Tag Archives: Transmitter

Certifying Unlicensed Transmitter Products in Canada

“We are selling our part 15 unlicensed transmitter products successfully in the US.   Our certification testing, reports, declarations, and labels are all consistent with FCC requirements, and we have an interest in selling our products in Canada. What do we need to do?”industrycanada

Canadian electronic product compliance law is fairly consistent with US law, which makes selling electronic products into Canada relatively straight forward. While in the US unlicensed transmitters need to be certified with the FCC, in Canada unlicensed transmitters need to be certified through “Industry Canada” authorities.

While in the US, product certification requires using independent “Telecommunication Certified Body” (TCB) contractors, engineers on staff within Industry Canada validate and certify product documentation directly. This means that certified test labs in the US who are registered with Canada can file certification data and documentation directly.

While US and Canadian emissions data and reporting requirements are similar, they are not exactly the same. For example, Canadian law requires that signal bandwidth be measured and reported in a slightly different manner. Canadian laws are also more specific with regard to instrument settings when measuring emissions.   Additionally, documentation filed with Canada generally needs to cite applicable Canadian laws and standards. The bottom line is that reports written for FCC compliance usually require some “tweaking” to meet Canadian requirements.

With regard to product certification, Canadian law requires that a “Canadian Contact” be included with the registration. A Canadian Contact is a company that is willing to assume direct contact responsibilities within Canada for any questions or complaints initiated after the product is certified.

Also, Canadian labeling requirements apply in addition to FCC, and user manual documentation needs to include compliance information in both French and English languages.

At SEI, we can help guide you through the certification process in the US, Canada, Europe, and beyond. One of the services we provide is product test planning, to help bring your product to market as quickly and as cost efficiently as possible. Give us a call to request a quote for product prescreen and debug, test and certification planning, and certification testing and report services through AHD or a certified test lab of your choice.

Using Certified Transmit Modules in Electronic Products

Incorporating modules that have already been FCC certified can be a good way to introduce wireless functionality into a product line. While the use of pre-certified modules simplifies the compliance testing process, several factors must be considered.

Certified modules have grant conditions associated with them. The grant conditions for a device are an_rko_radio_picture___extended___rocky_horror_by_deviever-d5b7ex8supposed to be documented in the device user manual, but they can also be found by looking up the device FCCID Form 731 on the FCC website. Grants usually include restrictions on antennas, operational duty cycle, and the intended usage model of the device, including collocation of the device with other transmitters and end user exposure to rf signals.

At minimum, an end product incorporating a wireless module still requires emissions testing, an emissions report, and appropriate FCC labeling prior shipping in US. If the module is used in a manner consistent with the module’s grant conditions, FCC part 15 subpart B unintentional radiator testing and documentation is required. FCC regulation 15.212 describes how labels must identify certified modules used internal to the end product.

If the module is collocated with another transmitter closer than either transmitter grant allows, or if the module is used in a manner inconsistent with its grant (i.e a mobile device grant used in a user extremity exposure configuration), additional testing and documentation must be provided to prove that EMC and end user rf exposure limits are not exceeded. EMC testing would include scanning for intermodulation noise products, and at minimum SAR exclusion thresholds for the collocated transmitters must be calculated. See KDB 447498 D01 for information about SAR testing and exclusion requirements.

If testing and calculations prove that transmitter performance is not degraded, the testing described above would be consistent with a Class 1 Permissive Change, which does not require filing with the FCC. Documentation for Class 1 configuration changes should be forwarded to the module manufacturers.   See FCC regulation 2.1043 and KDB 178919 for more information regarding Permissive Changes.

If a module is modified in a manner that increases its output power, a new FCCID is required for the device. This can be filed by either the end product manufacturer or the module manufacturer. A full suite of transmit performance tests are required specific to the operating frequency and mode of the module.

If a module is used in a manner that is inconsistent with the grant and degrades the performance of the module, including changes to the antenna or operational parameters, then a class 2 permissive change may be necessary for the module.

Class 2 permissive changes are required to be filed by the certified module manufacturer. If the module manufacturer does not wish to file the change, the end product manufacturer can request a cover letter from the module manufacturer granting permission to file the change. If the module manufacturer is not willing to give the end product manufacturer permission to file the change, then the end product manufacturer must obtain a new FCC ID. For more information regarding transmitter module equipment authorization, see the FCC KDB 996369 document.

In conclusion, while use of certified transmit modules in end user products can simplify the compliance process, care must be taken with regard to grant restrictions associated with the module. Factors such as antenna usage, operational duty cycle, intended usage model of the device, and collocation of the device with other transmitters all affect what testing and documentation is required before marketing a device in the US.

The contributions towards this discussion from Jeff Woods CB Manager at ACS test labs and Gordon Helm at AHD test lab are greatly appreciated. Feel free to comment on this and other upcoming blogs. The interpretation of rules and regulations with regard to EMC compliance test rules are often conflicting and confusing, and certainly warrant discussion.