Trying to determine the requirements for a new or unfamiliar radio device can be challenging. By becoming familiar with the structure of the FCC regulations and by following a few simple procedures, it is possible to identify the appropriate test and filing requirements for most radio devices regulated by FCC.

The rules are divided into parts 0 through 101, which are organized into four subchapters (A, B, C, and D). The subchapters are published in five separate volumes in book format. New versions are available from the U.S. Government Printing Office in February or March each year. Each volume includes current regulations adopted by October 1 of the previous year. Table I provides a summary of the rule sections applicable to radio-transmitter certifications.

The table of contents of each rule section is useful for determining the types of equipment covered by the section. Most rule parts have a descriptive heading such as "Technical Standards" or "Equipment Authorization."

The individual rule parts address specific services or product classes. Part 2 of the rules contains global requirements that must be met for all types of devices subject to equipment authorization. Subpart J of Part 2 is titled "Equipment Authorization Procedures" and is the logical place to begin searching for equipment authorization requirements. Three procedures are described as verification, declaration of conformity, and certification. For equipment subject to verification, manufacturers must perform testing to verify that the equipment meets the technical requirements. No submission is made to FCC. Declaration of conformity is similar to verification in that no submission is required; however, testing must be performed only by those laboratories accredited as required by paragraph 2.948 of the rules.

Certification Requirements. The certification procedure is required for nearly all radio transmitters, whether for licensed or unlicensed operation. The requirements for certification begin at paragraph 2.1031. FCC form 731 must be filed for each unique product identifier, and a unique FCC identifier is required on the product label. Product documentation must accompany the application, fees must be submitted, and descriptions of the required test data must be provided. Paragraph 2.1033(b) lists the requirements for devices regulated by parts 11, 15, and 18. Paragraph 2.1033(c) lists the requirements for applications for equipment types other than those operating under Part 15 or Part 18.

Measurement Procedures. For Part 15 and Part 18 devices, measurement procedures are specified in the rules governing particular devices. In addition, devices must meet the requirements for radio-frequency (RF) radiation exposure in paragraph 2.1091 and 2.1093 as applicable. For devices subject to other rule parts, test requirements are described in the paragraphs listed in paragraph 2.1041. The following paragraphs list measurement data requirements for devices regulated under rule parts other than Part 15 or Part 18:

Paragraph 2.1057 specifies the frequency spectrum to be investigated for the spurious emissions tests described in paragraphs 2.1051 and 2.1053. For devices operating below 10 GHz, emissions measurements are made from the lowest RF signal generated up to the 10th harmonic or 40 GHz, whichever is lower. For devices operating between 10 and 30 GHz, the upper limit for investigation is 5 fo (operating frequency) or 100 GHz, and for devices operating above 30 GHz, the upper limit is 5 fo or 200 GHz, whichever is lower.

The procedures and measurements described in Part 2 are required for all applicable products, including those for which the individual rule parts seem to provide an exemption. For instance, paragraph 90.217 exempts certain low-power transmitters from the technical standards required elsewhere in Part 90, but all testing required by Part 2 must be performed, and data must be submitted along with the application for certification.

Applications for certification must be submitted electronically. Required exhibits must be in one of the following electronic file types: Adobe Acrobat (.pdf), JPEG, Microsoft Excel, Microsoft Word, WordPerfect, or plain text. FCC requires up to 13 different exhibit types. The number of exhibits required for a submittal depends on the type of equipment for which authorization is sought.

For most equipment types, an alternative route to certification is now available. FCC has appointed a number of test laboratories as telecommunications certification bodies (TCBs). Most TCBs have Web sites similar to FCC's for submitting an application for certification. They require similar attachments. TCBs issue a grant that appears on the FCC Web site and is, in fact, the official FCC grant for the product. Review time for TCBs varies; applications typically take 2–3 weeks to clear. Expedited service can be requested.

It is important to realize that FCC has retained exclusive jurisdiction over some equipment—such as customer-premises equipment in the multipoint and multichannel multipoint distribution system (MDS/MMDS) services—and that TCBs may have more-stringent limitations for issuing grants in certain other equipment categories. FCC has published a list that outlines what types of products TCBs are excluded from granting. High-power transmitters and transmitters that require specific absorption rate (SAR) evaluation under the RF exposure requirements in paragraphs 2.1091 and 2.1093 (as applicable) are currently excluded from TCB approval. A TCB can provide a copy of this exclusion list so that a manufacturer can determine whether the TCB can certify certain equipment. These restrictions and TCB exclusions must be weighed against the benefit of receiving certification grants more quickly.

Once FCC publishes a revised version of OET Bulletin 65 (Evaluating Compliance with the FCC Guidelines for Human Exposure to Radio-frequency Electromagnetic Fields) and the TCBs have completed training, the exclusion list will be eliminated. At that time, TCBs will be able to certify all types of products. The TCBs can be found on the FCC Web site at https://gullfoss2.fcc.gov/oet/tcb_index.html. A search can be made by name, by state, or by country.

Often, designers, importers, and manufacturers have all of the technical specifications for a wireless product, but still find it difficult to identify which rule section contains the requirements for a certain device. This is particularly true for devices with technology originally developed overseas, designed for the military, or matured from the research and development environment to enter the marketplace. Individual rule sections are generally organized independently of particular technologies or frequency bands, making it difficult to determine which rules apply. Asking some basic questions and following a few simple strategies simplifies the task of determining the FCC requirements for a wireless device.

Unlicensed Operation. In general, an operator's license is required for most radio products. In the United States, unlicensed operation is allowed for a variety of radio devices. These are regulated under Part 15. If a radio transmitter has a maximum output power of less than 1 MW effective isotropic radiated power (EIRP), or 0 dBm, or if it operates in one of the internationally recognized industrial, scientific, and medical (ISM) bands, the product is likely to be acceptable under one or more sections of Part 15.

Spread-spectrum radios, as described in Subpart C of Part 15, are permitted up to 1 W (30 dBm) of output power and can use high-gain directional antennas in point-to-point operations provided certain conditions are met. Another high-power unlicensed application is the 5-GHz unlicensed national information infrastructure (U-NII) band regulated under Subpart E of Part 15, where up to 200 W EIRP (53 dBm) of output is authorized under certain conditions.

In general, however, unlicensed devices are very low power and are suitable only for limited use over a short range. Most devices have a field-strength limit as opposed to an output power limit. The rules are generally product specific and have different limits for the same frequency band (for example, in the band 902–928 MHz, limits differ for cordless telephones, spread-spectrum products, and field-disturbance sensors). Some general requirements apply to all unlicensed products. The table of contents for Part 15 is informative in that it is organized around frequency bands and individual applications. In most cases, a thorough examination of Part 15 can yield enough information to determine whether a device is applicable for unlicensed operation.

Licensed Service. For transmitters used in the licensed services, identifying the correct requirements is usually more difficult. Sometimes the title of the rule part contains sufficient information, such as Aviation Services (Part 87), Radio Broadcast Services (Part 73), or Personal Communications Services (Part 24). However, it is usually necessary to review the entire table of contents to find familiar product descriptions (for instance, cellular radio requirements are found in Subpart H of Part 22, Public Mobile Services). Some applications are found in several rule parts. Paging services, for example, are called out in Subpart E of Part 22, in Subpart P of Part 90, and in paragraph 24.130 in Subpart D of Part 24.

It is sometimes necessary to read an entire section or rule part to determine whether it is applicable to a particular product (for example, 800-MHz specialized mobile radio (SMR) in Part 90 or local multipoint distribution service (LMDS) in Part 101).

Using the following strategies, it is possible to narrow the search for the requirements applicable to licensed and unlicensed devices—without having to read every page of 47 CFR.

Paragraph 2.106 of the rules contains tables showing the allocation, assignment, and use of radio frequencies from 9 kHz to 300 MHz. Column headings are "International Table," "United States Table," and "FCC Use Designators." The U.S. table entries have descriptions of government and nongovernment allocations for each frequency band. Many of the FCC use designator entries include a reference to a rule part.

The list of applicable rule parts is not all-inclusive. Part 15 (unlicensed use), for example, is applicable to a number of frequency bands in the tables for which there is no Part 15 reference in the rule parts entry.

FCC has developed an excellent Web site that has proved very useful in determining equipment authorization requirements. OET, which is responsible for certification application review, also issues FCC grants of equipment authorization. A generic search form is available at https://gullfoss2.fcc.gov/prod/oet/index.html. The certification database can be searched by frequency, by product type, by company name, or by date. For most applications granted after 1998, copies of the FCC grant, test reports, and other required attachments are available for viewing.

Also available on this Web page is a link to the Rule Interpretations Database. The database is currently limited, with a concentration on Part 15 issues. The search engine is fairly basic, but the content is expected to be expanded to include other rule parts.

Resources for finding information about FCC are located at http://www.fcc.gov/resources/html. The page includes links to FCC rule parts on-line, which direct the search to the Government Printing Office. On-line versions of the rules for 2000 are available to download. Downloadable files are typically available in text or Acrobat (.pdf) format and can be easily searched using standard find and search commands.

Finding Rule Updates. Although on-line versions of the rules are updated a few times a year, rule makings are issued throughout the year, some of which may directly affect equipment authorization requirements. Searching the Web sites of the various bureaus or offices can reveal the most-current rule makings, which can be viewed or downloaded. This can be a tedious process because most rule makings are not concerned with equipment authorization matters. Searches are more manageable when they start at the date for which the latest on-line rules are currently available.

Links to bureaus are available from the FCC home page at http://www.fcc.gov. The following bureaus and offices are involved with maintaining rule parts associated with radio device equipment authorization:

FCC Staff. The FCC Laboratory Division staff is responsible for administering and interpreting the requirements for equipment authorization. Questions can be addressed via e-mail to Richard Fabina, Chief, Equipment Authorization Branch, at rfabina@fcc.gov. It is important to supply as much information about the product as possible because multiple rule parts are applicable to certain frequency bands. A device could be classified as either licensed or unlicensed depending on its output power and application. Because of staff limitations, it may take a few days for FCC to generate a response.

If the applicable rule part is known, it is useful to contact the bureau or office that is charged with administering that rule part when trying to determine equipment authorization requirements. In most cases, however, the inquiry will be referred to OET's laboratory division.

TCBs and Independent Test Laboratories. Test laboratories that have registered with FCC can be searched on the laboratory division electronic filing site at https://gullfoss2.fcc.gov/prod/oet/index.html. Most can provide guidance as to which requirements govern a particular device. Many have in-depth experience with applications to FCC for a wide variety of equipment. It is important to note that information from independent laboratories is opinion, and that these interpretations may not agree with those of FCC.

Laboratories that are also TCBs generally have more in-depth knowledge of which rule parts might apply to a product because their accreditation includes a demonstration of their familiarity with the correct application of the rules. The scope of TCBs' accreditation and expertise varies and can be examined under the TCB Scope section of the Web site's generic search form.