Mutual Recognition Agreement
(MRA) International Workshop
2009 Tokyo, Japan
Overview of FCC Requirements
March 4, 2009
George Tannahill
FCC Lab - Technical Research Branch
george.tannahill@fcc.gov
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
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MRA International Workshop
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
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2009 Tokyo, Japan
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FCC Organizational Chart
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2009 Tokyo, Japan
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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
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2009 Tokyo, Japan
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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
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2009 Tokyo, Japan
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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.
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2009 Tokyo, Japan
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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
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2009 Tokyo, Japan
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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
•
•
•
•
March 4, 2009
Part
Part
Part
Part
11:
20:
22:
24:
Emergency Alert Systems (EAS)
Commercial Mobile Radio Services
Public mobile services
Personal communication services
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2009 Tokyo, Japan
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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
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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
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2009 Tokyo, Japan
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Equipment Authorization Program
Maximum
The type of approval
is specified in the
rules
for the particular
type of device
Certification
(Approved by FCC
or TCB)
DoC
(Self-approval using
an accredited lab)
SDoC (Part 68)
(Self-approval
Database by ACTA)
Minimum
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2009 Tokyo, Japan
Verification
(Self-approval)
12
FCC Authorization Requirements
Verification
Most ISM
Equipment
TV & FM
Receivers
All Other Digital
Devices
Pt-to-Pt
Microwave
Broadcast
Transmitters
Aux. Broadcast
Transmitters
INMARSAT
Equipment
406 MHz ELT
SDoC
DoC
Certification
Cable System
Term. Device
PC’s & Peripherals
PC’s & Peripherals1
Most Receivers
Most Receivers
TV Interface
Devices
Consumer ISM
Equipment
TV Interface Devices
Telephone
Equipment
Consumer ISM
Equipment
Telephone
Equipment1
Most transmitters
Scanning Receivers
CATV Relay
Transmitters
(1)
March 4, 2009
The FCC Lab no longer certifies this equipment. However, this equipment may be certified by a TCB.
MRA International Workshop
2009 Tokyo, Japan
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Equipment Authorization Top Ten
Certification Equipment Classes
Percent vs Equipment Class
20
18
16
14
12
10
8
6
4
2
0
March 4, 2009
DTS DXX DSS PCE
JBP
DSC TNB NII
MRA International Workshop
2009 Tokyo, Japan
PCB 8CC
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
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86.7
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
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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.)
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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)
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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
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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
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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
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Application for Certification
Information
2.1033(b)Part11,15,18
– Name, address
– FCCID
– User/installation
Manual
– Circuit Description
– Block Diagram
– Schematics (when
required)
– Measurement Report
– Photos
• Internal, external,
setup
March 4, 2009
2.1033(c) Other Parts
– Name, address
– FCCID
– User/installation
Manual
– Circuit Description
– Emission Type
– Frequency Range
– Power levels & max.
– Tune Up procedure
– Schematics
– Measurement Report
– Photos
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2009 Tokyo, Japan
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FCC/TCB Certifcation Process
Comparison
Pay for
TCB
Services
Product is entered into the
FCC Database through
Form 731
Support Information
is uploaded
Product is entered into the
FCC Database
Processing
Grant is Issued
Product is Tested
Completes
Form 731
Grant is Issued
FCC Fees
If no problems are found a
Grant is issued.
Questions and Answers
Examiner Review
Manufacturer’s Product
March 4, 2009
Engineer Review
MRA International Workshop
2009 Tokyo, Japan
The review process is
between 30 – 45 days
23
Equipment Authorization
Certification Process Trends
12000
10000
Authorized by
FCC
8000
6000
Authorized by
TCBs
4000
2000
Total New
Authorizations
20
01
20
02
20
03
20
04
20
05
20
06
20
07
20
08
0
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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
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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.
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2009 Tokyo, Japan
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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
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2009 Tokyo, Japan
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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
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2009 Tokyo, Japan
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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
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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
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Identification of US Players
Regulatory
Authority (RA)
Federal Communications
Commission (FCC)
Designating
Authority (DA)
National Institute of Standards www.nist.gov
and Technology (NIST)
Accreditation Body
(Phase 1)
National Voluntary Lab
www.nist.gov
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)
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2009 Tokyo, Japan
www.fcc.gov
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
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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
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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
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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
March 4, 2009
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2009 Tokyo, Japan
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Accreditation Requirements
MRA Phase I/EMC
Arrangement
– Regulatory Authority
– Designating Authority
– Accrediting Body
• ISO17011
– CAB
• ISO 17025
March 4, 2009
MRA Phase II/Japan MRA
– Regulatory Authority
– Designating Authority
– Accrediting Body
• ISO17011
– CAB
• ISO 65
• ISO 17025
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2009 Tokyo, Japan
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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.
March 4, 2009
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2009 Tokyo, Japan
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MRA Status – Phase I/EMC
Arrangement
Phase I/EMC Arrangement
(mutual acceptance of
test data) is operational
with the following
countries:
•
•
•
•
•
•
Australia
Canada
Chinese Taipei
European Union
Hong Kong, China
Japan
– 60 recognized
• Korea
• Singapore
• Vietnam
March 4, 2009
Region
North
America
Europe
Asia
Middle
East
Total
MRA International Workshop
2009 Tokyo, Japan
Number of
Labs
91
47
125
3
266
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
March 4, 2009
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2009 Tokyo, Japan
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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
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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.
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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/2009MRA-Workshop.cfm
FCC Knowledge Database
– www.fcc.gov/labhelp
Beta Test/Practice Website
– https://selafoss.fcc.gov/tcb/index.html
March 4, 2009
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TCB/Accreditor Filing Webpage
March 4, 2009
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TCB Login Homepage
March 4, 2009
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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
March 4, 2009
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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
March 4, 2009
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2009 Tokyo, Japan
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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-09146A1.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-09147A1.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-09253A1.pdf
March 4, 2009
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2009 Tokyo, Japan
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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
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Summary
FCC
– Overview
– Regulations
– Equipment Authorization Process
TCB
– Requirements & responsibilities
MRA
– Overview
– Statistics
Post Grant Surveillance & Enforcement
Information sources
March 4, 2009
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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
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Thanks!
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