Introducing Wireless Into Your Product A collaborative presentation session by: Blue Guide EMC and UL VS Ltd.

Carl Hunt BEng (Hons) Technical and Regulatory Support Engineer Consumer Technologies Division ---------------------------------------------------- UL VS Ltd. Grove House, Lutyens Close, Basingstoke, Hampshire, RG24 8AG, England. T: +44 1256 31 2131 | M: +44 7894 412 240 E: carl.hunt@ul.com | W: http://industries.ul.com/wireless CTECH – UL 3.5 Years technical / regulatory support. Previous Marine / OTA Icebreaker! Traffic 350km

Agenda (Europe) R&TTE Directive - (Official Journal EU), Articles 3.1a, 3.1b and 3.2. R&TTE Directive - Annexes: Self-Declaration, Notified Body and TCF. Frequency Allocation - Unlicensed Bands in EU. Wireless Devices - Modular Approach, Typical Testing of 2.4GHz Device, Integration RSE, Antennas. R&TTE EMC - Wireless Modes. RF Exposure - Low Power Exemption, MPE Calculations, SAR Testing. Closing Note - Looking to the RE-D.

Agenda (USA and Canada) Authorization Routes - Certification, Verification, DoC. Rules & Standards - 47 CFR vs RSS Standards. Frequency Allocation - Unlicensed Bands in North America. Wireless Devices - Modular Approach (Single vs Limited), Grant Conditions, Typical Testing (15.247/RSS-210 Clauses), Integration RSE, Antennas. Unintentional Radiators - EMC of Digital Devices. RF Exposure - Mobile vs Portable Conditions, SAR Testing and Exemption.

UL Consumer Technology Division At UL, our mission of working for a safer world since 1894 is at the core of everything we do. Global coverage: 152 labs worldwide. 11,000 employees. ‘CTECH’ acknowledges the need for wider-reaching compliance solution: one-stop-shop! Competitiveness Collaboration Integrity

R&TTE Directive - (Official Journal EU), Articles 3.1a, 3.1b and 3.2. In 1999, the R&TTE Directive materialised as a 'New Approach' Directive: essential requirements + harmonised standards + responsibility of manufacturers + ex post market surveillance*. Essential requirements 1. The following essential requirements are applicable to all apparatus: (a) the protection of the health and the safety of the user and any other person, including the objectives with respect to safety requirements contained in Directive 73/23/EEC, but with no voltage limit applying; (b) the protection requirements with respect to electromagnetic compatibility contained in Directive 89/336/EEC. 2. In addition, radio equipment shall be so constructed that it effectively uses the spectrum allocated to terrestrial/space radio communication and orbital resources so as to avoid harmful interference. *TCAM = Telecommunication Conformity Assessment and Market Surveillance Committee  * ADCO = Group of Administrative Co-operation

R&TTE Directive - Annexes: Self-Declaration, Notified Body and TCF. Annex II (Internal production control) “whereby the manufacturer or his authorised representative…ensures and declares that the products concerned satisfy the requirements of this Directive that apply to them. The manufacturer or his authorised representative established within the Community must affix the CE marking to each product and draw up a written declaration of conformity.” Annex III (Internal production control plus specific apparatus tests) “The identification of the test suites that are considered to be essential is the responsibility of a notified body chosen by the manufacturer except where the test suites are defined in the harmonised standards.” Annex IV (Technical Construction File) “The manufacturer, his authorised representative established within the Community or the person responsible for placing the apparatus on the market, must present the file to one or more notified bodies, each of the notified bodies must be informed of others who have received the file.” http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:31999L0005

Frequency Allocation - Unlicensed Bands in EU. THE EUROPEAN TABLE OF FREQUECY ALLOCATIONS AND APLICATIONS IN THE FREQUENCY RANGE 8.3 kHz to 3000 GHz (ECA TABLE) 13.56MHz 433MHz 868MHz 2.4GHz 5GHz http://www.erodocdb.dk/Docs/doc98/official/pdf/ercrep025.pdf RFID Tag Remote Keyfob Wireless Alarm Bluetooth Dongle Wireless Router

Wireless Devices - Modular Approach. Like the FCC, Europe is modular-friendly! A pre-approved wireless module can be inserted into a host under the R&TTE Directive and repeat Testing of Article 3.2 might not be necessary. There are three typical scenarios considered by R&TTE CA TGN01: a. A Radio Module not placed on the market but integrated in a product by a (number of) different manufacturer(s) who places the final product on the market. Partial testing (Art 3.2 only) is acceptable. Compliance of end product falls to OEM Integrator. b. An assessed Radio Module placed on the market and installed in a product by the end user. Full testing Art 3.1a, 3.1b and Art 3.2 is required. c. An assessed Radio Module placed on the market and integrated in a product by a different manufacturer who places the final product on the market. Partial testing (Art 3.2 only) to permit movement of goods is acceptable but not ideal. http://www.rtteca.com/TGN01%20-%20May%202013.pdf

Wireless Devices - Typical Testing of 2.4GHz Device. (2400-2483.5MHz) EN 300 328 = Wideband transmission systems in the 2.4GHz band. The latest harmonised version of EN 300 328 is V1.8.1 which requires complete re-testing over V1.7.1 (expired 31st Dec 2014). >10dBm devices now need to demonstrate Spectrum sharing techniques: Adaptivity such as LBT, D&A Medium Utilisation (MU) 10% Tx cycle For transceiver devices, all clauses would be tested. Also, all except emissions, are normally performed on a conducted port. Radiated measurements This method shall only be used for integral antenna equipment that does not have a temporary antenna connector(s) provided.

Wireless Devices - Integration RSE, Antennas. “S1.145 spurious emission: Emission on a frequency or frequencies which are outside the necessary bandwidth and the level of which may be reduced without affecting the corresponding transmission of information. Spurious emissions include harmonic emissions, parasitic emissions, intermodulation products and frequency conversion products, but exclude out-of-band emissions.” A final product integrating an assessed radio module with an integral antenna or supplied with a specific antenna and installed in conformance with the radio module manufacturer's installation instructions may require no further evaluation under Article 3.2 of the R&TTE Directive. Changing the antenna from that which was originally approved should prompt a spurious emissions re-test. Note that integrating a pre-approved module into a host product does not exempt any/all emissions testing! (EMC Directive) http://www.itu.int/pub/R-REG-RR/en http://www.rtteca.com/TGN01%20-%20May%202013.pdf

R&TTE EMC - Wireless Modes. (Wireless = RF transmitter!) EMC (Electromagnetic Compatibility) is about testing the equipment in it normal but worst-case operating mode. If the Primary function of your device is, as an example, a network router / switch, then the testing under EMC Directive would probably be to EN 55022 and EN 55024 as I.T. Equipment. If the device has no wireless function then this is the only thing you need to do. If the device incorporates wireless (Tx, Rx or both) then more EMC modes exist that must be tested. Allocated (traffic or transmit) Idle (non-traffic or receive only) R&TTE Directive, Standards: EN 301 489-1 Ref EN 301 489-17

RF Exposure - Low Power Exemption, MPE Calculations. Health & Safety of the user regarding exposure to RF energy (R&TTE Art 3.1a). EN 62479 – General low power exemption levels such as 20mW. EN 62311 – Maximum Permissible Exposure (MPE) calculation. This determines the safe distance at which a person could be from the radiating structure. In Europe the power density is given and the distance is variable. Power Density (S) in W/m2 Port Power (P) in Watts Antenna Gain (G) in dBi Distance of person (r) in meters 𝑆= 𝑃.𝐺 4π𝑟2

RF Exposure – SAR Testing. Specific Absorption Rate (or SAR) is a measure of how transmitted RF energy is absorbed by human tissue. Is a function of electrical conductivity, the radiated energy (E-Field) and mass of a sample. Against an anthropomorphic model (head or body), the transmitter is configured to operate constantly. Robot arm manoeuvres probe to measure many different positions inside and records values. If we consider the radiation of RF energy from the previous slide, then we must have a way of determining how a radio transmitter will affect the human body when used in close proximity or for extended periods. SAR stands for Specific Absorption Rate and is calculated by assessing both how conductive a sample is, how strong the electric field influencing it is and how much mass the sample has. A good analogy might be a sponge soaking up water! <click space> So that a device can be assessed relevantly, it is positioned against a phantom head or body that is filled with special fluid. This fluid has a known permittivity (that’s the impact it has on electric fields) at a certain frequency and replicates the behaviour of human tissue. With this the impact on a person using a mobile phone can be measured by positioning a probe at varying places inside the phantom head and taking a reading each time. The resulting data can be processed to show a plot of absorbed power or used in a calculation that gives out one single figure for SAR measured in W/kg. High power into a small area is extremely dangerous. High power into a large area is likely to be manageable!

Closing Note - Looking to the RE-D. (dates of note) Article 48: “If you meet the requirements of the RTTE Directive before 13 June 2016, you have until 13 June 2017 to update to the Radio Equipment Directive” Article 49: “From 13 June 2016, equipment placed on the market for the first time must meet the requirements of the RED” Article 50: Directive 1999/5/EC (R&TTE) is repealed with effect from 13 June 2016.

Closing Note - Looking to the RE-D Closing Note - Looking to the RE-D. (Supplemental to original presentation) Further to questions received on the day, this slide is included as guidance to how I personally would handle the introduction of the RE-D! The Directive text is only in final draft at the moment. My notes following are guidance only and are subject to change but many sources on the internet are all along the same lines. Only when the Directive is mandated by member states will it become harmonised. Until then, do not reference it! Knowing the likely changes is one thing, I recommend manufacturers prepare themselves by reviewing the standards applicable to their products on the ETSI download page E.g. EN 300 328 (tick ‘all versions’) Working Group notes – important, read for changes!! The actual standard document.

Closing Note - Looking to the RE-D. (main changes) Article 2 Definitions: Sound and TV broadcast receivers, previously excluded, will now fall within the scope of the Directive [Art. 2.1(1)] Fixed-line telecom terminal equipment cease to fall within the scope of the Directive [Art. 2.1(2)] Radio-determination equipment becomes explicitly included [Art. 2.1(3)] Equipment operating below 9 kHz, previously excluded, will now fall within the scope of the Directive [Art. 2.1(4)] Note: Industrial Scientific Medical (ISM) equipment continues to be outside the scope of the Directive

Closing Note - Looking to the RE-D. (main changes) Article 2 Definitions: Sound and TV broadcast receivers, previously excluded, will now fall within the scope of the Directive [Art. 2.1(1)] Fixed-line telecom terminal equipment cease to fall within the scope of the Directive [Art. 2.1(2)] Radio-determination equipment becomes explicitly included [Art. 2.1(3)] Equipment operating below 9 kHz, previously excluded, will now fall within the scope of the Directive [Art. 2.1(4)] Note: Industrial Scientific Medical (ISM) equipment continues to be outside the scope of the Directive

Closing Note - Looking to the RE-D. (main changes) Article 3 Essential requirements: Art. 3(1), the protection of health and safety of persons and of domestic animals and the protection of property .. 2014/35/EU but with no voltage limit applying Art. 3(2) has been clarified so as to ensure that it includes requirements for the performance of radio receivers Art. 3(3)(a) can be invoked to cover interoperability between radio equipment and accessories such as chargers for mobile telephones Art. 3(3)(i) can be invoked to ensure that radio equipment can only upload software if the compliance of the combination of the software and the radio equipment has been demonstrated

Useful Links. Official Journal EU Harmonised Standards http://ec.europa.eu/growth/single-market/european-standards/harmonised-standards/index_en.htm R&TTE (soon to be RED) Compliance Association http://www.rtteca.com/index.htm http://redca.eu/ ECO Frequency Information System http://www.efis.dk/ ETSI Download Area + TR 102 070-1 and TR 102 070-2 http://www.etsi.org/standards-search http://www.etsi.org/deliver/etsi_tr/102000_102099/10207001/01.02.01_60/tr_10207001v010201p.pdf http://www.etsi.org/deliver/etsi_tr/102000_102099/10207002/01.01.01_60/tr_10207002v010101p.pdf

End of Part 1 – Europe Begin Part 2 – US & Canada

Authorization Routes – Certification Required for intentional transmitters – module or end-product. (a) Certification is an equipment authorization issued by the Commission (or TCB), based on representations and test data submitted by the applicant. (b) Certification attaches to all units subsequently marketed by the grantee which are identical (see §2.908) to the sample tested except for permissive changes or other variations authorized by the Commission pursuant to §2.1043. TCB’s now account for 99% of listings on the FCC database. Category I Equipment Category I equipment, which is comprised of radio apparatus which requires a technical acceptance certificate (TAC), pursuant to subsections 4(2) of the Radiocommunication Act and 21(1) of the Radiocommunication Regulations. Either the Certification and Engineering Bureau of Industry Canada (the Bureau) or a recognized Certification Body (CB) may issue a TAC. FCC ID: RI7GL865Q IC (ID): 5131A-GL865Q

Authorization Routes – Certification How do we obtain an FCC/IC ID? To get an FCC ID a manufacturer needs to have two things in place first: An FRN. https://apps.fcc.gov/coresWeb/publicHome.do A Grantee Code. http://transition.fcc.gov/oet/ea/granteecode_info.html E.g. Let’s say your Grantee Code is ABCDE and let’s say your Product Code you wanted as 12345.  On your label would then be FCC ID: ABCDE12345 Company numbers can be obtained through the E-filing System. To obtain a company number, login to E-filing, select "Manage Company Information" and then "Obtain new company number". After you have filled in the information and completed the request, an e-mail will be sent to you with your new company number. First time users of the E-filing system must register with Industry Canada before they can obtain a company number. https://strategis.ic.gc.ca/app/scr/registration-inscription/home.html?bpss The certification number shall appear as follows: IC: XXXXXX-YYYYYYYYYYY This is passed to the TCB on a 731 Form. This is passed to the FCB on the RSP-100 Annex A Application Form.

Authorization Routes – Certification What next? Manufacturer finds an FCC/IC approved test facility. §2.948   Description of measurement facilities. (d) A laboratory that has been accredited with a scope covering the required measurements shall be deemed competent to test and submit test data for equipment subject to verification, Declaration of Conformity, and certification. Such a laboratory shall be accredited by an approved accreditation organization based on the International Organization for Standardization/International Electrotechnical Commission (ISO/IEC) Standard 17025, “General Requirements for the Competence of Calibration and Testing Laboratories.” Test the product. (see later slide for typical rule parts) Get a test report. Manufacturer supplies application documentation ‘exhibits’. TCB/FCB performs a Technical Review. If product is approved: Application documents/Exhibits are uploaded to the FCC website TCB issues “Equipment Authorisation Grant” Client can sell in US If not approved, customer can not sell the product!!

Authorization Routes – Certification Is there anything a manufacturer should be prepared for? YES! The Exhibit categories for FCC are: Attestations Block Diagrams Cover Letters External Photos Internal Photos ID Label / Location Info Operational Description Parts List / Tune Up Info RF Exposure Info Schematics Test Report Test Set Up Photos Users Manual

Authorization Routes – FCC §15 Authorization Routes – FCC §15.101 Does Verification or DoC apply to my unintentional emitter?

Authorization Routes – Verification (FCC = Part 15B. IC = ICES-003.) Customer finds an FCC/IC approved test facility. §2.948   Description of measurement facilities. (1) If the measured equipment is subject to the verification procedure, the description of the measurement facilities shall be retained by the party responsible for verification of the equipment. Test the product Get a test report Hold the report on file Apply the appropriate equipment label Sell product in US Labelling requirements according to ICES-003 for IT Equipment. CAN ICES-3 (*)/NMB-3(*) This device complies with part 15 of the FCC Rules. Operation is subject to the following two conditions: (1) This device may not cause harmful interference, and (2) this device must accept any interference received, including interference that may cause undesired operation. Labelling requirements according to FCC 15B for unintentional emitters.

Authorization Routes – DoC (FCC = Part 15B. IC = ICES-003.) Customer finds an FCC/IC approved test facility. §2.948   Description of measurement facilities. (3) If the equipment is to be authorized under the Declaration of Conformity procedure, the laboratory making the measurements must be accredited in accordance with paragraph (d) of this section. Test the product Get a test report Hold the report on file Apply the appropriate equipment label Write and supply a Declaration of Conformity Sell product in US

Rules & Standards - 47 CFR vs RSS Standards. Published Rules: Part 15B Part 15C Parts 22/24/27 Published Standards: ICES-003 / RSS-Gen RSS-210 RSS-132/133 Unintentional Emitters / Receivers (PC Peripherals, Digital Devices, IT Equipment, Paging Receivers) Unlicensed Devices (SRD, Bluetooth, Zigbee, WLAN, NII) Licensed Devices (GSM 2G, UMTS 3G, E-UTRA 4G)

Frequency Allocation - Unlicensed Bands in North America. US and Canadian equivalent license-free bands. 13.56MHz >70MHz* 915MHz 2.4GHz 5GHz http://transition.fcc.gov/oet/spectrum/table/fcctable.pdf http://reboot.fcc.gov/reform/systems/spectrum-dashboard http://www.ic.gc.ca/eic/site/smt-gst.nsf/eng/h_sf01678.html RFID Tag Remote Keyfob Wireless Alarm Bluetooth Dongle Wireless Router * §15.231   Periodic operation in the band 40.66-40.70 MHz and above 70 MHz.

Wireless Devices - Modular Approach (Single vs Limited). All Yes = Single! Module can then be integrated into further host units with minimal fuss if Grant is adhered to. Any No = Limited! Limitation must be assessed when integrating into further host units. Possible Permissive change needed to address Grant compliance.

Wireless Devices - Grant Conditions. Grant conditions provide an overview or summary of the compliance requirements of the listing under that must be adhered to when integrating the module. Modular status or product approval noted. RF Exposure conditions. For cellular devices antenna gain in bands will be listed. Multi-transmitter restrictions.

Wireless Devices - Typical Testing (15.247/RSS-210 Clauses). FCC Test Clauses for a 2.4GHz WLAN device. Includes AC conducted emissions. IC Test Clauses for a 2.4GHz WLAN device. Note the addition of 99% emission BW above the FCC requirements.

Wireless Devices – Integration RSE & Antennas A transmitter device, whether it be a module or an end-product, will always be tested with at least 1 antenna. If integrating a pre-approved module into a product, RSE is not a certainty! Part 15 Devices for unlicensed bands: Manufacturer Type (omni, sectorized, patch etc.) Gain In-band & Out-band characteristics. If any of the above change then re-testing is advised! Part 22/24/27 for licenses bands: Only gain is really important (see Grant notes)

Unintentional Radiators - EMC of Digital Devices Unintentional Radiators - EMC of Digital Devices. (Testing to FCC = Part 15B and IC = ICES-003.) (k) Digital device. (Previously defined as a computing device). An unintentional radiator (device or system) that generates and uses timing signals or pulses at a rate in excess of 9,000 pulses (cycles) per second and uses digital techniques; … electronic computations, operations, transformations, recording, filing, sorting, storage, retrieval, or transfer. §15.3   Definitions. Subpart B—Unintentional Radiators (h) Class A digital device. A digital device that is marketed for use in a commercial, industrial or business environment, exclusive of a device which is marketed for use by the general public or is intended to be used in the home. (i) Class B digital device. A digital device that is marketed for use in a residential environment notwithstanding use in commercial, business and industrial environments. Examples of such devices include, but are not limited to, personal computers, calculators, and similar electronic devices that are marketed for use by the general public. Radiated Emissions (15.109) Conducted Emissions (15.107)

RF Exposure - Mobile vs Portable Conditions. US & Canada 2.1091 rule part indicates requirements for usage outside of 20cm. (MOBILE) 20cm 2.1093 rule part indicates requirements for usage inside of 20cm. (PORTABLE) §2.1091 (MPE Calculation) a mobile device is defined as a transmitting device designed to be used in other than fixed locations and to generally be used in such a way that a separation distance of at least 20 centimetres is normally maintained between the transmitter's radiating structure(s) and the body of the user or nearby persons. §2.1093 (SAR) a portable device is defined as a transmitting device designed to be used so that the radiating structure(s) of the device is/are within 20 centimetres of the body of the user.

RF Exposure - SAR Testing and Exemption. For PORTABLE devices, one of three routes is available to demonstrate compliance: 1) SAR exemption according to procedures permitted in KDB 447498 and RSS-102. FCC KDB 447498, Section 4.3.1 Standalone SAR test exclusion considerations IC RSS-102, Section 2.5.1 Exemption Limits for Routine Evaluation – SAR Evaluation

RF Exposure - SAR Testing and Exemption. For PORTABLE devices, one of three routes is available to demonstrate compliance: 2) SAR exemption by rationale of host equipment usage – Source Based Time Averaged Calculation (SBTA). = (maximum average RF power / transmit duty cycle) * (maximum Tx exposure time / maximum period of operation) Note: maximum RF power requires a tune-up document detailing the manufacturing tolerance and measurement uncertainty of manufacture and of measurement during quality checking! 3) SAR testing (routine evaluation). Expect price to be € thousands * number of bands!

Useful Links. FCC eCFR Title 47 FCC KDB Page http://www.ecfr.gov/cgi-bin/text-idx?tpl=/ecfrbrowse/Title47/47tab_02.tpl FCC KDB Page https://apps.fcc.gov/oetcf/kdb/index.cfm FCC Authorization Search Page https://apps.fcc.gov/oetcf/eas/reports/GenericSearch.cfm IC RSS List http://www.ic.gc.ca/eic/site/smt-gst.nsf/eng/h_sf06129.html IC Certification and Engineering Bureau http://www.ic.gc.ca/eic/site/ceb-bhst.nsf/eng/Home IC Radio Equipment List (REL) https://sms-sgs.ic.gc.ca/equipmentSearch/searchRadioEquipments?execution=e1s1&lang=en

THANK YOU.