South of the Border: The Radio Approvals Process

David A. Case

Understanding the requirements for a few key countries can help wireless manufacturers get through the approvals process in Central and South America.

The process for obtaining radio approvals in most countries has been addressed often in a host of articles. Concerns usually focus on radio product sales in North America, Asia Pacific, and Europe. However, the use of wireless technologies is increasing in countries such as Mexico, Brazil, Argentina, and many others south of the U.S. border. As the need for wireless technologies grows in that part of the world, so do the requirements for radio product approvals.

The approvals processes and requirements in some of these countries are not well known. With the mutual recognition agreements (MRAs) currently being negotiated between the United States and South and Central American nations, it is a good time to take a look at the overall process for obtaining approval of wireless products in that region.

Requirements

Basic. Most agencies in Central and South American countries require that manufacturers work through an established local office or agent. Although this requirement adds to the cost, it can help make the process much smoother, depending, of course, on the agent. Using a local agent helps when identifying appropriate standards and is key to ensuring compliance with that nation's requirements. Moreover, many government agency staff speak only Portuguese or Spanish, which can present a challenge (especially for those whose Spanish is limited to ordering fajitas in a restaurant).

Most of the standards are written in Spanish or Portuguese only. However, a comparison of a nontranslated version of the Paraguayan Agency requirements, for example, to FCC regulations reveals that the Paraguayan standards are essentially the FCC regulations written in Portuguese.

A review of the South and Central American standards—especially those for wireless local-area network (WLAN) devices—clearly shows that most are (at least in part) based on FCC standards. In most cases, an FCC report is accepted for the basic review and starts the overall process.

Country-Specific. Although the approval process is generally the same for most countries in Central and South America, each country has its own requirements for wireless devices.^1,2 Because there are many types of wireless devices—and hence many regulations—this article addresses only WLAN devices operating in the 2.4 GHz band. A few countries have been selected to provide a snapshot of the overall process (see Table I).

Country Agent Required Test Units Required Test Reports Required In-Country Testing Argentina Yes Two samples required; special connectors required at the output of the radio. FCC Part 15.247 or ETSI and other documents. Yes Brazil Yes1 No; paperwork only. FCC Part 15.247 or ETSI and other documents. Yes Columbia Not required. Not required. No requirements. No Ecuador Not required. Not required. No requirements. No Mexico Yes No; paperwork only. FCC Part 15.247 or ETSI and other documents. TBD2 Venezuela Yes No; paperwork only. FCC Part 15.247 or ETSI and other documents. No 1. In-country agent not needed if filed through accredited agency. 2. There is a possibility within the next few months that Mexico will move to an in-country test requirement.

Table I. General requirements for selected South and Central American countries.

Argentina and Brazil

In Argentina, the Comisión Nacional de Comunicaciónes (CNC) reviews and issues certifications for wireless products. In Brazil, these are handled by Agência Nacional de Telecomunicações (Anatel). The requirements for both countries are somewhat similar with only slight differences.

To obtain approval of a WLAN radio product in Argentina, it must be audited in that country before the certificate can be issued. Argentina has no module approval, and each model number must be certified. It is best to send at least two production units of each model for testing, as well as a complete set of supporting hardware.

Argentina accepts only test reports from accredited laboratories. Test reports must be issued within the previous 18 months. The overall process takes about 60 to 70 days to complete, provided all information has met the requirements.

To obtain approval from Anatel in Brazil, an in-country audit of a WLAN radio product is required before a certificate is issued. The testing requirements are the same as for Argentina. Brazilian approvals, however, are not issued until after a product has been reviewed for electrical safety. The overall process takes about 45 to 60 days to complete, provided all the required information has met the requirements.

The good news is that Anatel has designated some U.S. companies to perform product reviews and issue certifications. The process is similar to submitting a product to a U.S. telecommunications certification body. Using these accredited reviewers for Brazilian approvals does speed the approvals process. The bad news is that Brazil is considering requiring a license for outdoor WLANs operating in the 2.4 GHz band. This requirement is designed to control possible interference to electronic newsgathering and outside broadcasting services in the 2.4 GHz band.

Chile

The Chilean Radio Agency, Subsecretariá de Telecomunicaciónes (Subtel), deals with the unlicensed spread-spectrum radios in several different ways, depending on usage and power output. Chile has changed its regulations twice. In early 2001, Chile changed its regulations to 10 mW, but it changed them back in the fall of 2001.

Under the original regulations, if a system operated at <50 mW, no formal registration was required other than that the importation paperwork include a letter stating that the system had met the relative requirements for operation in Chile. Compliance to FCC Part 15.247, Canada's RSS-210, or Europe's ETS 300 328 would suffice as meeting the requirements.^3–5 If the system operated at >50 mW, then no authorization was required, but a detailed report of the system had to be reviewed by Subtel.

For systems operating at >100 mW (and for outdoor use only), Subtel would sometimes require an in-country audit. Each installed site was subject to agency review and approval to prevent interference issues.

In early 2001, Chile restricted the power output for WLANs operating in the 2.4 GHz band to 10 mW effective isotropic radiated power (EIRP). This requirement basically eliminated WLAN technology in Chile. However, after some intense industry lobbying, Chile reversed its decision. Operation of WLAN devices with power levels up to 100 mW EIRP is now allowed without a license. It is also possible to get a higher-power system approved, but each system requires a license for each installed location, and the certification covers only that specific system.

Columbia and Ecuador

In Columbia, the Comisión de Regulación de Telecomunicaciones (CRT) reviews and issues certifications for wireless products. In Ecuador, these are handled by Secretaría Nacional de Telecomunicaciones (Senatel). For unlicensed WLAN devices operating at 2.4 GHz, no formal filing other than FCC approval is required to import the devices into these two countries. An end user may be required to register outdoor systems with the local government office, but registration requirements are somewhat loose.

Mexico

The country requirements for Mexico basically address paper filing only. The Comisión Federal de Telecomunicaciónes (Cofetel) requires no product audit. As with the other South American countries, the same standard paperwork (test reports, schematics, and label information) must be submitted. Manufacturers must also forward a complete set of photos showing all sides of a product, including proper labels for model number, serial number, and logo.

Under Nom-121-sct-1, the frequency range for WLAN devices operating in the 2.4 GHz band is restricted to operation between 2450 and 2483.5 MHz.⁶ The average turnaround time for the approval process is about 30 to 45 days.

The Mexican agency has just released Nom-121-sct-1-2001. Changes include allowing indoor systems to operate in the entire 2400–2483.5 MHz band. Maximum power is limited to 650 mW EIRP. Outdoor operation (or wide area, as they refer to it) is still restricted to the 2450–2483.5 MHz portion of the band.

The new version of the standard also references specific test procedures for these devices as well as specific radio parameters, including frequency stability and spurious emissions. Other changes include new power output levels up to 100 mW EIRP for 902–928 MHz. Power output in the 5725 MHz band is limited to 250 mW EIRP.

Venezuela

In Venezuela, Consejo Nacional de Telecomunicaciónes (Conatel) reviews and issues certifications for wireless products. Originally, other than an FCC certificate, Venezuela radio law had no real requirements for WLAN devices. However, the agency is currently reviewing and implementing a new set of in-country rules for certification of these types of radios.

As the popularity and use of wireless devices increases, it appears that Venezuela may adopt rules similar to FCC Part 15.247 as its national radio law. Although the rules are still in early draft stages, Venezuela has begun requesting FCC reports to review before products can be imported. At this time, there is still no formal type approval. However, Venezuela is considering a formal type-approval process.

Conclusion

The approval processes in Central and South America can be compared in part with the European Union (EU) before the Radio and Telecommunications Terminal Equipment (R&TTE) Directive, or even before the adoption of the ETSI standards when each European country had unique requirements. The recommended use of local agents in Central and South America is similar to the EU process in the mid-1990s. Working directly with the various agencies through a qualified agent makes the process easier to navigate.

The biggest problem that might be encountered is the language barrier, which is partly why a local agent is necessary. The real test is to see whether the process will speed up approvals once the MRAs take effect. Perhaps the MRAs will eliminate or at least reduce the testing required for these countries.

References

1. H Jones, "Central and South American Approvals: Green Light or Red Tape?" Compliance Engineering 18, no. 3 (2001): 174–179.

2. K Eroglu, "Gaining Approval of Wireless LAN Devices in South America," Compliance Engineering 17, no. 3 (2000): 230–233.

3. Code of Federal Regulations, 47 CFR 15.247.

4. RSS-210, "Low Power License-Exempt Radiocommunication Devices (All Frequency Bands)," Industry Canada, Ottawa, ON, Canada, November 2001.

5. ETS 300 328, "Radio Equipment and Systems (RES); Wideband Transmission Systems; Technical Characteristics and Test Conditions for Data Transmission Equipment Operating in the 2.4 GHz ISM Band and Using Spread Spectrum Modulation Techniques," European Telecommunication Standards Institute, Sophia Antipolis, France, 1999.

6. Nom-121-sct-1-1994, "Installation and operation of radio communication systems that use the technique of dispersed phantom in the bands of 902–928 MHz, 2450–2483.5 MHz and 5725–5850 MHz," Federal Commission of Telecommunications, Del. Cuajimalpa, Mexico, June 1995.

David A. Case, NCE, is a senior radio compliance engineer for Cisco Systems Corporate Compliance Operations and EMC Standards Group (Akron, OH). He is chair of the telecom technical committee (TC-8) for the Information Technology Industry Council and a member of Compliance Engineering's editorial advisory board. He can be reached via e-mail at davecase@cisco.com.