Mutual Recognition Agreement (MRA) International Workshop 2009 Tokyo, Japan Overview of FCC Requirements
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1 Mutual Recognition Agreement (MRA) International Workshop 2009 Tokyo, Japan Overview of FCC Requirements George Tannahill FCC Lab - Technical Research Branch george.tannahill@fcc.gov Office of Engineering and Technology Federal Communications Commission 1
2 Overview FCC Overview FCC Regulations Equipment Approval Process General information TCB information MRA information Post Grant Surveillance TCB Implementation/Operations Information Sources 2009 Tokyo, Japan 2
3 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 2009 Tokyo, Japan 3
4 FCC Organizational Chart 2009 Tokyo, Japan 4
5 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 2009 Tokyo, Japan 5
6 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 2009 Tokyo, Japan 6
7 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 Tokyo, Japan 7
8 FCC Administrative Regulations 47 CFR Part & Confidentiality 47 CFR Part & RF Exposure 47 CFR Part 2 Subpart I Marketing Subpart J Equipment Authorization Emission designators Authorization Types ID Labels Application for Certification Permissive Changes General tests for licensed devices Subpart K Importation of Devices 2009 Tokyo, Japan 8
9 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 2009 Tokyo, Japan 9
10 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 2009 Tokyo, Japan 10
11 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 OET Website for Equipment Authorization General Information: Tokyo, Japan 11
12 Equipment Authorization Program The type of approval is specified in the rules for the particular Maximum Certification (Approved by FCC or TCB) DoC (Self-approval using an accredited lab) type of device SDoC (Part 68) (Self-approval Database by ACTA) Minimum Verification (Self-approval) 2009 Tokyo, Japan 12
13 FCC Authorization Requirements Verification SDoC DoC Certification Most ISM Equipment Cable System Term. Device TV & FM PC s & Peripherals PC s & Peripherals 1 Receivers All Other Digital Most Receivers Most Receivers Devices Pt-to-Pt TV Interface TV Interface Devices Microwave Devices Broadcast Transmitters Consumer ISM Equipment Consumer ISM Equipment Aux. Broadcast Transmitters Telephone Equipment Telephone Equipment 1 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 Tokyo, Japan 13
14 Equipment Authorization Top Ten Certification Equipment Classes Percent vs Equipment Class DTS DXX DSS PCE JBP DSC TNB NII PCB 8CC 2009 Tokyo, Japan 14
15 Equipment Authorization Classifications Category Description Percent Rules DTS Digital Transmission System C DXX Part 15 Low Power Communication Device Transmitter C DSS Part 15 Spread Spectrum Transmitter C JBP Part 15 Class B Computing Device Peripheral B PCE PCS Licensed Transmitter held to ear 9 Licensed 24 DSC Part 15 Security/Remote Control Transmitter C TNB Licensed Non-Broadcast Station Transmitter 4.4 Licensed 22 PCB PCS Licensed Transmitter 4.1 Licensed 24 NII Unlicensed National Information Infrastructure TX E 8CC Part 18 Consumer Device 1 18 Total Tokyo, Japan 15
16 General Equipment Types License Exempt Devices Parts 15 & 18 Incidental Radiator - Parts & 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 2009 Tokyo, Japan 16
17 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 MHz TV interface devices (VCRs, cable terminal devices, etc.) 2009 Tokyo, Japan 17
18 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) 2009 Tokyo, Japan 18
19 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 2009 Tokyo, Japan 19
20 Telephone Terminal Regulations 47 CFR Part 68 Telephone Terminal Equipment (TTE) Public Switched Telephone Network (PSTN) Private Line Interfaces Analog Interfaces Digital Interfaces Tokyo, Japan 20
21 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 2009 Tokyo, Japan 21
22 Application for Certification Information (b)Part11,15,18 Name, address FCCID User/installation Manual Circuit Description Block Diagram Schematics (when required) Measurement Report Photos Internal, external, setup (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 2009 Tokyo, Japan 22
23 Pay for TCB Services FCC/TCB Certifcation Process Comparison Product is entered into the FCC Database through Form 731 Support Information is uploaded Grant is Issued Product is Tested Completes Form 731 Product is entered into the FCC Database Processing Grant is Issued FCC Fees If no problems are found a Grant is issued. Questions and Answers Examiner Review Manufacturer s Product Engineer Review The review process is between days 2009 Tokyo, Japan 23
24 Equipment Authorization Certification Process Trends Authorized by FCC Authorized by TCBs Total New Authorizations 2009 Tokyo, Japan 24
25 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 2009 Tokyo, Japan 25
26 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 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 Tokyo, Japan 26
27 TCB Scope of Responsibility TCB (see (e) and Public Notice, DA ) 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 2009 Tokyo, Japan 27
28 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 2009 Tokyo, Japan 28
29 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 2009 Tokyo, Japan 29
30 MRA Webpage Organizes all FCC related MRA information in one location: 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 2009 Tokyo, Japan 30
31 Identification of US Players Regulatory Authority (RA) Designating Authority (DA) Accreditation Body (Phase 1) AB (Phase 2) Federal Communications Commission (FCC) National Institute of Standards and Technology (NIST) National Voluntary Lab Accreditation Program (NVLAP) & American Association of Lab Accreditation (A2LA) American National Standards Institute (ANSI) American Association for Laboratory Accreditation (A2LA) Tokyo, Japan 31
32 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 2009 Tokyo, Japan 32
33 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 2009 Tokyo, Japan 33
34 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, Gaithersburg NIST May 4-8, 2009 Information on US-Japan MRA: Tokyo, Japan 34
35 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 2009 Tokyo, Japan 35
36 Accreditation Requirements MRA Phase I/EMC Arrangement Regulatory Authority Designating Authority Accrediting Body ISO17011 CAB ISO MRA Phase II/Japan MRA Regulatory Authority Designating Authority Accrediting Body ISO17011 CAB ISO 65 ISO Tokyo, Japan 36
37 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 Tokyo, Japan 37
38 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 Region North America Number of Labs 91 Europe 47 Asia 125 Middle 3 East Total Tokyo, Japan 38
39 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 2009 Tokyo, Japan 39
40 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 2009 Tokyo, Japan 40
41 Process Summary (continued) How to authorize equipment: Log on to FCC Equipment Authorization Website: Go to 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 Tokyo, Japan 41
42 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 MRA-Workshop.cfm FCC Knowledge Database Beta Test/Practice Website Tokyo, Japan 42
43 TCB/Accreditor Filing Webpage 2009 Tokyo, Japan 43
44 TCB Login Homepage 2009 Tokyo, Japan 44
45 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 KDB rchresultpage.cfm?id=20540&switch=p Other General public complaints/testing Competitors complaints/testing 2009 Tokyo, Japan 45
46 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 2009 Tokyo, Japan 46
47 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 ). 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 ). 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 ). EB Tokyo, Japan 47
48 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 ). EB $15,000 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 ). EB $5,000 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 ). EB $30,000 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 ). EB $30, Tokyo, Japan 48
49 FCC Summary Overview Regulations Equipment Authorization Process TCB Requirements & responsibilities MRA Overview Statistics Post Grant Surveillance & Enforcement Information sources 2009 Tokyo, Japan 49
50 Information On Line Equipment Authorization Webpage Measurement techniques, explanation of EA programs, filing information, MRAs, TCBs, EA announcements, etc.: Procedures for information sharing and distribution Updated Interpretation Database & new contact desk for web based inquiries: OET Info on line (Orders, Public Notices, etc.) FCC Rules and Regulations: General FCC Information: FCC MRA Webpage Tokyo, Japan 50
51 Thanks! 2009 Tokyo, Japan 51
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