Mutual Recognition Agreement (MRA) International Workshop 2009 Tokyo, Japan Overview of FCC Requirements
March 4, 2009
George Tannahill FCC Lab - Technical Research Branch [email protected] Office of Engineering and Technology Federal Communications Commission
1 Overview
FCC Overview FCC Regulations Equipment Approval Process – General information – TCB information – MRA information Post Grant Surveillance TCB Implementation/Operations Information Sources
MRA International Workshop March 4, 2009 2009 Tokyo, Japan 2 Federal Communications Commission Federal Communications Commission (FCC) regulates the private sector telecommunications industry, in the public interest
– Establishes technical regulations for transmitters and other equipment to minimize their potential for causing interference to radio services.
– Administers an authorization program to ensure that equipment reaching the market complies with the technical requirements
MRA International Workshop March 4, 2009 2009 Tokyo, Japan 3 FCC Organizational Chart
MRA International Workshop March 4, 2009 2009 Tokyo, Japan 4 OET Lab Principle Functions Equipment Authorization including monitoring Telecommunication Certification Bodies (TCBs)
Ensure compliance through market surveillance and enforcement
Technical Studies supporting regulatory policies and rulemaking
Providing web-based comprehensive and timely clarification of technical standards and procedures MRA International Workshop March 4, 2009 2009 Tokyo, Japan 5 FCC Regulations Title 47 of the Code of Federal Regulations (47 CFR) Transmitter specifications Radio Services EMC specifications Telephone Terminal Equipment Test Methods Equipment Authorization Requirement Marketing and Importation Rules
MRA International Workshop March 4, 2009 2009 Tokyo, Japan 6 FCC Regulations Overview Administrative Rules – Contain general requirements applicable to all other rule sections • 47 CFR Parts 0, 1 and 2 – Examples: application filing process, general description of required tests, confidentiality, etc. Radio Service Rules – Contain specific user licensing and equipment authorization testing requirements • 47 CFR Part 15, 18, 22, 24, etc. – Examples: Line conducted and radiated emission limits for specific products, occupied bandwidth masks, etc.
MRA International Workshop March 4, 2009 2009 Tokyo, Japan 7 FCC Administrative Regulations 47 CFR Part 0 – 0.457 & 0.459 Confidentiality 47 CFR Part 1 – 1.1307 & 1.1310 – RF Exposure 47 CFR Part 2 – Subpart I – Marketing – Subpart J – Equipment Authorization • 2.201-2.202 – Emission designators • 2.902-2.907 Authorization Types • 2.929 – 2.926 – ID Labels • 2.1033 – Application for Certification • 2.1043 – Permissive Changes • 2.1046 – 2.1057 – General tests for licensed devices – Subpart K – Importation of Devices MRA International Workshop March 4, 2009 2009 Tokyo, Japan 8 Equipment Authorization Regulations Administrative • Part 0: Commission organization • Part 1: Practice and procedure • Part 2: General rules and regulations License Exempt Operation • Part 15: Radio frequency devices • Part 18: Industrial, Scientific, and Medical Equipment • Part 68: Telephone Terminal Equipment Licensed Operation • Part 11: Emergency Alert Systems (EAS) • Part 20: Commercial Mobile Radio Services • Part 22: Public mobile services • Part 24: Personal communication services MRA International Workshop March 4, 2009 2009 Tokyo, Japan 9 Equipment Authorization Regulations (continued)
Licensed Operation (continued) • Part 25: Satellite communications • Part 27: Miscellaneous wireless communication service • Part 73: Radio broadcast services • Part 74: Experimental, Auxiliary & Special broadcast services • Part 80: Maritime services • Part 87: Aviation services • Part 90: Private land mobile radio service • Part 95: Personal radio service • Part 97: Amateur radio services • Part 101: Fixed microwave services
MRA International Workshop March 4, 2009 2009 Tokyo, Japan 10 Measurement Techniques
What Measurement Techniques Should Be Used? – A number of measurement techniques have been identified and can be found in: • FCC Rules – Radio Service Rules – Part 2 General Rules & Regulations – Industry Standards Incorporated by Reference • Text of the Report and Order • Public Notice Issued by the Commission • Knowledge Database • Industry Standards – Measurement Procedures Website • http://www.fcc.gov/oet/ea/eameasurements.htm – OET Website for Equipment Authorization General Information: http://www.fcc.gov/oet/ea/Welcome.html
MRA International Workshop March 4, 2009 2009 Tokyo, Japan 11 Equipment Authorization Program
Maximum Certification (Approved by FCC or TCB) The type of approval DoC is specified in the (Self-approval using rules an accredited lab) for the particular type of device SDoC (Part 68) (Self-approval Database by ACTA)
Verification Minimum (Self-approval)
MRA International Workshop March 4, 2009 2009 Tokyo, Japan 12 FCC Authorization Requirements
Verification SDoC DoC Certification Most ISM Cable System Equipment Term. Device TV & FM PC’s & Peripherals PC’s & Peripherals1 Receivers All Other Digital Most Receivers Most Receivers Devices Pt-to-Pt TV Interface TV Interface Devices Microwave Devices Broadcast Consumer ISM Consumer ISM Transmitters Equipment Equipment Aux. Broadcast Telephone Telephone Transmitters Equipment Equipment1 INMARSAT Most transmitters Equipment 406 MHz ELT Scanning Receivers CATV Relay Transmitters
(1) The FCC Lab no longer certifies this equipment. However, this equipment may be certified by a TCB.
MRA International Workshop March 4, 2009 2009 Tokyo, Japan 13 Equipment Authorization Top Ten Certification Equipment Classes
Percent vs Equipment Class
20 18 16 14 12 10 8 6 4 2 0 DTS DXX DSS PCE JBP DSC TNB NII PCB 8CC
MRA International Workshop March 4, 2009 2009 Tokyo, Japan 14 Equipment Authorization Classifications
Category Description Percent Rules
DTS Digital Transmission System 16.1 15C
DXX Part 15 Low Power Communication Device Transmitter 13.9 15C
DSS Part 15 Spread Spectrum Transmitter 18.7 15C
JBP Part 15 Class B Computing Device Peripheral 11.4 15B
PCE PCS Licensed Transmitter held to ear 9 Licensed 24
DSC Part 15 Security/Remote Control Transmitter 4.5 15C
TNB Licensed Non-Broadcast Station Transmitter 4.4 Licensed 22
PCB PCS Licensed Transmitter 4.1 Licensed 24 NII Unlicensed National Information Infrastructure TX 3.6 15E
8CC Part 18 Consumer Device 1 18 Total 86.7
MRA International Workshop March 4, 2009 2009 Tokyo, Japan 15 General Equipment Types
License Exempt Devices – Parts 15 & 18
– Incidental Radiator - Parts 15.13 & 15.5(b)
– DC Motors & mechanical light switches
– Unintentional Radiator - Part 15 Subpart B
– Intentional Radiator - Part 15 Subpart C +
– Industrial, Scientific and Medical equipment – Part 18
Licensed Transmitters – Other Rule Parts
MRA International Workshop March 4, 2009 2009 Tokyo, Japan 16 License Exempt Unintentional Radiators
Part 15, Subpart B – Any device that intentionally generates RF energy, but does not intentionally radiate that energy
Examples:
– Digital devices (data processing equipment, computers, etc.)
– Radio receivers that tune between 30-960 MHz
– TV interface devices (VCRs, cable terminal devices, etc.)
MRA International Workshop March 4, 2009 2009 Tokyo, Japan 17 License Exempt Intentional Radiators
Part 15, Subpart C – Lists frequency bands and types of operation permitted.
Examples: – Cordless Telephones – Remote Switches, door controls, alarms – Wireless Local Area Network (WLAN)
MRA International Workshop March 4, 2009 2009 Tokyo, Japan 18 Licensed Radio Services
Transmitters that require either an individual license or a blanket authorization are subject to requirements of a specific radio service. – General Mobile Radio Services (non-cellular) – Personal Mobile Services – Broadcast Radio Services – Microwave Radio Services – Maritime and Aviation Radio Services
MRA International Workshop March 4, 2009 2009 Tokyo, Japan 19 Telephone Terminal Regulations
47 CFR Part 68 – Telephone Terminal Equipment (TTE) – Public Switched Telephone Network (PSTN) – Private Line Interfaces – Analog Interfaces – Digital Interfaces – www.part68.org
MRA International Workshop March 4, 2009 2009 Tokyo, Japan 20 MRA Equipment Authorization Processes
Declaration of Conformity – Approval using an accredited test lab – MRA Phase I/Japan EMC Arrangement Certification – Approved by FCC or Telecommunication Certification Body (TCB) – MRA Phase II/Japan MRA
MRA International Workshop March 4, 2009 2009 Tokyo, Japan 21 Application for Certification Information
2.1033(b)Part11,15,18 2.1033(c) Other Parts – Name, address – Name, address – FCCID – FCCID – User/installation – User/installation Manual Manual – Circuit Description – Circuit Description – Block Diagram – Emission Type – Schematics (when – Frequency Range required) – Power levels & max. – Measurement Report – Tune Up procedure – Photos – Schematics • Internal, external, – Measurement Report setup – Photos
MRA International Workshop March 4, 2009 2009 Tokyo, Japan 22 FCC/TCB Certifcation Process Comparison Pay for TCB Services Product is entered into the Support Information Grant is Issued FCC Database through is uploaded Form 731
Product is Tested
Completes Grant is Issued Form 731 Product is entered into the Processing FCC Database
FCC Fees If no problems are found a Grant is issued. Questions and Answers
Examiner Review
The review process is Manufacturer’s Product Engineer Review between 30 – 45 days MRA International Workshop March 4, 2009 2009 Tokyo, Japan 23 Equipment Authorization Certification Process Trends
12000
10000 Authorized by FCC 8000
6000 Authorized by TCBs 4000
2000 Total New Authorizations 0
2001 2002 2003 2004 2005 2006 2007 2008 MRA International Workshop March 4, 2009 2009 Tokyo, Japan 24 Why Use the Private Sector?
Speed at which technology is changing and shorter product life cycles require faster product approvals The private sector has the technical expertise and ability to certify equipment. Increase the resources performing conformity assessment Efficiencies in designing and approving product in the same geographic location Reduce uncertainty and delay in obtaining certification
MRA International Workshop March 4, 2009 2009 Tokyo, Japan 25 What is a TCB?
A Telecommunication Certification Body is a Certification Body that has been accredited to ISO/IEC Guide 65 and ISO/IEC Standard 17025 by a recognized Accrediting Organization and recognized by the FCC to approve equipment subject to certification. A TCB has certain rights and responsibilities (e.g. equitable treatment of applicants, audit through sampling of equipment on market) Foreign entities may become a TCB in accordance with the terms of a government-to-government Mutual Recognition Agreement/Arrangement.
MRA International Workshop March 4, 2009 2009 Tokyo, Japan 26 TCB Scope of Responsibility
TCB (see § 2.962 (e) and Public Notice, DA 99-1640) – Is empowered to certify products in accordance with the FCC rules – Must provide fair and equitable treatment – Must accept test data from any source, subject to subcontracting clause in ISO Guide 65 and shall not unnecessarily repeat tests – May assess fees for processing applications – May rescind grant within 30 days
MRA International Workshop March 4, 2009 2009 Tokyo, Japan 27 MRA Introduction
Purpose of MRA -- To facilitate trade by allowing Conformity Assessment Bodies (CAB) in one economy to test (Phase I) and/or certify (Phase II) products to the Technical Regulations of another economy.
Participation in a MRA is voluntary -- however, if a economy agrees to participate in either Phase I and/or Phase II certain rights and obligations in accordance with the terms of the MRA apply. Government to Government Use of harmonized technical standards is not part of an MRA
MRA International Workshop March 4, 2009 2009 Tokyo, Japan 28 Benefits of MRAs Products May be shipped directly to foreign countries without any further requirements for testing and/or certification thereby reduced costs and time to market Facilitates trade by promoting market access and competition Reduces and minimizes non-tariff trade barriers Shortens time for manufacturers to introduce their products into the importing countries
MRA International Workshop March 4, 2009 2009 Tokyo, Japan 29 MRA Webpage
Organizes all FCC related MRA information in one location: – www.fcc.gov/oet/ea/mra • Links to agreements • Implementation information – Accredited CAB requirements – Certification Body requirements » TCB Guide 65 Checklist » TCB Roles and Responsibilities » Measure procedures • Contact information for stakeholders
MRA International Workshop March 4, 2009 2009 Tokyo, Japan 30 Identification of US Players
Regulatory Federal Communications www.fcc.gov Authority (RA) Commission (FCC)
Designating National Institute of Standards www.nist.gov Authority (DA) and Technology (NIST) Accreditation Body National Voluntary Lab www.nist.gov (Phase 1) Accreditation Program (NVLAP) & www.a2la.org American Association of Lab Accreditation (A2LA) AB (Phase 2) American National Standards www.ansi.org Institute (ANSI) American Association for www.a2la.org Laboratory Accreditation (A2LA)
MRA International Workshop March 4, 2009 2009 Tokyo, Japan 31 United States and MRAs
The US Government has agreed to participate in the following MRAs for conformity assessment:
European Union MRA
European Free Trade Association (EFTA) MRA
Asian Pacific Economic Co-operation Tel MRA (APEC)
Inter-American Commission for Telecommunications (CITEL MRA)
Japan MRA
MRA International Workshop March 4, 2009 2009 Tokyo, Japan 32 US – Japan Telecom MRA
Scope: Telecommunications terminal equipment and radio equipment – Limited to radio and telecommunications equipment subject to certification • Doesn’t include ISM and unintentional radiators. – United States – FCC Rules (47 CFR) – Japan – Telecom Business Law, Radio Law, related ordinances – Regardless of location of the supplier or country of origin of the equipment MRA International Workshop March 4, 2009 2009 Tokyo, Japan 33 US – Japan Telecom MRA
Entry into force – Signed February 16, 2007 in Washington, D.C. by officials of the U.S. and Japan – Japan’s Parliament (Diet) approved the MRA; June 19, 2007 – Arrangement on Electro-Magnetic Compatibility (EMC): through Exchange of letters Exchange of diplomatic notes – December 2007 • Official implementation date January 1, 2008 – Training/Workshops in 2009 • Tokyo March 3-4, 2009. • Gaithersburg NIST May 4-8, 2009 Information on US-Japan MRA: – http://ts.nist.gov/Standards/Global/mra_rebuild_japan.cfm – http://www.fcc.gov/oet/ea/mra/Japan.html
MRA International Workshop March 4, 2009 2009 Tokyo, Japan 34 MRA Implementation Process
Basic Requirements: – Regulatory Authority – Designating Authority – CAB Accrediting Body Modify laws to allow if necessary – Laws must allow private sector testing and approval. Establish: – Procedures for recognizing foreign CABs – Procedures for designating CABs MRA International Workshop March 4, 2009 2009 Tokyo, Japan 35 Accreditation Requirements
MRA Phase I/EMC MRA Phase II/Japan MRA Arrangement – Regulatory Authority – Regulatory Authority – Designating Authority – Designating Authority – Accrediting Body – Accrediting Body • ISO17011 • ISO17011 – CAB – CAB • ISO 65 • ISO 17025 • ISO 17025
MRA International Workshop March 4, 2009 2009 Tokyo, Japan 36 MRA Phase I/EMC Arrangement - Accreditation of Test Laboratories Laboratories outside the United States will be recognized by the FCC if one of the following two conditions are met:
– the laboratory has been designated by a foreign authority and recognized by the Commission under the terms of a government-to-government Mutual Recognition Agreement or Arrangement; or
– the laboratory has been accredited by an organization whose accreditations are recognized by the Commission.
MRA International Workshop March 4, 2009 2009 Tokyo, Japan 37 MRA Status – Phase I/EMC Arrangement Phase I/EMC Arrangement (mutual acceptance of Region Number of test data) is operational with the following Labs countries: North 91 • Australia America • Canada • Chinese Taipei Europe 47 • European Union Asia 125 • Hong Kong, China • Japan Middle 3 – 60 recognized East • Korea • Singapore Total 266 • Vietnam MRA International Workshop March 4, 2009 2009 Tokyo, Japan 38 MRA Status – Phase II/Japan MRA
Phase II (mutual acceptance of approvals) is operational with the following countries: • Canada • European Union • Hong Kong, China (pending development of procedures) • Singapore A total of 32 Telecommunication Certification Bodies (TCBs) have been recognized by the FCC. • 17 domestic TCBs • 15 foreign TCBs
MRA International Workshop March 4, 2009 2009 Tokyo, Japan 39 Process Summary How to become a Certification Body/TCB – Accreditation by FCC recognized accreditation body – Apply to MIC for Designation to FCC – Upon FCC recognition TCB may begin authorizing equipment. After Recognition – TCB may authorize equipment in accordance with FCC Rule – TCB may not make interpretations or waivers – Keep up to date with FCC regulations MRA International Workshop March 4, 2009 2009 Tokyo, Japan 40 Process Summary (continued)
How to authorize equipment: – Log on to FCC Equipment Authorization Website: • Go to www.fcc.gov • Click on “e-filing” link • Scroll to “OET TCB/Accreditor Electronic Filing” link and click on it and bookmark page that opens. • Click TCB login and enter login and password. • Complete Form 731 to issue grant.
MRA International Workshop March 4, 2009 2009 Tokyo, Japan 41 TCB Training
Monthly conference calls with TCB Council – Phone in first Tuesday every month at 11 AM Washington DC time. TCB Meetings – TCB’s meet 2-3 times annually to discuss issues and for training. Other training opportunities – Scheduled as necessary – May 5-7, 2009 NIST in Gaithersburg, MD USA • http://ts.nist.gov/Standards/Conformity/mra/2009- MRA-Workshop.cfm FCC Knowledge Database – www.fcc.gov/labhelp Beta Test/Practice Website – https://selafoss.fcc.gov/tcb/index.html
MRA International Workshop March 4, 2009 2009 Tokyo, Japan 42 TCB/Accreditor Filing Webpage
MRA International Workshop March 4, 2009 2009 Tokyo, Japan 43 TCB Login Homepage
MRA International Workshop March 4, 2009 2009 Tokyo, Japan 44 Post Grant Surveillance FCC – Reviews TCB Grants – Requests Samples from Grantees and TCB’s – Purchases Samples – Focused sampling projects TCB – FCC requires each TCB to audit 5 % of products they authorized annually • 1 % RF Exposure if applicable • www.fcc.gov/labhelp KDB 610077 – https://fjallfoss.fcc.gov/oetcf/kdb/forms/FTSSea rchResultPage.cfm?id=20540&switch=P Other – General public complaints/testing – Competitors complaints/testing
MRA International Workshop March 4, 2009 2009 Tokyo, Japan 45 Post Grant Audit Issues
FCC Actions – Non compliance issues: – Require explanation – Monetary fines – Confiscate equipment – Fix equipment TCB Responsibilities – Required to report issues to FCC & Grantee Applicant Issues – Non response • Grantee code deferral
MRA International Workshop March 4, 2009 2009 Tokyo, Japan 46 Enforcement Actions PROXIM WIRELESS CORPORATION. Notified of a $11,000 monetary forfeiture for marketing non-compliant wireless access points. Adopted: 01/29/2009 by NAL. (DA No. 09- 146). – http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-09- 146A1.pdf
INTER TECH FM. Notified of a $7,000 forfeiture for marketing unauthorized equipment (47 USC 302(b); 47 CFR 2.803(a)(2)), and an $11,000 forfeiture for providing incorrect material factual information without a reasonable basis (47 CFR 1.17(a)(2). Adopted: 01/29/2009 by NAL. (DA No. 09-147). – http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-09- 147A1.pdf POWER 7 TECHNOLOGY CORPORATION. Issued a $25,000 proposed monetary forfeiture for marketing unauthorized radio frequency devices. Action by: Chief, Spectrum Enforcement Division, Enforcement Bureau. Adopted:02/17/2009 by NAL. (DA No. 09-253). EB – http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-09- 253A1.pdf MRA International Workshop March 4, 2009 2009 Tokyo, Japan 47 Enforcement Actions Continued
HUMAX CO., LTD. Adopted a Consent Decree terminating an investigation into equipment marketing violations by Humax. Action by: Chief, Enforcement Bureau. Adopted: 02/12/2009 by ORDER. (DA No. 09-214). EB $15,000 http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-09-214A1.pdf AUDIOVOX CORPORATION. Adopted a Consent Decree terminating an investigation into possible equipment marketing violations by Audiovox. Action by: Chief, Enforcement Bureau. Adopted: 02/12/2009 by ORDER. (DA No. 09-229). EB $5,000 http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-09-229A1.pdf WISTRON NEWEB CORPORATION. Adopted a Consent Decree terminating an investigation into equipment marketing violations by Wistron NeWeb. Action by: Chief, Enforcement Bureau. Adopted: 02/12/2009 by ORDER. (DA No. 09-215). EB $30,000 http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-09-215A1.pdf KI RYUNG ELECTRONICS CO., LTD. Adopted a Consent Decree terminating an investigation into whether certain satellite radio equipment manufactured and sold by KRI in Korea and China and imported and marketed in the United States by third parties comply with FCC Rules. Action by: Chief, Enforcement Bureau. Adopted: 02/12/2009 by ORDER. (DA No. 09-226). EB $30,000 http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-09-226A1.pdf
MRA International Workshop March 4, 2009 2009 Tokyo, Japan 48 Summary FCC – Overview – Regulations – Equipment Authorization Process TCB – Requirements & responsibilities MRA – Overview – Statistics Post Grant Surveillance & Enforcement Information sources
MRA International Workshop March 4, 2009 2009 Tokyo, Japan 49 Information On Line
Equipment Authorization Webpage – Measurement techniques, explanation of EA programs, filing information, MRAs, TCBs, EA announcements, etc.: http://www.fcc.gov/oet/ea/ Procedures for information sharing and distribution – Updated Interpretation Database & new contact desk for web based inquiries: http://www.fcc.gov/labhelp OET Info on line (Orders, Public Notices, etc.) – http://www.fcc.gov/oet/info/ FCC Rules and Regulations: – http://www.fcc.gov/oet/info/rules General FCC Information: – http://www.fcc.gov FCC MRA Webpage – www.fcc.gov/oet/ea/mra MRA International Workshop March 4, 2009 2009 Tokyo, Japan 50 Thanks!
MRA International Workshop March 4, 2009 2009 Tokyo, Japan 51