FCC Regulations: Procedural Updates for Electronic and Radio Equipment

The Code of Federal Regulations – the US Code of Federal Regulations which contains, among other aspects, the regulations for electronic and telecommunications equipment - has recently undergone important updates. These make it useful, if not necessary, to provide an overview of some application details of the rules themselves. Clearly the Federal Code is very complex, consequently what follows is a general analysis valid for most equipment, however each case needs to be evaluated individually.

Title 47 of the Code of Federal Regulations

Taking a step back, as is known, the Federal Communications Commission (FCC) defines regulations for different types of electronic equipment, including radio frequency devices, telecommunications terminals, and industrial, scientific, and medical equipment. The regulations are contained in the sections of Title 47 of the aforementioned Code of Federal Regulations.

Specific parts of this section of the Code are examined, which define an important distinction between the types of products. Reference is made to unintentional radiators and intentional radiators, inserting in the first category all those products that do not intentionally emit radio frequencies - such as electronic and IT devices without radio transmitters - and leaving in the second category those that intentionally emit radio frequencies, such as such as radio transmitting equipment.

In the Part 15 of the Title to which reference is made, the limit quantity of electromagnetic interference emitted by intentional emitters, radio devices that transmit without requiring a license, and non-intentional emitters, electrical devices that contain a digital circuit inside them and which operate at a frequency above 9kHz. Specifically, Part 15B sets out the rules for unintentional radiators and Part 15C for intentional radiators.

Certification and Declaration of Conformity

In relation to the type of product and equipment for which approval is requested, the compliance with FCC requirements is demonstrated following two different procedures.

The Suppliers' Declaration of Conformity (SDoC) which can be carried out by the manufacturer with the help of a equipped laboratory to carry out the necessary tests. The SDoC is applicable for a series of products such as electronic and IT products without radio transmitters and products that integrate one or more radio modules already FCC certified and which do not require the execution of SAR tests, which is discussed in more detail in the next paragraph.

The procedure called "Certification" involves the execution of tests at a FCC accredited laboratory and the involvement of a Telecommunications Certification Body. The TCB also takes care of uploading the documentation to the FCC website (including test reports).

This procedure requires the company responsible for the product to obtain a from the FCC identifier called Grantee Code. This identifier is required only once and will constitute the first characters of all FCC ID codes that will be assigned to the various products of that company.

Furthermore, the nomination of is requested an FCC US Agent, responsible for representing the manufacturer or importer in all interactions with the FCC regarding the certification and authorization of their equipment. The agent must have based in the United States and be authorized to receive legal notifications and other official documents on behalf of the manufacturer or importer.

The need for SAR testing

The SAR tests they are required and necessary in the case of products that require their use with the radiating part (antenna) less than 20 cm from the body. An exception is made to products that satisfy one of the following characteristics:

radio power transmitted, averaged over time, overall of all transmitters less than 1 mW (also valid for implanted devices);
power of each transmitter, averaged over time, less than 1 mW and distance between the relative radiating parts greater than 2 cm;
for multiple transmitters that do not operate simultaneously and that individually comply with one of the above rules;

Furthermore, there are other exclusion conditions depending on the power and frequency of the transmitters which require a detailed calculation, very specific to be able to be explored in detail here.

In all other cases, except those just listed, the following is followed “Certification” procedure as described above.

To launch their products on the US market safely and quickly, companies are required to certify that the products to be placed on the market comply with the technical requirements established by the regulations.

Sicom Testing offers its customers a full service FCC marking for all the cases indicated above, included company registration with FCC (Grantee Code) and the function of responsible representative agent. Similar services are also offered for Canada in accordance with specific regulations.