U.S. and EU EMC Compliance of Wireless Devices

Greg Kiemel

With many regulatory hurdles now gone, getting a wireless radio device to market is easier than ever.

The compliance process has gotten easier in both the United States and Europe, but EMC test requirements must still be addressed early in the design of wireless products.

Radio manufacturers now have faster, more-convenient options for product compliance in the United States and the European Union (EU). The Telecommunications Certification Body (TCB) authorization process in the United States offers manufacturers more than one approval body from which to select. Competition among TCBs has kept costs low and processing times fast, providing an alternative to the FCC's authorization process. In Europe, the Radio and Telecommunications Terminal Equipment (R&TTE) Directive has removed many regulatory hurdles and allows manufacturers to self-declare compliance to the applicable harmonized standards.

This article provides an overview of the wireless-product compliance process for electromagnetic compatibility (EMC) in the United States and in Europe. The new FCC authorization process through TCBs is discussed, as well as how the R&TTE Directive is implemented in the EU. Key topics include compliance considerations, the FCC authorization process, and the R&TTE Directive.

Compliance Considerations

Before developing a wireless device, it is imperative that manufacturers thoroughly investigate the EMC requirements for their target markets. Incredibly, there have been cases in which a company has spent hundreds of thousands of dollars on the development of a radio product, and is on the verge of product release, only to discover that operation of the radio would be illegal in those target markets. This nightmare scenario can be avoided with minimal up-front research. However, more-common compliance issues require periodic attention throughout the product development cycle.

With the recent advent of low-cost wireless technologies, many companies are looking to add wireless features to their existing products. Experienced radio-frequency (RF) design engineers are familiar not only with performance and interoperability issues, but with EMC requirements as well. Unfortunately, that level of expertise can be difficult to retain in-house, especially if wireless products are not the core focus of the company. In the long run, a great deal of time and money can be saved by consulting with an expert in the EMC authorization of wireless products. That expert should be able to provide rules interpretations, create test plans, and offer EMC design strategies.

Whether a company decides to seek expert advice or opts to handle the process in-house, it's best not to wait until the end of the design cycle to test. To avoid costly rework or last-minute board-turns, it is always advisable to test early in the design cycle. It is also important to test several times prior to the final certification test.

The most economical use of test time can be achieved through the use of a test plan. The information contained in a test plan will allow test laboratories to provide more-competitive rates, better preparation in advance of testing, and, consequently, more-effective use of test time. The test plan should include a thorough functional description of the product. The following parameters should be specified: output power (fixed or variable), data rates, modulation scheme(s), channel assignments, wired input/output (I/O) ports, power-supply requirements, accessories, and installation options. Too often during the authorization process, an untested feature is revealed in the user manual that was not obvious in the sample presented to the testing laboratory. A test plan is a key strategy in preventing delays during the equipment authorization process.

From the beginning, EMC compliance must be a design consideration. Fortunately, the principles of good EMC design and smart RF design are similar. Although some engineers may rely entirely on shielding as their suppression strategy, in most cases, single solutions do not exist. Rather, a combination of strategies is required to achieve compliance. In addition to shielding, the focus of EMC design should include grounding, filtering, component selection, and printed circuit board (PCB) layout. If experienced EMC design talent is not available in-house, seek the advice of an EMC consultant familiar with that particular radio technology. Involve your expert at regular intervals during the design cycle.

FCC Authorization Process

The FCC rules for wireless devices are found in Title 47 of the Code of Federal Regulations (CFR). Hard copies can be purchased from the Government Printing Office Bookstore, or downloaded electronically at http://www.access.gpo.gov, and http://www.fcc.gov/oet. Title 47 is organized into parts that cover the various radio services. Here are some examples:

• Part 2—Authorization and Measurement Procedures, Frequency Allocations, General Rules.
• Part 15—Receivers and Unlicensed Transmitters (Intentional Radiators).
• Parts 22 and 24—Cellular Radio and PCS.
• Part 90—Specialized Mobile Radio Service (Land Mobile).
• Part 95—Personal Radio Service (FRS, GMRS, CB, R/C), WMTS, and MICS.
• Part 101—Fixed Microwave Radio Service.

In recent years, the FCC equipment authorization process has been simplified. Previously, there were five authorization procedures, distinguished as:

• Type Acceptance: Required an application to the FCC; applied to licensed transmitters.
• Certification: Similar process to type acceptance; applied to unlicensed low-power transmitters that operated under FCC Parts 15 and 18.
• Notification: Required an application, but no measurement data; used for products with a good record of compliance, such as most receivers.
• Declaration of Conformity (DoC): A self-approval procedure that required no application to FCC. The product must have been tested at an NVLAP- or A2LA-accredited lab. This procedure was used for personal computers and peripherals only.
• Verification: A self-approval procedure that did not require testing at an accredited lab; used for nonresidential devices operating under FCC Parts 15 and 18.
  FCC now has only three authorization procedures:
• Certification: Applies to all transmitters, transceivers, scanning receivers, and radar detectors.
• DoC: Applies to most receivers, personal computers and peripherals, and residential Part 18 devices.
• Verification: Used for nonresidential devices operating under FCC Parts 15 and 18; also applies to receivers that are part of a certified transceiver.

Other aspects of the FCC authorization process have been made easier. For years, lengthy FCC processing times burdened radio manufacturers. The application process was so complex that it often required an in-house expert to shepherd the transmitter through regulatory hurdles. Internationally, in comparison with other regulatory agencies, FCC was becoming increasingly different in its system of product authorizations. Eventually it was realized that the FCC certification process was not in harmony with international mutual recognition arrangements (MRAs).

In response, FCC devised an alternate authorization process that was intended to remedy these problems. In Docket 98-68 (12/17/98), TCBs were established, and FCC designated the initial group of TCBs in June 2000. Without replacing the existing FCC approval process, the new process uses private entities (designated by FCC) to issue transmitter and telecom certifications. Manufacturers have the choice of using either FCC or TCBs to certify products. TCBs function like FCC by certifying a product based on the test results of one representative sample. The TCB authorization process also parallels the product certification processes in other countries—an essential step in the MRA process. The FCC rules governing TCB designation and operation are found in 47 CFR 2.960 and 2.962.

Figure 1. TCB application trend.1

TCB Advantages

The TCB authorization process offers manufacturers more than one approval body to select from. TCBs provide a faster turnaround than FCC's authorization process. Competition among TCBs has kept costs low and processing times fast. Currently, TCBs grant more certifications than FCC (see Figure 1).¹

Initially, FCC had hoped to direct more of its freed resources toward enforcement. Unfortunately, there does not appear to have been a significant increase in enforcement; rather, FCC resources have been tapped to develop new rules for emerging technologies, develop policy covering RF safety issues, and to support homeland security. If FCC can provide adequate enforcement, the competitive playing field will be leveled against those who have been shortcutting the regulatory process.

TCB Activities

TCBs certify devices in accordance with FCC rules and policies. They issue written grants of certification based upon applications that contain the same information currently required by FCC rules. The grantee remains responsible to FCC for compliance. TCBs accept and review test data from manufacturers or test laboratories. However, TCBs are responsible for the accuracy of the test data and may perform laboratory audits or ask for sample units for testing before accepting test data. TCBs verify that all FCC labeling requirements, including the FCC identification, are met. Upon successful review of the application, TCBs grant a certificate of equipment authorization. TCBs then submit an electronic copy of the application and a completed Form 731 to FCC. Immediately, FCC posts a TCB grant of equipment authorization on its Web site (https://gullfoss2.fcc.gov/prod/oet/index_ie.html). TCBs can also approve permissive changes, regardless of who originally certified the equipment. FCC requires TCBs to perform postmarket audits of equipment they certify.

TCB Prohibitions

TCBs are prohibited from the following activities:

• Granting waivers to FCC rules and regulations.
• Certifying new technologies where FCC rules do not exist.
• Certifying products on the FCC Exclusion List (latest version released July 2002).
• Enforcing FCC rules.
• Granting transfers of control of certifications.
• Imposing their own requirements.

Figure 2. Process flow.2

All TCB actions are subject to FCC review. In cases of dispute, FCC will be the final authority (see Figure 2).²

Currently, there are 20 TCBs in the United States and 11 in Europe.³ The TCB program is considered to be a huge success in allowing manufacturers to rapidly obtain FCC certification of their wireless devices. For a list of current TCBs, go to https://gullfoss2.fcc.gov/prod/oet/index_ie.html. Under "Reports," click on "Generic Search." Scroll through "TCB Information" for the list.

EU Compliance Process—R&TTE Directive

On April 1, 2000, Directive 1999/5/EC (also known as the R&TTE Directive) went into effect (http://europa.eu.int/comm/enterprise/rtte/dir99-5.htm). It dramatically changed the way manufacturers achieved compliance for their wireless devices in the EU. Previously, approval was obtained from the spectrum authority in each country. Because few MRAs existed, it was an arduous country-by-country process. The notified body in each country played a primary role in the approvals process. Now, under the R&TTE Directive, compliance is based on a manufacturer's DoC. The role of a notified body is greatly diminished. Their expertise is required when harmonized standards do not exist; otherwise, manufacturers can voluntarily elect to use their services. A guiding principle of the directive is that manufacturers take full responsibility for their products and should test to verify compliance.

Unlike FCC rules, the R&TTE Directive requires no certification prior to marketing. In the absence of tight premarket controls, postmarket surveillance is the primary enforcement strategy. Several member states have comprehensive surveillance and testing programs. Not only is compliance with the applicable technical standards randomly checked, but labeling and user information are thoroughly reviewed as well.

The requirements of the R&TTE Directive are legal rather than technical and are designed to safeguard the RF spectrum. The European Telecommunication Standards Institute (ETSI) and the European Committee for Electrotechnical Standardization (CENELEC) provide the technical requirements in the form of harmonized standards.⁴ An ETSI standard (http://www.etsi.org/) is considered harmonized once it is published in the Official Journal of the European Communities (http://europa.eu.int/comm/enterprise/rtte/harstand.htm).

Although harmonized standards are voluntary, compliance with them gives a presumption of conformity with the directive. Testing to verify compliance with harmonized standards is the easiest route for manufacturers. In the absence of harmonized standards, manufacturers can use other methods (developed either in-house or under the guidance of a notified body).

It is important not to confuse harmonized standards with harmonized spectrum. Although there are many harmonized standards, very few portions of the EU radio spectrum are completely harmonized. Compliance with the applicable harmonized standards is sufficient to apply the CE mark, but notification to the spectrum authority in each member state is still required prior to marketing a device. The notification process is relatively simple and can be accomplished on-line or via e-mail. If no reply is received within 30 days of notification, then the manufacturer is free to market its device. The R&TTE Directive provides free movement of radios within the EU, unless the spectrum authority in a member state has good reasons to bar products (usually due to spectrum allocation issues).

The essential requirements of the directive are outlined in Article 3 as:

• Electrical safety and health (e.g., Low Voltage Directive 73/23/EEC, RF Safety).
• Electromagnetic compatibility (as in EMC Directive 89/336/EEC).
• No harmful interference to the spectrum (as in compliance with harmonized ETSI standards).

Another important requirement, specified in Article 4, is to operate in accordance with national frequency plans. A useful database containing the spectrum allocation of EU member states can be found on-line (see EFIS at http://www.ero.dk).

The conformity assessment process is outlined in Article 10 of the directive. Again, the main principle is that manufacturers take full responsibility and should test to verify compliance. The procedures described in Annex III or Annex IV are the most common compliance routes. The following section provides a brief description of each procedure.

Conformity Assessment

Annex II—Internal Production Control. Per Article 10(3), this procedure is available only to telecommunications terminal equipment and receivers, not transmitters. Technical documentation is assembled to demonstrate conformity with the essential requirements of Article 3. Documentation covers design, manufacture, and operation of the product, and may include test reports. The documentation must be kept on file by either the manufacturer or its representative in the EU. In either case, it should be readily available in case surveillance authorities request evidence of compliance.

Annex III—Internal Production Control Plus Specific Apparatus Tests. The requirements of Annex II, plus all the essential radio test suites, must be performed. In the absence of harmonized standards, a notified body identifies the essential radio test suites in the form of a test plan. Otherwise, manufacturers may test to the applicable harmonized standards. Finally, the manufacturer or its EU representative must declare that the tests have been carried out, declare that the apparatus complies with the essential requirements of the R&TTE Directive, and apply the CE mark. If a notified body has been involved, its number must accompany the CE mark.

Annex IV—Technical Construction File (TCF). This process includes the requirements of Annex III, plus a TCF that contains a DoC to specific radio test suites. A notified body reviews the TCF and issues an opinion within four weeks. This is not a certification. Notified bodies do not issue certifications under the R&TTE Directive. If no opinion is received within four weeks, the manufacturer may place the product on the market. The TCF must be kept ready for inspection by the manufacturer or its EU representative for at least 10 years after the last product of that type has been manufactured.

Annex V—Full Quality Assurance. This process is more complex than those previously discussed. Only some notified bodies are approved to perform this process. The manufacturer must operate an approved quality system for design, manufacture, and final product inspection. A notified body must assess whether the quality control system ensures conformity with the requirements of the directive. Manufacturing facilities are then subject to on-site surveillance by a notified body. A number of documents must be kept ready for inspection by the manufacturer for at least 10 years after the last product of that type has been manufactured.

European Perspective

The European Commission reports a positive experience with the R&TTE Directive for wireless devices. Manufacturers are particularly pleased with the new streamlined process, and spectrum authorities report that there has been no visible increase in radio interference.⁵

Conclusion

The wireless-product compliance processes for electromagnetic compatibility (EMC) in the United States and in Europe have gotten faster and more convenient for radio manufacturers. The TCB authorization process in the United States offers manufacturers a choice of approval bodies from which to select, and competition has kept costs low. The R&TTE Directive has removed many regulatory hurdles, allowing self-declaration to the applicable harmonized standards.

References

1. William Hurst, "FCC Recent Activity Report," presented at the USCEL Meeting, Minneapolis, August 19, 2002.

2. Art Wall, "New FCC Rules to Privatize Equipment Authorization and Implement MRAs," presented at the EMC Globalization Workshop, Washington DC, February 10, 1999.

3. William Hurst, "FCC Recent Activity Report," presented at the USCEL Meeting, Minneapolis, August 19, 2002.

4. Mark Bogers, "EU/US MRA CAB Training," presented at the U.S. CAB Workshop, Arlington, VA, April 10, 2002.

5. Mary Jo DiBernardo, "MRA Update," presented at the USCEL Meeting, Minneapolis, August 19, 2002.

Bibliography

Directive 1999/5/EC (R&TTE), available on the Internet: http://europa.eu.int/comm/enterprise/rtte/dir99-5.htm).

Title 47, Code of Federal Regulations, available at two locations on the Internet: http://www.access.gpo.gov, and http:// www.fcc.gov/oet.

Greg Kiemel is director of engineering for Northwest EMC Inc. (Hillsboro, OR). He can be reached at 888-364-2378 or by e-mail at gkiemel@nwemc.com.