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Latest News in Testing, Inspection and Certification

NTS News Center - Latest News in Testing, Inspection and Certification

Upcoming Changes for Wireless Equipment – EN 301 489-x

EN 301 489 series of standards for EMC testing of radio equipment are being revised. Although these EMC standards are intended for radio equipment, they are not planned to be listed in the Official Journal of the European Union under the Radio Equipment Directive 2014/53/EU (RED). Depending on your risk analysis results, the use of the new versions of the EN 301 489-x standards may fully cover the essential requirement of article 3.1(b) of RED for all types of radio equipment.

Depending on the results of the risk analysis, manufacturers should follow the new version of EN 301 489-1 and the particular EN 301 489 standard requirements and update their test reports for their current products as soon as possible. Testing may be necessary since there may be changes in the requirements. In particular, the radiated immunity frequency range for many but not all products has been extended to 6 GHz.

Manufacturers of radio equipment can use the R&TTE Directive – 1999/5/EC (Radio and Telecommunication Terminal Equipment Directive) and it’s harmonized standards, such as EN 301 489-1 V1.9.2 and EN 301 489-3 v1.6.1 in their Declaration of Conformities (DoC) until June 12, 2017.

After this date, manufacturers of any radio device who places product on the market in any country which requires CE marking, have to use RED (Radio Equipment Directive 2014/53/EU) in their DoC. This is applicable for all new products as well as for products that are currently being marketed and intended to be placed on the market after this date. Products with DoCs that are not updated to the RED are not to be placed on the European Union market after June 12, 2017.

Upcoming Changes for Transmitters and Receivers for Private Mobile Radio (PMR) service in the European Union. EN 300 113

By Deniz Demirci, Senior Wireless / EMC Engineer, NTS Silicon Valley

Manufacturers of radio transmitters and receivers used in stations in the Private Mobile Radio (PMR) service, operating on radio frequencies between 30 MHz and 1 GHz, intended for sale in the EU should take note of some important changes.

Currently, manufacturers of these type of equipment can still use the R&TTE Directive 1999/5/EC (Radio and Telecommunication Terminal Equipment  Directive) and it’s harmonized standard EN 300 113-2 V1.5.1 in their Declaration of Conformities (DoC) until June 12, 2017. After this date, manufacturers of any radio device that enters any country which requires CE marking, have to use the RED (Radio Equipment Directive – 2014/53/EU) in their DoC. This is applicable for all new products as well as for products that are currently being sold and are intended to be placed on the market after this date. Products for which DoCs are not updated to the RED are not to be placed on the European Union market after June 12, 2017.

The new version of the standard for Radio Equipment Directive was published in the ETSI web site as EN 300 113 V2.2.1 and it is listed in the Official Journal (OJ) of the EU (Harmonized).

Our recommendation to manufacturers is to schedule tests for the new requirements as soon as possible in order to update their test reports for the new directive.

The receiver performance requirements in the standard, which were not part of essential test suites before, are now unconditionally applicable to all receivers and transceivers in order to align with the Article 3.2 of the directive.

The new essential receiver test suits are;

  • Receiver maximum usable sensitivity1.
  • Receiver error behavior at high input levels.
  • Receiver co-channel rejection.
  • Receiver adjacent channel selectivity1.
  • Receiver spurious response rejection.
  • Receiver intermodulation response rejection.
  • Receiver blocking or desensitization.
  • Duplex operation receiver tests.

Note 1: The tests have to be repeated in extreme voltage and temperature conditions with every available channel spacing and modulation.

Manufacturers who cannot or decide not to use harmonized radio standards in their DoCs must have a Notified Body Type Examination & Certificate in order to presume compliance with the directive. The Notified Bodies have to follow Article 3.2 of RED in their type examination evaluations and will ask for evidence of presumption of conformity which must include a demonstration that the product meets the requirements of the directive which includes spectrum protection measures such as the performance characteristics of receivers.

Upcoming Changes for Wireless Equipment operating in the 2.4 GHz Band EN 300 328

By Deniz Demirci, Senior Wireless / EMC Engineer, NTS Silicon Valley

EN 300 328 V2.1.1 was harmonized and listed in the Official Journal of the European Union under Directive 2014/53/EU for RED (Radio Equipment Directive) on January 13, 2017. This version of the standard covers the essential requirements of article 3.2 of RED for 2.4 GHz ISM band WiFi, Bluetooth, and other Wideband transceivers.

Manufacturers of these types of equipment can still use the R&TTE Directive – 1999/5/EC (Radio and Telecommunication Terminal Equipment Directive) and its harmonized standard EN 300 328 V1.9.1 in their Declaration of Conformities (DoC) until June 12, 2017.

After this date, manufacturers of any radio device who enter any country which requires CE marking, have to use the RED (Radio Equipment Directive 2014/53/EU) in their DoC.

This is applicable for all new products as well as for products that are currently being marketed and intended to be placed on the market after this date. Products which DoCs are not updated the RED are not to be placed on the European Union market after June 12, 2017.

Manufacturers should follow EN 300 328 V2.1.1 requirements and update their test reports for their current products as soon as possible since there is significant change in the essential requirements.

  • The Receiver Blocking requirement is unconditionally applicable to all radio equipment regardless of receiver category or adaptivity capability. This is a major change from the previous version of the standard.

Since the Receiver Blocking was previously conditionally applicable to the adaptive equipment only and the test methods as well as the performance criteria were different, most products may have never been evaluated for this requirement before.

Note:  After June 12, 2017, any radio device which the standards are not yet harmonized and listed in the Official Journal of the European Union, must have a Notified Body Opinion/Type Examination Certificate in order to presume compliance with the essential requirements in Article 3.2 of Directive 2014/53/EU – RED.

Upcoming Changes for Wireless Equipment operating in 5 GHz Bands in the European Union EN 301 893

Manufacturers of wireless devices operating in the 5 GHz bands intended for sale in the European Union (EU) should take note of some important changes.

Manufacturers of these types of wireless equipment can still use the R&TTE Directive 1999/5/EC (Radio and Telecommunication Terminal Equipment  Directive) and it’s harmonized standard EN 301 893 V1.8.1 in their Declaration of Conformities (DoC) until June 12, 2017. After this date, manufacturers of any radio device that enters any country which requires CE marking have to use the RED (Radio Equipment Directive – 2014/53/EU) in their DoC. This is applicable for all new products as well as for products that are currently being sold and are intended to be placed on the market after this date. Products for which DoCs are not updated to the RED are not to be placed on the European Union market after June 12, 2017.

An issue with just declaring compliance with the RED as it is, that a RED harmonized version of EN 301 893 will not be listed in the Official Journal (OJ) of the EU by June 13, 2017. v2.1.0 of the standard is still in review and is scheduled to be published by ETSI on June 6, 2017 as v2.1.1. Harmonization is not expected (i.e. listed OJ) until September 19, 2017

Our recommendation to manufacturers is to schedule tests for the new requirements as soon as possible since test methods are significantly different.

Some of the changes are:

  1. Adaptivity has 3 different mandatory Interference signal types (AWGN, OFDM and LTE). Medium Access test methods have changed significantly. There are new procedures for Frame Based (other than 802.11) devices.
  2. The Receiver Blocking requirement is a new performance test applicable to all radio equipment.

With the absence of a harmonized version of this product standard, after June 12, 2017, any 5 GHz radio device must have a Notified Body Type Examination & Certificate in order to presume compliance with the Article 3.2 of the RED. Notified Bodies have to follow Article 3.2 of RED in their type examinations and will ask for evidence of presumption of conformity which must include a demonstration that the product meets Receiver Blocking requirements that are part of v2.1.0 of EN 301 893.

The new Adaptivity requirement as developed for the RED version of EN 301 893 is not aimed to address RED receiver requirements but future coexistence scenarios such as LTE-U which is not expected to be mass-marketed until 2018. Thus manufacturers can chose to submit the test cases to cover all the requirements of v1.8.1 version of the standard and receiver blocking testing of v2.1.0 for their Notified Body Type Examination applications until June 12, 2018.

When v2.1.1 is listed in the OJEU, the manufacturers will not have to have Notified Body Type Examination & Certificate if they follow this harmonized version of the standard but may still chose to use the Notified Body option to exclude new (enhanced) Adaptivity requirements until June 12, 2018.

Upcoming Changes for Wireless Equipment in the 5 GHz Band EN 301 893

By Deniz Demirci, Senior Wireless/EMC Engineer, NTS Silicon Valley 

Manufacturers of wireless devices operating in the 5 GHz bands intended sale in the EU should take note of some important changes.

Draft version of EN 301 893 V2.0.7 has been published in the ETSI web site in order to align with the Article 3.2 – Essential Requirements of Radio Equipment Directive 2014/53/EU.

Currently, manufacturers of these type of equipment can still use R&TTE Directive 1999/5/EC (Radio and Telecommunication Directive) and it’s harmonized standard EN 301 893 V1.8.1 in their Declaration of Conformities (DoC) until June 13, 2017.

After this date, manufacturers of any radio device who enters any country which requires CE marking, have to use RED (Radio Equipment Directive 2014/53/EU) in their DoC.

This is applicable for all new products as well as for products that are currently being marketed and intended to be sold after this date. Products which DoCs are not updated by this date, should not be sold in the European Union.

It is very likely that any RED version of EN 301 893 will not be ready and will not be listed in the OJ on June 13, 2017. The version V2.0.7 of the standard is still in review process and is scheduled to be published on July 8, 2017. The standard is expected to be listed on the Official Journal of the European Union on October 21, 2017.

With the absence of this product standard, there is a possibility that EN 301 893 V1.8.1 may be listed in the OJ with additional Adaptivity and Receiver Blocking requirements aligned with 301 893 V2.0.7 in order to presume compliance with RED until the new version of the standard is published.

Otherwise, after June 13, 2017, any 5 GHz radio device must have a Notified Body Opinion/Type Examination Certificate in order to presume compliance with the Article 3.2 – essential requirements of Directive 2014/53/EU – RED. Which means that, overwhelming number of products on the market will require Notified Body Opinion.

The Notified bodies also have to follow Article 3.2 of RED in their assessments and will ask for evidence of presumption of conformity which will include Adaptivity and Receiver Blocking tests.

Our recommendation to the manufacturers is to schedule the tests for the new requirements as soon as possible since the test methods are significantly different.

Some of the major changes are:

  1. Adaptivity has 3 different mandatory Interference signal type (AWGN, OFDM and LTE). Medium Access test methods have changed significantly. There are new procedures for Frame Based (other than 802.11) devices.
  2. The Receiver Blocking requirement is a new performance test and unconditionally applicable to all radio equipment.

Please contact us at sales@nts.com or call 800-270-2516 for additional details and how to test your product and update test reports for Radio Equipment Directive.

Changes for Medical Equipment IEC 60601-1

UL 60601-1 and CAN/CSA C22.2 No. 60601-1

With the publication of the fourth edition of IEC 60601-1-2 [1] and its European equivalent, EN 60601-1-2 [2] being listed in the Official Journal, the EMC requirements for medical electronic devices changed. Products that will remain in production after the mandatory effective date of December 31, 2018 may require redesign to comply with the requirements of the fourth edition. Changes in design will also affect the FDA approval. Even if no changes are required, testing will need to be performed to assess the product’s performance in light of the expanded scope of testing of this new edition for the EU. There is no grandfathering of equipment that was assessed using the third edition of the standard in the EU. A presumption of conformity with the essential requirements of the Medical Device Directive (MDD) may only be assumed if the new edition is employed after the transition date. For the sake of brevity, whenever I refer to the standard, I am talking about the fourth edition of IEC 60601-1-2 and EN 60601-1-2.

Test Requirements: Emissions

The emissions requirements are found in Table 2 of the standard and cover conducted and radiated emissions using the limits and methods of CISPR 11, harmonic distortion using IEC 61000-3-2 and voltage fluctuations and flicker using IEC 61000-3-3. The application of IEC 61000-3-2 and IEC 61000-3-3 depends on the use environment. Different requirements may be necessary based on other uses, such as in transportation.

Test Requirements: Immunity

Performance Requirements

As you read the standard, you eventually get to the section on immunity requirements for ME equipment and systems. The test levels to be used are described in the standard for two types of environments. Use of higher or lower values may be used depending on the outcome of the risk management process.

At first glance, you may decide that degradations of performance are not allowed during the tests and that your product will not be able to meet a performance criteria without a significant redesign. However, as stated, the intent of this section is to describe these degradations in light of the Essential Performance and Basic Safety of the product being tested. The product is allowed to exhibit degradations that do not affect Essential Performance and safety during the tests.

Basic Safety and Essential Performance

What are Basic Safety and Essential Performance? These are defined terms in the standard IEC 60601-1. Basic Safety is “freedom from unacceptable risk directly caused by physical hazards when ME equipment is used under normal condition and single fault condition.” Essential Performance is “performance necessary to achieve freedom from unacceptable risk.” According to the standard, a risk management process shall be used to identify risks from electromagnetic disturbances in addition to any other risks.” Annex F provides additional guidance for including the risks from electromagnetic disturbances in the risk management process described in ISO 14971. The risk management report produced by the process provides the description of pass fail criteria for each function of the product and how the basic safety and essential performance will be monitored during each immunity test. This information is incorporated in the EMC test plan. This test plan is required prior to starting any EMC testing. An example is provided in Annex G of the standard.

The implication here is that you should perform a risk analysis (see Annex F of the standard for more details) prior to establishing the compliance criteria to avoid the need to perform more tests against more stringent criteria. Depending on the class of device as determined from Annex I of the medical device directive, a notified body will likely need to be consulted in determining the performance criteria to apply based on the risk analysis. The establishing of the performance criteria is crucial to evaluating the observations made of product operation during immunity tests and in determining the methods used to monitor the product. The risk analysis must account for all manners of use of the product. After assessing all the risks and determining the residual risk level, you enumerate the compliance criteria. Examples of criteria can be found in Annex I of the standard.

Tests

Now that you have established the compliance criteria you will use during the immunity tests, you are ready to test. Not so fast. The standard requires a completed test plan be prepared prior to the start of formal testing. The recommended content of the test plan is given in Annex G of the standard. The standard includes the normal set of immunity tests that are to be applied and describes test levels for special environments in Annex E. The tests are the same tests that are applied for other products such as radio equipment, networking equipment and information technology equipment except that the standard incorporates some specific test application guidance notes that require special consideration. Tables 4 through 8 list the immunity tests applicable to medical devices and the basic levels for both professional healthcare facility and home healthcare environments.

The list may include additional tests and the test specification column may change based on the type of equipment to be evaluated and particular standard that would therefore apply. It is beyond the scope of this paper to present the appropriate specifications for all medical devices. However, some examples can serve to illustrate the point. EN 60601-2-24, particular to infusion pumps, modifies the test specifications: radiated immunity test level changes to 10 V/m even if the product is for professional healthcare environments; magnetic immunity test level increases to 400 A/m. EN 60601-2-10, particular to nerve stimulators, adds that patient leads are to be placed in saline solution during testing. EN 60601-2-2, particular to HF surgical equipment, modifies the compliance criteria and the emissions test configuration.

To evaluate the DFS functions of a system the regulatory standards describe waveforms to be used when evaluating DFS. These waveforms are defined in terms of the number of pulses, the pulse width and the pulse repetition frequency (or period) for the radar signal. The pulses may be modulated with an FM chirp, and may contain pulses of different widths and different periods.  Manufacturers should always bear in mind that their radar detection algorithms should be designed to detect all radar systems.

Table 1: Immunity Tests
Environmental Phenomena Test Specification Test Setup
Electrostatic Discharge ±8kV (Contact)

±2, 4, 8, 15kV (Air)

EN 61000-4-2
RF Fields 80 – 2700 MHz

3V/m (professional healthcare facilities) or 10V/m (home use)

80% AM, 1 kHz

EN 61000-4-3
RF Proximity fields Various frequencies up to 28 V/m EN 61000-4-3
Fast transients

Power

Signal

5/50ns, 100 kHz

±2.0 kV

±1.0 kV

EN 61000-4-4
Surges

Line to PE

Line to Line

Outdoor SIP/SOP

1.2/50μS

±0.5, 1.0 & 2.0kV

±0.5 & 1.0 kV

± 2 kV line to ground

EN 61000-4-5
RF Voltage (Conducted Immunity) 0.15 – 80 MHz

3V (6V in some frequency ranges)

80% AM, 1 kHz

EN 61000-4-6
Magnetic Fields* 50 Hz

30A/M

EN 61000-4-8
Voltage Dips 100%, 0.5 cycles at various phase angles

100%, 1 cycle

30%, 25/30 cycles

EN 61000-4-11
Voltage Interruption 100% for 250/300 cycles EN 61000-4-11
*Applies only if the product has magnetically sensitive components or circuity

 

The standard has higher test levels for ESD and magnetic field immunity, magnetic field immunity may not be needed, additional RF field immunity requirements with potentially higher levels and additional VDI requirements compared to the previous edition. It also makes clear the need for a test plan prior to testing. Depending on the product, the test plan may need to include other tests or test levels that will also need to be evaluated based on the intended use of the product.

Basic Immunity Test Modifiers

For some of the immunity tests, the standard specifies modifications to the methods of the basic standards listed in table 1 above.

For example:

The dwell time at each frequency step for conducted and radiated immunity must be set to allow the product to be fully evaluated at each step. Dwell times exceeding 15 seconds are not uncommon.

Electrical fast transient tests are not performed on patient cables.

During conducted emissions, electrical fast transient/burst and conducted immunity tests, patient coupled parts shall be terminated with artificial hands.

CDNs shall not be used for conducted immunity tests on patient leads.

Power input voltage and frequency are specified for each test in Table 1 of the standard. In most cases, the tests are performed at one voltage and one frequency from the ranges of voltage and frequency for which the product is rated. Voltage dips and short interruption tests shall be performed at the minimum and maximum rated voltages if the product has rated voltage range ≥ 25% of the minimum rated voltage.

Product Information

Assuming that you have performed all of the appropriate emissions and immunity tests using the compliance criteria specified in the test plan with acceptable results, the requirements of the standard are still not yet fulfilled. The standard requires information about EMC to be included in the instructions furnished to the user. These can be found in Clause 5. The tables of information there were part of the third edition of the standard are not included in the fourth edition.

The instructions shall also provide technical information such as compliance information for each test and test levels for immunity. The justification for using the levels other than described in the standard shall be provided in the instructions. Instructions necessary for maintaining BASIC SAFETY and ESSENTIAL PERFORMANCE with regard to electromagnetic disturbances shall also be provided.

Radio Functions in Medical Devices

If a radio is provided with the product either internally or as a separate unit, the radio part of the device or system may only need approval against the applicable radio standards. However, if the function of the radio affects the essential performance of the system, then the radio and medical device both must be evaluated for immunity using the medical equipment standard.

The emissions of the radio part must comply with the medical equipment standard except in the dedicated transmission band. This means that spurious emissions of the radio must meet the CISPR 11 limits, which in most cases are more restrictive than the spurious emissions limits for the radio device.

Summary

The new edition of EN 60601-1-2 presents many challenges to manufacturers. From the beginning of the design process, manufacturers are encouraged to seek assistance from test labs and certification agencies to understand the provisions of EN 60601-1-2 as they apply to their specific product.

References

[1] IEC 60601-1-2:2014, International Standard for Medical electric equipment – Part 1-2: General requirements for basic safety – Collateral standard: Electromagnetic compatibility – Requirements and tests.

[2] EN 60601-1-2:2015, European Standard for Medical electric equipment – Part 1-2: General requirements for basic safety – Collateral standard: Electromagnetic compatibility – Requirements and tests.

Upcoming Changes for Wireless Equipment in the 2.4 GHz Band EN 300 328

By Deniz Demirci, Senior Wireless/EMC Engineer at NTS Silicon Valley

EN 300 328 V2.1.1 was harmonized and listed in the Official Journal of the European Union under Directive 2014/53/EU for RED (Radio Equipment Directive) on January 13, 2017. This version of the standard covers the essential requirements of article 3.2 of RED for 2.4 GHz ISM band WiFi, Bluetooth and other Wideband transceivers.

Manufacturers of these type of equipment can still use R&TTE Directive 1999/5/EC (Radio and Telecommunication Directive) and it’s harmonized standard EN 300 238 V1.9.1 in their Declaration of Conformities (DoC) until June 13, 2017.

After this date, manufacturers of any radio device who enters any country which requires CE marking, have to use RED (Radio Equipment Directive 2014/53/EU) in their DoC.

This is applicable for all new products as well as for products that are currently being marketed and intended to be sold after this date. Products which DoCs are not updated by this date, should not be sold in the European Union.

Manufacturers should follow EN 300 328 V2.1.1 requirements and update their test reports for their current products as soon as possible since there is significant change in the essential requirements;

  • The Receiver Blocking Requirement is unconditionally applicable to all radio equipment regardless of receiver category or adaptivity capability. This is a major change from the previous version of the standard.

Since the Receiver Blocking was conditionally applicable to the adaptive equipment only and the test methods as well as the performance criteria were different, most products may have never been evaluated for this requirement before.

Note: After June 13, 2017, any radio device which the standards are not yet harmonized and listed in the Official Journal of the European Union, must have a Notified Body Opinion/Type Examination Certificate in order to presume compliance with the essential requirements in Article 3.2 of Directive 2014/53/EU – RED.

For more details and information on how to update test reports for the Radio Equipment Directive, other specification interoperability scenarios or test, design and engineering help is available by contacting NTS at 800-270-2516 or emailing sales@nts.com.

Dynamic Frequency Selection (DFS) in 5GHz Unlicensed Bands

An Overview of Worldwide Regulatory Requirements

The advent of the 802.11a wireless market and the constant push to open up spectrum for unlicensed use required that a mechanism be implemented for spectrum sharing. Dynamic Frequency Selection (DFS) is the mechanism that was adopted to allow unlicensed devices to use the 5 GHz frequency bands already allocated to radar systems without causing interference to those radars. The concept of DFS is to have the unlicensed device detect the presence of a radar system on the channel they are using and, if the level of the radar is above a certain threshold, vacate that channel and select an alternate channel.

The regulatory requirements for DFS, along with requirements along with Transmit Power Control (TPC), have been adopted in Europe, the United States of America, and many other geographical areas. The following is an overview of the current DFS requirements for Europe, the USA, Canada, Taiwan, Australia, and Japan.

Click here to download and review this white paper.

Challenges of Meeting Dynamic Frequency Selection (DFS) Requirements

Dynamic Frequency Selection (DFS) requirements for products that operate in certain 5 GHz bands are now firmly established in most regions of the world. DFS is a mechanism that allows sharing of spectrum with radar systems operating in the 5250-5350 MHz, 5470-5725 MHz and in some regions of the world 5725-5850 MHz of the RF spectrum. Regulatory authorities required this sharing mechanism when the decision to open this spectrum up for uses like WiFi was adopted. The mechanism needed to verify that a channel is free of radar before using it, monitoring a channel for radar once a channel is in use, vacating the channel if radar is detected and remain off of a channel on which radar has been detected.

In some cases, the requirements have continued to evolve. For example, last year the FCC updated their testing procedures (KDB 905462 D02) for the Bin 5 radar type waveform to use a fixed width chirp in a given trial and changed which frequencies are used for each trial in the statistical performance check.

A continuing challenge is the requirement that the FCC pre test all products that are required to detect radar transmissions prior to a grant of equipment authorization being issued by a Certification Body. Depending on the FCC workload this can delay FCC certification by 1-3 months.

Since DFS compliance is primarily related to the software controlling a radio, it is necessary to involve software development personnel in DFS evaluation process that includes debug of issues found during testing. In addition, a description of how the product software that controls the radio DFS functions is secured to prevent tampering with by users of the product is necessary for product approval.

DFS testing involves different operation of the radio from other certification testing. Normal product operation with the added ability to restrict DFS functions and report detections are needed (KDB 905462 D04). Testing will proceed more quickly if a complete setup typical of actual use with the device configured to communicate with another product in a manner that produces a sufficiently high use of the channel (typically 17-30%). Additional information needed for performing the tests are the modes of operation, 99% bandwidth for each mode and antenna types and gains (testing with the lowest gain antennas is required).

If you have any questions regarding the best methods to ensure your DFS test session is successful to gain compliance, ask our experts or call 800-270-2516.

FCC 5GHz UNII Rule Changes

Will the FCC Extend the June 2, 2016 Deadline?FCC Recognition

Our FCC certifications team has received many questions related to the FCC 5GHz rule changes implemented in FCC Report & Order 14-30, June 2014.

The FCC issued a Memorandum Opinion and Order (MO&O) – FCC 16-24 – on Wednesday March 2, 2016 that has added to the confusion.

The most often asked question: Is the FCC going to delay the June 2, 2016 deadline for all devices (new and older devices still being sold) to be approved using the new rules?

Answer:  No.  Come June 2, 2016 all 5GHz unlicensed devices still shipping must be approved using the FCC rules issued in June 2014.

The MO&O issue addressed spurious emissions limits for the 5725-5850MHz band.  This was a point of contention when the rules were updated to change the rule part under which devices using the this band were approved.  There has been an ongoing discussion between manufacturers and the FCC regarding this band.  Previously, most manufacturers approved their devices that operated in this band using the limits published in FCC §15.247.  The 5 GHz rule update made the limits more restrictive, specifically at the band-edges, and greatly impacted manufactures that used higher gain antennas intended for long distance links.

Manufactures that performed permissive changes to update to the new rules usually had to reduce power for channels at the edge of the band from their original approvals.

Under the MO&O, issued last week, the FCC is updating the rules to allow two different options for showing compliance with the spurious emission requirement for UNII devices operating in the 5725-5850MHz band (UNII-3 band).  One option is a mask that is less stringent than the current requirement.  This is the long term requirement.  The second option is a temporary option that allows manufactures to revert to the 15.247 limit in the rules prior to June 2014 for spurious emissions.  How temporary depends on the gain of the antennas used.  Devices with antennas >10dBi have until March 2, 2018 to update their approval to the mask.  If their antenna gain is <10dBi, they have until March 2, 2020 to update to the mask.

The MO&O can NOT be used for certification yet.  The updated rules need to be first published in the Federal Register and then there is a 30 day delay before TCBs can approve applications using either of the options.  When the MO&O will get published in the Federal Register is unknown.

Options for New Devices Seeking Authorization

For new devices seeking authorization, manufactures have a few choices at this time on how to test the UNII-3 band:

  1. Use the current (aka – new 5GHz rules, from 2014).
  2. Use the mask, and understand that certification will have to wait for the rules to go into effect.
  3. Use the 15.247(d) limits, knowing they will need to update their approval in the future (if still shipping), and understand that certification will have to wait for the rules to go into effect

Devices currently approved using the “old” rules, with the 5725-5850MHz band approved under the DTS/15.247 rules, still need to get updated to the new rules by June 2, 2016 or stop shipping.  The options are:

  1. Test the 5725-5850MHz band against the most stringent June 2014 UNII limit.  Reduce power, and file a Class II Permissive Change (C2PC)
  2. Test the band against the new mask.  File a C2PC once the rules go live
  3. Use the old 15.247 report (Note: we are still waiting confirmation from the FCC that this would be allowed), no testing, and file a C2PC once the rules go live.  This would give manufactures a couple of years to deal with the change.  It is likely that the FCC will require a new report with 15.407 references to be submitted.

An additional note, this does not address any of the other requirements that need to be met for the new rules (UNII-1, DFS, software security) that still need to be met by June 2, 2016. These must be included in new and C2PC filings.

For more information, please contact us at (800) 270-2516 or via email to sales@nts.com. If you would like to book your testing prior to the deadlines, please use our Request a Quote form for the quickest response.