetic Compatibility (EMC) requirements ETS 300 328: –Radio Equipment and Systems (RES); Wideband transmission systems; Technical characteristics and test conditions for data transmission equipment operating in the 2,4 GHz ISM band and using spread spectrum modulation techniques

142 Getting the CE Marking Procedure for Harmonized Standard Look in ERC Report 70-03 for Country Restrictions and Harmonized Standard Test product to standard Notify Spectrum Authorities Prepare final documentation Label device Ship

143 Classification Class 1: equipment, which can freely move and be switched on in the Community (wired equipment, GSM, Receive-only equipment, etc.) Class 2: equipment, for which this is not the case (transmitters, which are to be licensed) –Marking: simple marking scheme agreed between Member States: CE mark only for class 1 equipment (+ NB Numbers) CE mark + for class 2 equipment (+ NB Numbers)

144 Examples Short Range Device (SRD) Operating at 433 MHz Spread Spectrum WLAN/RLAN operating at 2.4 GHz GSM phone operating at 900 MHz band

145 Example 1: Short Range Device (SRD) Equipment Parameters: –433.92MHz –Low power <2.5mW –Modulation: FSK –Duty Cycle: <1% –Integral Antenna –Battery Powered –“Non-Specific Short Range Device”

146 Example 1 SRD: ERC 70-03 Restrictions

147 Example 1 SRD: ERC 70-03 Technical Restrictions

148 Example 1 SRD: ERC 70-03 Standards to Apply

149 Example 1 SRD: ERC 70-03 Standards to Apply

150 Example 1 SRD: Full R&TTE Requirements Compliance test requirements –Radio: EN 300 220-3 Radio and Spectral Matters –LVD: EN 60065 –EMC EN 301 489-3 (SRD) Emissions Immunity

151 Example 1 SRD: Documentation Requirements 1.Equipment complies: Test report/TCF 2.Generates and signs DOC 3.Labels equipment 4.Notifies countries before marketing (Only if frequencies are not harmonized)

152 Example 2: Spread Spectrum WLAN/RLAN Equipment Parameters: –2400-2483.5 MHz –Power <100mW EIRP –Duty Cycle: No Restriction

153 Example 2 RLAN: ERC 70-03 Restrictions

154 Example 2 RLAN: ERC 70-03 Technical Restrictions

155 Example 2: ERC 70-03 Standard to Apply

156 Example 2: Standard to Apply

157 Example 2 RLAN: Full R&TTE Requirements Compliance test requirements –Radio: EN 300 328 Radio and Spectral Matters –LVD: EN 60950 –EMC EN 301 489-17 (RLAN) Emissions Immunity

158 Example 3: GSM Phone

159 Example 3 GSM Phone: Harmonized Standard for BS

160 Example 3 GSM Phone: Harmonized Standards for Handsets

161 RF Exposure Harmonised Standards for Electromagnetic Fields EN50360 & EN50361 for handsets

162 Labeling Summary

163 R&TTE Labeling Example NAME OF A COMPANY MODEL NUMBER SERIAL NUMBER FREQUENCY BAND nnnn The Notified Body Number: used when either annex III, IV or V have been used Alert symbol used when frequency is not harmonized

164 Conclusions Much simpler than in years past CE Marking allows access to multiple markets Frequencies increasingly harmonized Good access to ETSI/EN standards Worldwide product designs possible for many types of products.

165 Thank You!

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