ACB
EN 300 328 V1.8.1
Michael Derby
ACB Europe
9 April 2014
Introduction
• American Certification Body
• TCB, FCB, RCB, Notified Body
• Notified Body to the R&TTE Directive
• Michael Derby
• Regulatory Engineer, TCB, FCB, Notified Body
• EMC and Radio Test Engineer for many years
• Previously on ETSI TG11 (EN 300 328)
Introduction of Presentation
• EN 300 328 (primary focus here is V1.8.1)
• The standard is used by many people
• Quick poll?
• Applicable to WLAN, Bluetooth, Zigbee, etc.
• Does not exclude other device types or technologies
• 2.4 GHz frequency band is very busy
• Significant changes observed in the last few years
• Sensitive, provocative, controversial topic
• Chris is on standby!
Introduction of Presentation
• Agenda
• Only 45 minutes… don’t expect many numbers!
• Deleted text in favour of ‘future’ section
• European Regulatory process for R&TTE
• Standards, Decisions, Notified Body, Directive
• Harmonised Standards, Official Journal, DoC
• EN 300 328
• History and technical requirements
• Changes to the test methods
• The future
European Compliance
• Process for authorising radios in Europe
• The R&TTE Directive
• It’s a ‘Declaration of Conformity’ Directive
• The DoC is to the Directive
• Not a certification to the standard
• Dynamic DoC applies each day to each unit
• Harmonised Standards
• Simple way to ‘presume’ compliance with Directive
• Standards are listed in the Official Journal
European Compliance
• Hierarchy within the system:
R&TTE Directive
↑
Notified Body
↑
(Commission Decision)
↑
Harmonised Standards
DoC and HS
• Harmonised Standards (HS)
• Used to give “presumption of conformity” to
the manufacturer (or who placing on market)
• Declaration of Conformity (DoC)
• Applies on each new day, to each new unit
• Helps with technology and interference issues
• Notified Body statement of opinion
• DoC, when Harmonised Standard not applied
• Or does not (fully) comply with HS
Official Journal (OJ)
• Official Journal on Europa website
• Updated periodically
• Perhaps once per year (though request for more)
• List of current harmonised standards (and version)
• A transition period with superseded standards
• OJ explains dates of transition
• New standards added without transition
• In rare cases, a ‘note’ is added to the OJ
• As with EN 300 328 V1.7.1, since 2009
EN 300 328 History
• EN 300 328 V1.6.1 (2004-11)
• No specific spectrum sharing requirements
for non FHSS transmitters
• Expired from OJ on 30 June 2008
EN 300 328 History
• EN 300 328 V1.7.1 (2006-10)
• Medium Access Protocol is mandatory (“U”)
• No test methods presented in the HS
• If using HS route (Annex III of R&TTE D)
• Manufacturer responsible for own decision
• If using NB route (Annex IV of R&TTE D)
• NB assess spectrum sharing (esp. non-WLAN)
• For WLAN, it ‘was’ assumed that 802.11 was ok
EN 300 328 History
• EN 300 328 V1.7.1 (2006-10)
• Note added to OJ on 15 December 2009
• Spectrum sharing, DAA, LBT is required for HS
• Explained that draft V1.8.1 was in progress
• Confirmed ‘mandatory’ nature of requirement
• Note added to OJ on 23 October 2012
• Spectrum sharing tests of V1.8.1 to be used for HS
• Reaffirmed mandatory nature of requirement
• V1.7.1 (including additional note) will cease
HS on 31 December 2014
EN 300 328 History
• EN 300 328 V1.7.1 (2006-10)
• Why is spectrum sharing such a surprise?
•
•
•
•
•
•
Manufacturers assumed labs were doing it?
Labs assumed manufacturers were doing it?
Innocent ignorance of the requirements?
Lazy avoidance of the full requirements?
Lack of regulatory knowledge?
Genuine misunderstanding of WLAN technology?
EN 300 328 History
• EN 300 328 V1.8.1 (2012-06)
• Added to the OJ on 23 October 2012
• Spectrum sharing requirements mandatory
• Medium Access Protocol replaced by ‘Adaptivity’
• Test methods introduced for various technologies
• (To be clarified on later slides)
• Clearer requirements and test methods
• As requested by TCAM, European Commission;
and Industry
EN 300 328 History
• Reasons for change:
• Interference in the band
• TCAM statement that 2.4 GHz band must be
technology neutral
• 2.4 GHz is a busy band
• Something needed to be done
• “Medium Access Protocol” was in the standard
• Requirement was mostly ignored
• Therefore detailed test methods were required
• ETSI instructed to create these test cases
• European Commission and TCAM
EN 300 328 History
• Reasons for change:
• Power measurement challenges
• Medium Utilisation (MU) required a test method that
captures and stores values for burst power and
duration over a long observation period
• Noting that power can change from burst to burst
• Many existing technologies have variable duty cycle
• Regulators and MSA want ‘real life’ test methods
• No customised test modes permitted
• Cannot use non-realistic test modes
EN 300 328 History
• Choice of test methods:
• Test methods are written by the attendees at
the ETSI meetings
• Test labs, manufacturers, regulators
• I used to attend as a test lab representative
• The ‘various options’ in previous versions
• Presently, the TCB Council is not a contributor
EN 300 328 History
• Final Draft EN
300 328 V1.8.2 (2014-04)
• Download now from ETSI website
• Now in the final phase of National vote
• Not on the OJ
• It’s a draft
• Some changes
• Discussed at the end of this presentation
• It will become EN 300 328 V1.9.1
Essential V1.7.1
Essential V1.8.1
V1.7.1 verses V1.8.1
EN 300 328 V.1.7.1
EN 300 328 V.1.8.1
E.I.R.P.
Output Power / E.I.R.P.
Spectral Power Density
(non-FSS only)
Spectral Power Density
(non-FSS only)
Frequency Range
Occupied Bandwidth
Transmitter Out-of-Band Emissions
Hopping, Channels and Dwell Time
(FHSS only)
Hopping, Channels and Dwell Time
(FHSS only)
Medium Access Protocol
Adaptivity (Adaptive)
Receiver Blocking (Adaptive)
Duty Cycle & Utilisation (non-Adaptive)
Transmitter Spurious Emissions
Transmitter Spurious Emissions
Receiver Spurious Emissions
Receiver Spurious Emissions
New Requirements of V1.8.1
• Disclaimer:
Read the standard for full details!
• We will discuss some of the most significant
new additions in EN 300 328 V1.8.1
• There is not enough time to go through each
section in detail, of course
New Requirements of V1.8.1
• Equipment Types: Operation of the EUT
• Adaptive and non-Adaptive modes, modes of
operation, modulations, channel utilisation,
number of transmitter chains, antennas, etc.
• All to be declared to the test lab, by manufacturer
• Testing route will depend on the declaration
• Annex E of EN 300 328 V1.8.1 gives sample form
• This should be included in the test report
• Not appearing in many test lab’s reports!
New Requirements of V1.8.1
• Equipment Types:
• Section 4.2.2 – Explanation of “Adaptive
Equipment” and “Non-Adaptive Equipment”
• Adaptive equipment uses automatic mechanisms
for avoiding interference with other radios
• Non-adaptive equipment uses alternative means to
reduce interference with other radios,
such as low duty cycle or low spectrum utilisation
• This is common to other ETSI EN standards
• Such as EN 300 220, EN 300 440, etc.
New Requirements of V1.8.1
• Extreme Test Conditions:
• Section 5.1 – Extreme temperature & voltage
• Previously dictated by the standard
• Now it is at the declaration of the manufacturer
• Note that reasonable guidance does exist
• EN 300 019 series of standards
• Gives recommended levels for location types
New Requirements of V1.8.1
• General layout of the standard
• Split between FHSS and non-FHSS devices
• Within each section (FHSS & non-FHSS), there is
a split between adaptive and non-adaptive devices
• Adaptive FHSS can be silent on occupied
channels or jump immediately to next channel
• Adaptive non-FHSS choose/avoid channels
• Adaptivity or low MU (interference reduction)
only applies to devices >10 mW e.i.r.p.
New Requirements of V1.8.1
• Technical: Output Power
• Applies to FHSS and non-FHSS
• Limit is still 20 dBm (100 mW), e.i.r.p.
• Fast Power Sensor of minimum 1 MS/s is needed
• Spectrum Analyser or ‘normal’ power meter not used
• FHSS equipment tested while hopping during
normal operation mode
• Non-FHSS tested on three channels (B, M, T)
during normal operation mode
New Requirements of V1.8.1
• Technical: Output Power
• Test method is quite lengthy and complicated
• Duty cycle correction no longer used
• Sensor captures data for processing to find burst power
• MIMO test synchronised on all ports together
• Storage of data and processing
• Gating of power sensors
• It’s different to the method used before
• Signals of varying duty cycle
• Linked to MU; a calculation of power and time
New Requirements of V1.8.1
• Technical: Power Spectral Density
• Applies to non-FHSS only
• Limit is still 10 dBm/MHz, e.i.r.p.
• Test method is new
• Different RBW and settings
• Use 10 kHz RBW to measure multiple 1 MHz segments
• Analyse to find the worst one
• Post test data processing required
New Requirements of V1.8.1
• Technical: Occupied Channel Bandwidth
• Applies to FHSS and non-FHSS
• Based on 99% bandwidth
• Must fall completely within band (band edge)
• Partly replaces the old Frequency Range test
• For non-Adaptive FHSS with >10 mW, e.i.r.p.
• Limit: <5 MHz
• For non-Adaptive non-FHSS with >10 mW, e.i.r.p.
• Limit: <20 MHz
New Requirements of V1.8.1
• Technical: Occupied Channel Bandwidth
• Top and Bottom channels to be tested
• For FHSS, it is a test of an individual hopping
channel
• Not the whole hopping band
• May need to stop the hopping to test
New Requirements of V1.8.1
• Technical: Tx Emissions out-of-band
• Applies to FHSS and non-FHSS
• This is really a ‘band edge’ type of test
New Requirements of V1.8.1
• Technical: Tx Emissions out-of-band
• Measured in the time domain (zero Hz)
• Multiple plots for multiple segments
• Tested at nominal and extreme conditions
• (Only at nominal in EN 300 328 V1.8.2)
New Requirements of V1.8.1
• Technical: Tx Spurious Emissions
• Applies to FHSS and non-FHSS
• Limits and RBW requirements are new
• V1.7.1 was not aligned with other ETSI standards
• Based on ERC Recommendation 74-01
• Lower limits in sensitive broadcast bands
• New (aligned) resolution bandwidth above 1 GHz
• No differentiation between narrow and wide band
• Procedure for final measurements is different
• In general, requirements are now (correctly) tougher
New Requirements of V1.8.1
• Technical: Tx Spurious Emissions
New Requirements of V1.8.1
• Technical: Tx Spurious Emissions
• Test can be done radiated with antenna connected
• Test can be done conducted from the antenna port
and then additionally from the cabinet with the
antenna port terminated
New Requirements of V1.8.1
• Technical: Rx Spurious Emissions
• Applies to FHSS and non-FHSS
• Limits are the same as V1.7.1
• RBW requirements are different!
• V1.7.1 was not aligned with other ETSI standards
• New (aligned) resolution bandwidth above 1 GHz
• No differentiation between narrow and wide band
• Procedure for final measurements is different
• In general, requirements are now (correctly) tougher
New Requirements of V1.8.1
• Technical: Rx Spurious Emissions
New Requirements of V1.8.1
• Technical: Spectrum Sharing
• Reducing interference within the band
• TCAM: “Ensuring equal access to all and in case
of congestion, graceful degradation to all”
• Two main ways to achieve this:
• Adaptivity
• Detect and avoid (DAA)
• Clear Channel Assessment (CCA)
• Listen Before Talk (LBT)
• Low medium utilisation (power and time)
• Reduce power, or duty cycle, or both
New Requirements of V1.8.1
• Technical: Spectrum Sharing
• Adaptive and non-Adaptive modes
• It is possible that a device could have both modes
• It is not always possible to define the 'Equipment’
• If a device has both modes, then each mode must
comply with the requirements for that mode
• Example might be Bluetooth with Low Energy mode
New Requirements of V1.8.1
• Technical: Spectrum Sharing (idealistic)
Yes
e.i.r.p. <10 mW
No
Adaptive
Yes
No
MU < 10%
Yes
No
Fail
Pass
New Requirements of V1.8.1
• Technical: Spectrum Sharing (idealistic)
• Note that whilst some devices ‘should’ meet
the requirements, the tests exist for a reason
• Devices which are supposed to be ‘adaptive’
may fail to meet the tests if the adaptive
firmware is not correctly set, or has been
disabled, or could be disabled
• This needs to be considered with regard to the
set-up access an installer might have
• User cannot be permitted to cause non-compliance
New Requirements of V1.8.1
• Technical: FHSS Requirement
• Dwell Time test and limit
• Adaptive Equipment; silent on busy channels
• 400 mS in 400 mS x Channels
• (e.g., 31.6 seconds for 79 channel Bluetooth)
• Requirement is like FCC
• Non-Adaptive Equipment; always transmitting
while hopping but ‘blacklisting’ is permitted
New Requirements of V1.8.1
• Technical: FHSS Requirements
• Hopping Frequency Separation
• Adaptive and Non-Adaptive Equipment / Mode
• Adaptive Equipment limit: >100 kHz
• Non-Adaptive limit: >Occupied Bandwidth with a
minimum of 100 kHz
New Requirements of V1.8.1
• Technical: FHSS Requirements
• Duty Cycle, Tx Sequence, Tx Gap
• Non-Adaptive Equipment or Mode
• Only applies to devices with >10 mW, e.i.r.p.
•
•
•
•
•
•
MU approach is used
Tx Sequence is transmission (single or multi channel)
Tx Gap is silent period between transmissions
Tx Sequence <5 mS
Tx Gap >5 mS
Maximum duty cycle is 50%
New Requirements of V1.8.1
• Technical: Non-FHSS Requirements
• Duty Cycle, Tx Sequence, Tx Gap
• Non-Adaptive Equipment or Mode
• Only applies to devices with >10 mW, e.i.r.p.
• Tx Sequence is transmission (or burst)
• Tx Gap is silent period between transmissions
• Maximum duty cycle is 50%
• Max Tx Sequence = Min Tx Gap = ‘M’
• ‘M’ must be in range 3.5 mS to 10 mS
• Observed over a 1 second period
New Requirements of V1.8.1
• Technical: FHSS / Non-FHSS Requirement
• Medium Utilisation Factor (MU)
• Non-Adaptive Equipment or Mode only
• Only applies to devices with >10 mW, e.i.r.p.
• MU(%) = (Pburst/100 mW) x Duty Cyle %
• Device may have dynamic MU
• Power level and duty cycle varying over time
• Less power will allow higher duty cycle
• MU limit is 10%
• 100 mW power would require 10% duty cycle
• 50% duty cycle would require 20 mW power
New Requirements of V1.8.1
• Technical: FHSS Requirements
• Adaptivity
• Adaptive Equipment or Mode only
• Only applies to devices with >10 mW, e.i.r.p.
• Uses DAA mechanism to identify used frequencies
• May be LBT; check availability before transmission
• Or; check availability after transmission (BER or PER)
• Detection or reaction thresholds proportional to
output power, e.i.r.p.
New Requirements of V1.8.1
• Technical: Non-FHSS Requirements
• Adaptivity
• Adaptive Equipment or Mode only
• Only applies to devices with >10 mW, e.i.r.p.
• Uses DAA mechanism to identify used frequencies
• May be LBT; check availability before transmission
• Or; check availability after transmission (BER or PER)
• Clear Channel Assessments
• Detection or reaction thresholds proportional to
output power, e.i.r.p.
New Requirements of V1.8.1
• Technical: Non-FHSS Adaptivity
• Two main types of non-FHSS are described
• Frame Based equipment and Load Based equipment
• Frame Based equipment
• Transmit/Receive structure is not demand driven
• Load Based equipment
• Transmit/Receive structure is demand driven
• Test method looks similar to DFS
• Or blocking found with many other radio types, such as
Fixed Links or Cellular Base Stations
• Includes other than co-channel interference
New Requirements of V1.8.1
• Technical: Receiver Blocking
• Applies to FHSS and non-FHSS
• Adaptive Equipment or Mode only
• Only applies to devices with >10 mW, e.i.r.p.
• Uses DAA mechanism to identify used frequencies
• May be LBT or may be ‘other’ (such as real interference)
• In-band interfering CW signal at -30 dBm
• (Change to -35 dBm in EN 300 328 V1.8.2)
• Ability to detect and avoid other signals
• Or blocking found with Fixed Links or Base Stations
New Requirements of V1.8.1
• Evaluation: New HS exists!
• Can we re-use old test data for DoC?
• Realistically, no
• Too many differences in test methods
• This standard involves a lot of changes and
devices will need to be reassessed
• This includes existing devices which will continue
to be placed on the market or put into service
• A test report to V1.7.1 will not meet V1.8.1
New Requirements of V1.8.1
• Evaluation: Notified Body opinion?
• Can we re-use old test data for DoC?
• Most likely, no
• Must show compliance with latest requirements
• Notified Body can be useful for test methods
• A Notified Body could provide a positive opinion
for the DoC, based on alternative test methods
• Must demonstrate compliance with equivalent
protection and performance levels
EN 300 328 History
• Final Draft EN
300 328 V1.8.2 (2014-04)
• Some changes
• Significant changes to requirements for
Adaptive Frequency Hopping Devices
• “Dwell Time” changed to “accumulated Tx time”
• Definition but also scope of measurement
• May resolve some misunderstandings
• Significant changes to hopping time methods
• Significant changes to hopping limits and measurements
• May fix the reported problems
EN 300 328 History
• Draft EN
300 328 V1.8.2 (2014-04)
• Some changes
• Significant changes to requirements for
Adaptive non-Frequency Hopping Devices
• Significant changes for Load Based LBT DAA
• Changes to methods
• Significant changes to measurements and values
• Value “q” removed from standard
• Random factor “R” removed from standard
• Both of these quantities were causing confusion
EN 300 328 History
• Draft EN
300 328 V1.8.2 (2014-04)
• Output Power test method
• Start/Stop of burst at 30 dBc, instead of 20 dBc
• Sweep time change in Power Density and Hopping tests
• Adaptivity Test Method
• Some changes to values
• Clear definition of adaptivity interfering signal
• Continued channel monitoring (for FHSS)
EN 300 328 History
• Draft EN
300 328 V1.8.2 (2014-04)
• Spurious Emissions
• Change to sweep time and the number of sweep points
• Clarification that conducted antenna port emissions also
requires a radiated cabinet test
• Change of detector type
• EN 300 328 V1.9.1
• Will be the same as V1.8.2.
• If V1.8.2 passes national voting it will be published as V1.9.1
• Expected to be published in OJEU early 2015
EN 300 328 V1.9.1
• Future: Next version of the standard
• Timeline
• Pressure on ETSI to deliver a standard in 2014
• We do not expect a published version of V1.9.1
until sometime in 2015
• It is likely that V1.8.1 will be the only harmonised
version of the standard for some time in 2015
• Of course it is always possible to use Draft V1.8.2
and obtain a Notified Body opinion
EN 300 328 V1.9.1
• Future: Next version of the standard
• New Work Item approved for V1.10.1
• Is part of a political agreement to give the
Automation Industry the possibility to come with
new adaptive mechanisms (alternative mech.)
• Could be used to add alternative test methods to
the complex new methods, at least for equipment
with continuous transmissions, or equipment with
constant duty cycles (not WIFI)
Questions?
• Contacts:
• michaeld@acbcert.com
• www.acbcert.com