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Equipment Authorization Update
US Federal Communications Commission Office of Engineering and Technology
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Equipment Authorization Update
Overview FCC Rulemakings R&O FCC NPRM FCC 15-92 Related significant KDBs Certification and MRA Status Market Surveillance Recent considerations Information Sources April 2016 Equipment Authorization Update 2
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Review of Equipment Authorization Program
Presented at June 2012 Commission Meeting First NPRM – TCB Obligations Consider: Refine & codify PBA procedure Clarify TCB obligations for post-grant checks Require accreditation for all test labs Recognize latest industry testing standards Second NPRM – Administrative Procedures Merge different self-approval procedures Modify permissive change and Software Defined Radio rules Certify modular transmitters for licensed services April 2016 Equipment Authorization Update
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FCC Equipment Authorization Process
Notice of Proposed Rulemaking(NPRM) FCC became Report and Order FCC Released FCC February 15, 2013 Also known as ET Docket 13-44 FCC adopted December 17, 2014 Released December 30, 2014 Published in the Federal Register June 12, 2015 Effective date July 13, 2015 Highlights described in following slides Some changes effective immediately and others have specific transition dates FCC update over 70 KDBs to reflect changes KDB updates continue as transition dates pass April 2016 Equipment Authorization Update
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Equipment Authorization Update
FCC Summary Equipment Authorization Order overview FCC stopped accepting applications for FCC grants for equipment certification on July 13, 2015 TCBs now Certify all equipment Pre-approval guidance (PAG) procedure (formerly Permit but ask) codified and TCB exclusion list eliminated PAG Equipment list and procedures specified in KDB publication TCBs permitted to Dismiss applications not compliant with standards and upload relevant information Limited to applications they approved or been requested to approve Limited to pre-grant and within 30 days after grant Pending system programming Codifies TCB Post Market Surveillance requirements TCBs required to audit 5% of total EMC/Telecom devices they certified annually 1% of devices with RF exposure compliance requirements TCB may request voucher to obtain product from marketplace System programming changes pending to allow TCBs to request devices through FCC website April 2016 Equipment Authorization Update
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Equipment Authorization Update
FCC Summary 2 Additional options for addressing TCB Performance issues: Limit scope of deficient TCB Require all deficient TCB grants to be issued through pre-approval guidance procedures Update rules to reference current ISO/IEC Standards: ISO/IEC 17011:2004 for Accreditation Bodies ISO/IEC 17025:2005 for Accredited Laboratories ISO/IEC 17065:2012 – TCBs must be accredited by 9/15/2015 Update requirements for testing laboratories: Require all Certification and DoC testing to be done at accredited lab that is FCC recognized FCC KDB identifies scopes for recognized labs FCC stopped accepting requests for recognition of new Listed Test Firms on July 12, 2015 Existing recognized labs will remain recognized until July 12, 2016 April 2016 Equipment Authorization Update
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Equipment Authorization Update
FCC Summary 3 Codify requirements for recognition of laboratory Accreditation bodies- 47 CFR 2.949 Current procedures allow FCC to recognize: Domestic accredited labs Foreign accredited labs under the terms of Government to Government Mutual Recognition Agreement (MRA) Alternative arrangements can be recognized by FCC Currently no alternative arrangements recognized New procedures allow same options but do not require that FCC develop procedures to recognize accrediting bodies in non MRA countries If procedures to recognize non MRA country labs are developed they will be published but this is not required by FCC April 2016 Equipment Authorization Update
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FCC 14-208 - Standards Related Issues
ANSI C – Testing Unintentional Radiators Replaces ANSI C and ANSI C version ANSI C only option after July 12, 2016 Any version of the three test standards may be used before July 13, 2016. Limited exceptions to standards identified in KDB publications ANSI C Testing Unlicensed Wireless Devices Replaces ANSI C allowed by DA ANSI C must be used after July 12, 2016. Either standard version may be used before July 13, 2016 ANSI C – RF Measurement Antenna Calibration Required by ANSI C , ANSI C and ANSI C April 2016 Equipment Authorization Update
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FCC 14-208 - Standards Related Issues 2
Delegated authority Provides greater flexibility for FCC/OET to use delegated authority to address minor technical issues related to updating standards for Parts 2, 5, 15 and 18. New standards adoption or major standards revisions must still go through rulemaking process Site Validation when using ANSI C63.4 or ANSI C63.10 30 MHz to 1 GHz - test facilities for radiated measurements required to meet site validation requirements of ANSI C after July 12, 2016 1 GHz to 40 GHz – test facilities can use either site validation option in ANSI C clause 5.5 but after July 12, 2018 the test facility is required to comply with CISPR : April 2016 Equipment Authorization Update
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KDB 974614 Accredited Testing Laboratory Roles and Responsibilities
KDB Publication Last release 6/23/2015 Draft Publication 2/23/ /25/2016 Next final version just after TCBC Workshop Electronic Filing System updates to accommodate scopes in progress Expected completion prior to July 12, 2016 Accreditation Bodies may start assessing test labs to KDB scopes now Existing ~ 380 recognized testing laboratories scopes will need to be updated April 2016 Equipment Authorization Update
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KDB 974614 Accredited Testing Laboratory Roles and Responsibilities
Recognition of accredited testing laboratories Test firms must be accredited to ISO/IEC and the FCC requirements and FCC recognized in order for reports to be valid Testing by external resources/subcontracted must be completed by accredited test firm that is FCC recognized This is an expansion of the requirements in ISO/IEC 17025 TCBs will be required to verify that a test firm is FCC recognized for scope of testing for test reports they accept and authorize Test firms don’t need to be accredited to all scopes but must be accredited to everything within each scope they are accredited for April 2016 Equipment Authorization Update
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Equipment Authorization Update
KDB Draft Publication Review of major comments to draft publication Part 15 Intentional Radiator Scopes Frequency in scope name is highest measured frequency “Partial” Scope Terminology Confusion Scope vs test method/standard Labs in non-MRA countries Petitions for Reconsideration pending KDBs as part of assessed scope KDB updates after assessment * Note that the FCC may not adopt all discussed comments April 2016 Equipment Authorization Update
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KDB 974614 Consideration/Comments
Part 15 Intentional Radiator Scopes Group by measured frequency range or not? Not grouping by measured frequency reduces number of scopes to manage Fewer scopes without range allows more flexibility for test firms and accredited labs but would be more difficult for FCC, TCBs and grantees to identify test firm capabilities FCC website would need information to show scope limitations Free form text fields can be inconsistent and difficult for external users to search FCC received comments on both sides of issue FCC preference to have minimum necessary scopes April 2016 Equipment Authorization Update
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KDB 974614 Consideration/Comments
Scope vs Test Method/Standard Examples based on proposed draft scopes Part GHz Fundamental frequency transmitter test to 10th Harmonic Only scope Part 15 under 26.5 GHz scope needed Part GHz Fundamental frequency transmitter test to 40 GHz Scope Part 15 Transmitter under 26.5 GHz scope and Part 15 Transmitter above 26.5 GHz scope needed For Part 15 Transmitter if test firm only assessed to 26.5 GHz but test standard is valid to 40 GHz, FCC doesn’t consider this a “partial” FCC scope Accreditation body should note any test method/standard limitations on FCC designation information submitted Part 18 Scope has no FCC frequency limit. Test lab has flexibility on range they want to be assessed too Accreditation body should note limitation on FCC designation Test firm can’t test outside assessed scope April 2016 Equipment Authorization Update
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KDB 974614 Consideration/Comments
KDB’s and Accreditation Scope Should KDB’s be assessed to and or listed on scope of accreditation as part of assessment? Lots of comments to FCC on both sides KDBs can change faster than standards which makes it more difficult for AB’s to assess too Should KDB publication date be listed on scope of accreditation FCC proposed in draft allowing test firms to use newer versions of KDB’s until next scheduled assessment unless otherwise directed KDBs provide guidance where standards may not be clear or there isn’t standard available FCC Goal is to only use KDBs when standard not available or clarification of standard needed and remove KDB from scope test method list asap Assessing Test Labs to KDBs give FCC higher confidence level in test labs capabilities April 2016 Equipment Authorization Update
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KDB 974614 FCC modifications under consideration
Updating scopes Minor scope name corrections for clarity Added signal booster scope Part 15 intentional radiator scopes Merging scope tables 1 and 2 Reorganizing some sections for clarity April 2016 Equipment Authorization Update
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KDB 974614 Proposed draft publication scopes for 17025 Labs
Test Method(s) Additional Guidance Part 15, Unintentional Radiators ANSI C Part 18, Industrial, Scientific, and Medical Equipment FCC MP-5 (February 1986) Part 15 Intentional Radiators below 26.5 GHz – except Part 15D ANSI C KDB Publication Part 15 Intentional Radiators above 26.5 GHz - except Part 15D Part 15, Subpart D UPCS ANSI C Part 15 Subpart E UNII with DFS KDB Publication Licensed Radio Service Equipment - Commercial Mobile Services-22(cellular), 24, 25, and 27 ANSI/TIA-603-D (2010) KDB Publication April 2016 Equipment Authorization Update
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Equipment Authorization Update
KDB proposed draft publication proposed scopes for Labs II Scope Test Method(s) Additional Guidance Licensed Radio Service Equipment General Mobile Radio Services-22(non- cellular), 90, 95,and 97 ANSI/TIA-603-D (2010) Licensed Radio Service Equipment - Part 96 Citizens Broadband Radio Service KDB Publication Licensed Radio Service Equipment - Maritime (80) and Aviation (87) Radio Services Licensed Radio Service Equipment - Microwave Radio Services-27, 74, and 101 Licensed Radio Service Equipment - Broadcast Radio Services-73 and 74 RF Radiation Exposure IEEE Std 1528™-2013 KDB Publication KDB Publication Part 20 Hearing Aid Compatibility (HAC) ANSI C ANSI C KDB Publication Part 20 Signal Boosters KDB Publication April 2016 Equipment Authorization Update
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Other KDB updates www.fcc.gov
KDB Publication TCB Roles and Responsibilities Last release 7/31/2015 Draft Publication 12/16/15 – 1/22/2016 Next final version waiting on to be finalized Change summary Clarified ISO/IEC process requirements Application, Application Review, Evaluation, Review and Certification Decision Reorganized and updated text for clarity Added TCB scope reference to accredited lab scopes Added Key Personnel table KDB – Accredited Test Laboratory Technical Assessors Checklist - New version July 31, 2015 Modified scope for focus on C63.4 to newly adopted procedures April 2016 Equipment Authorization Update
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Equipment Authorization Update
FCC NPRM 15-92 ET Docket became Notice of Proposed Rulemaking (NPRM) 15-92 Adopted July 17, 2015 Released July 21, 2015 Comments due by October 9, 2015 Reply comments due by November 9, 2015 Proposals Unifying self approval procedures Modular transmitters Software based capabilities Changes to certified equipment April 2016 Equipment Authorization Update
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Equipment Authorization Update
FCC NPRM II Proposals (continued) Responsible Parties for certified equipment End products with modular transmitters Modification by third parties Repaired and refurbished equipment Imported equipment Information with applications for certification Confidentiality of applications Grant date/publication date/provisional grant April 2016 Equipment Authorization Update
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Equipment Authorization Update
FCC NPRM III Proposals (continued) Update certification and self approval procedures Labeling – E-Label Measurement procedures-Add KDBs Rule consolidation-Remove outdated rules Importation rules Form 740 Customs bonded warehouse Trade show devices allowance for licensed devices Excluded devices- update list Personal use imports- licensed devices April 2016 Equipment Authorization Update
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Public Notice DA 16-348 ANSI C63.26-2015
Public notice requesting comments on whether FCC should adopt ANSI C ANSI C published 1/15/2016 FCC has not adopted yet Comments submitted in FCC NPRM 15-92 DA Released by FCC April 1, 2016 Published in Federal Register April 20, 2016 Comment period ends May 5, 2016 Reply comments period ends May 16, 2016 April 2016 Equipment Authorization Update
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Equipment Authorization Update
Electronic Labeling E-Label Act of 2014/FCC NPRM 15-92 KDB Released July 11, 2014 Allows devices with integrated non removable screens to be electronically labeled Must be able to access: Without special access code In less than three steps in device menu Must be secured and unmodifiable Access instructions must be provided to users Must have physical label for importation and purchase Bulk imports may have adhesive label with conditions April 2016 Equipment Authorization Update
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Equipment Authorization Certification Process Trends
April 2016 Equipment Authorization Update
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Recognition of Accredited Testing Labs Phase I MRA /EMC Arrangement
The US has an operational MRA/EMC arrangement for acceptance of test data with the following countries: Australia Canada Chinese Taipei European Union Hong Kong, China Israel Japan Korea Singapore Vietnam Region Number of Labs FCC Recognized North America 139 Europe 51 Asia 194 Israel 4 Total 388 April 2016 Equipment Authorization Update 26
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TCB/ Phase II MRA Status
MRA’s for mutual acceptance of approvals are operational with the following countries: Canada European Union Hong Kong, China Singapore Japan A total of 38 Telecommunication Certification Bodies (TCBs) have been recognized by the FCC 20 domestic TCBs 18 foreign TCBs April 2016 Equipment Authorization Update 27
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Equipment Authorization Update
Market Surveillance FCC Reviews TCB Grants Requests Samples from Grantees and TCB’s Purchases Samples Focused sampling projects FCC selectively requesting audit test results from TCBs FCC selectively directing some samples to TCBs TCB FCC requires each TCB to audit 5 % of products they authorized annually 1 % RF Exposure if applicable KDB Other General public complaints/testing Competitors complaints/testing April 2016 Equipment Authorization Update 28
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Market Surveillance Audit Issues
FCC Actions Non compliance issues: Require explanation Monetary fines Confiscate equipment Fix equipment TCB Responsibilities Required to report issues to FCC & Grantee and resolutions to FCC Common Issues Applicant Non responsive Grantee code deferral Applicant didn’t produce or market product Applicant may request dismissal April 2016 Equipment Authorization Update 29
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Market Surveillance Summary
Blocked Grantee Codes 172 Grantees blocked in last year Failure to submit samples Invalid contact information Codes unblocked as soon as issue resolved TCBs Surveillance 2015 Required to audit/sample test 1153 devices Reports due January 31, 2015 Reports in process of being evaluated April 2016 Equipment Authorization Update
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Recent Concerns/Issues
RF Exposure Wireless chargers How to test and fit in existing rules Part 15/18 Beam forming chargers 6.78 MHz high power chargers 60 GHz devices 5G (fifth generation) mobile devices HDMI Dongles April 2016 Equipment Authorization Update
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Recent Concerns/Issues II
Standards Under development by ANSI committees ANSI C63.29 – Lighting products ANSI C63.30 – Wireless power transfer products ANSI C63.31 – ISM Equipment (MP-5) April 2016 Equipment Authorization Update
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Equipment Authorization Update
Information On Line Equipment Authorization Webpage Measurement techniques, explanation of EA programs, filing information, MRAs, TCBs, EA announcements, etc.: Procedures for information sharing and distribution Updated Interpretation Database & new contact desk for web based inquiries: OET Info on line (Orders, Public Notices, etc.) FCC Rules and Regulations: General FCC Information: FCC MRA Webpage April 2016 Equipment Authorization Update 33
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Equipment Authorization Update
Questions and Answers Thanks! April 2016 Equipment Authorization Update 34
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