2010

• This is a copy of an article Mike Violette prepared that ran in In Compliance magazine in April. This was written with the cooperation of the APEC TEL MRA working group members.
  04/01/2010
  
  Fostering International Trade: Ten Years of MRA Success by the APEC TEL MRA Task Force... full article here in PDF format >>>

• Mike Violette will be speaking at the National Institute of Standards and Technology’s Standards in Trade (SIT) Workshop Program, in Gaithersburg, Maryland
  09/25/08
   

  Mike Violette will be speaking on Thursday, September 25th at 1:30 pm at the National Institute of Standards and Technology’s (NIST) http://www.nist.gov/ Standards in Trade (SIT) Workshop Program, in Gaithersburg, Maryland. The presentation topic will be on " Certification Systems and Related Organization(s) in the U.S. and Vietnam.". Mike is also hosting an evening reception. The five-day workshop September 22 thru 26, 2008 is on Fire Safety of Buildings for the U.S. and Vietnam. This workshop will cover aspects of fire safety for new and recent buildings (residential, commercial and industrial buildings of new construction, or less than ten years old) in Vietnam. The workshop will include discussions about fire resistance of building structures and its content, active and passive fire protection and detection systems, and access/egress design and implementation. It will also seek to explore opportunities for future collaboration between the U.S. and Vietnam. The workshop is being organized in collaboration with Underwriters Laboratories (UL) and other U.S. public and private sector stakeholders.

• FCC PUBLIC NOTICE: IMPLEMENTATION OF MODULAR EQUIPMENT AUTHORIZATION RULES SCHEDULED FOR APRIL 15, 2008
  ET Docket No. 03-201
  03/28/08
   

  Section 15.212 of FCC rules regarding the authorization of modular and “split” modular transmitters will become effective on April 15, 2008. Read the full document...

• iNARTE - ATCB Partnership Announced
  03/05/08
   

  Training and Certification for Engineers AmericanTCB is proud to announce the signing of a partnership agreement with the International Association of Radio and Telecommunications Engineers (iNARTE) to promote EMC Personnel Certification in China. AmericanTCB, with offices in Taiwan, Shenzen, Beijing and Shanghai is uniquely positioned to provide the foundation for development of iNARTE's certification programs in China. An increasingly sophisticated electronics and RF design capability is blooming in China, bringing with it the need for trained, capable and certified EMC engineers. By focusing our energies on the Pearl River Delta Region, an unparalleled hub of electronics production, ATCB will strive to bring hundreds of new prospects into the iNARTE fold, providing our considerable support to iNARTE's mission by providing logistics, support and training for the Chinese EMC Market. For more information, visit: http://www.narte.org or contact Jerry Lee sales.asia@atcb.com

2007

• Washington Laboratories and AmericanTCB announce the successful production of the first Vietnam Conformity Assessment Conference
  10/25/07
   

  For Immediate Release Mclean, Virginia: Washington Laboratories and AmericanTCB announce the successful production of the first Vietnam Conformity Assessment Conference, held in Ho Chi Minh City and Hanoi, Vietnam. The conferences, attended by 250 people from the Foods and Electrical Industry, was co-organized by the Directorate of Quality and Standards (STAMEQ). The focus of the conference was to exchange information about the current and evolving Vietnamese Conformity Assessment system and the impact of standards on commerce. Experts from the United States provided lectures on Food Safety, Product Introduction, Electrical Safety and International EMC Compliance Requirements.

  Vietnam is an integral member of ASEAN, the Association of Southeast Asian Nations, which has the stated goal of accelerating trade and growth in the region, which boasts a combined population of 500 Million people. ASEAN, among other activities, facilitates standards negotiations between the ten member countries. The goal is to have a regional common market by the year 2011. Within the negotiations that are furthering the trade are conformity assessment processes based on standards. These standards are, at the ASEAN level, increasingly harmonized with the IEC (most notably). Vietnam will adopt the ASEAN regimen and, by default, the IEC standards. Riding on top of this regional catalyst is the influence exerted by the World Trade Organization. Vietnam’s implementation of International Standards is part of their obligations for integration into the WTO, which was initiated just last year. To fully comply with membership in the WTO, it is necessary that technical barriers to trade (TBTs) be removed so that the Vietnamese market is open and accessible. Dr. Ngo Quy Viet, General Director of STAMEQ wrote in a letter of 24 October “the Events played an important part of promoting trade ties between our countries.” A future conference is planned for April 2008 to include other areas vital to Vietnam’s development, including energy, environment and infrastructure. For more information, contact Mike Violette. 240 401 1388. Washington Laboratories http://www.wll.com AmericanTCB http://www.atcb.com www.VietnamEnvironmentalForum.com View the STAMEQ Letter (368KB .PDF)

• FCC Expands Modular Certification: Electronic FCC ID Display and "Split
  Modulars"
  04/24/07
   

  FCC Expands Modular Certification: Electronic FCC ID Display and "Split Modulars" Attribution: Mitchell Lazarus Fletcher, Heald & Hildreth, PLC Since 2000, the FCC has permitted "modular certification," under which it approves a transmitter module for use in multiple host devices. That option originated with a unilateral public notice from the FCC, rather than a rulemaking in which the public participated. Today the FCC released a "Second Report and Order" that codifies and extends the 2000 public notice. (The First Report and Order in this docket made other changes to the Part 15 rules without addressing modular certification.) The new order carries over most elements of the 2000 public notice almost intact, with two significant changes. First, devices incorporating modular transmitters may now display the FCC ID in electronic form. Electronic FCC ID display has previously been allowed only in software-defined radios. Second, the FCC adopted new rules to govern "split modular transmitters." In these, the radio front end and controlling firmware are separate, possibly located in different components. Manufacturers must ensure that only components that have been certified together are capable of operating together. An escape clause allows a manufacturer to bypass any of the modular requirements if it can persuade the FCC that the device will nonetheless comply in all of the end products in which it is used. A copy of the order is at the link below, or ask me for a copy by return email. http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-07-56A1.doc Mitchell Lazarus Fletcher, Heald & Hildreth, PLC 703-812-0440 (voice) 703-812-0486 (fax) 301-537-7278 (mobile) www.fhhlaw.com

• FCC Postpones 6.25 kHz Narrownbanding
  03/22/07
   

  From: Mitchell Lazarus Sent: Thursday, March 22, 2007 5:28 PM Subject: FCC Postpones 6.25 kHz Narrownbanding The FCC today backed away from its plans to require private land mobile licensees at 150-174 MHz and 421-512 MHz to transition to 6.25 kHz bandwidth transmitters. Equipment submitted for certification must meet the 6.25 kHz requirement as of January 1, 2011, newly postponed from January 1, 2005. The FCC declined to set a date when use of that equipment will be required. The news release is linked below. I will send a link to the Report and Order when it becomes available. http://hraunfoss.fcc.gov/edocs_public/attachmatch/DOC-271692A1.doc USUAL DISCLAIMER: This email is one of an occasional series on telecommunications regulatory issues sent to both clients and non-clients free of charge. It is not legal advice, does not create, extend, or reinstate an attorney-client relationship, and does not solicit the representation of entities that have regulatory counsel. Recipients are free to distribute this email to others, but please include this notice and the signature block. To add, change, or drop an email address, just let me know. Mitchell Lazarus Fletcher, Heald & Hildreth, PLC 703-812-0440 (voice) 703-812-0486 (fax) 301-537-7278 (mobile) www.fhhlaw.com

• FCC Imposes $75,000 fine for GPS Re-Radiator
  Washington DC
  01/16/07
   

  Washington DC. January 16, 2007. The FCC imposed a $75,000 fine against a company that marketed GPS "re-radiators." These devices receive, amplify, and retransmit incoming signals from GPS satellites to improve reception in areas where the signals would otherwise be too weak to use, such as inside buildings. The company's offense was marketing a product that required but did not have FCC authorization. But the FCC also noted that the product was ineligible for authorization. About forty frequency bands, the so-called "restricted bands," are closed to all but certain specified transmitters, even at extremely low power. These include the GPS frequencies, which can be used only by orbiting GPS satellites. Some of the federal agencies that use GPS signals complained to the FCC that the re-radiators could interfere with their operations (although none reported actual interference). The FCC investigated, and subsequently imposed the fine. The item is interesting for several reasons. First, the device at issue does not generate a radio signal internally, but rather picks up an existing signal and re-transmits it. It is nevertheless subject to the same FCC oversight as a conventional transmitter. (In 1998, the U.S. Court of Appeals affirmed FCC jurisdiction over this category of device in upholding the FCC's ban on a "radar jammer" that reflects a modified version of a police radar signal back to the radar gun.) Second, unlike most other targets of FCC enforcement, the product at issue here actually served a useful purpose not addressed by anything else on the market. Third, the FCC disregarded the manufacturer's claim it was unaware the device was illegal, despite this being one of the rare cases where that claim in fact was plausible. Finally, although the statute of limitations for the stated offense is one year, and violations within that period would have justified a fine of $28,000, the FCC took into account prior violations -- outside the statute of limitations -- in jacking up the fine to $70,000. The links below point to the January 16th 2007 order and to an earlier order in the same proceeding. http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-07-3A1.doc http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-06-30A1.doc For more information, contact: Mitchell Lazarus Fletcher, Heald & Hildreth, PLC 703-812-0440 (voice) 703-812-0486 (fax) 301-537-7278 (mobile) www.fhhlaw.com

2006

• Making radiated emission measurements below 30 MHz
  12/17/2004
   

  Question: What antenna does the Commission reference and use for making radiated emission measurements below 30 MHz? Answer: For radiated emission measurements on a Part 15 device below 30 MHz, the Commission recommends following the guidelines in ANSI-C63.4 (2001) for use of a loop antenna (A monopole or rod antenna may not be used). This is consistent with a long standing Commission Lab policy of requiring the use of a loop antenna below 30 MHz. While there may have been some relaxation of this policy in the past for the upper end of the band; henceforth, we will require the use of a loop antenna unless there is a special circumstance where a loop antenna is not practical. For these situations, contact the FCC Lab at labhelp@fcc.gov for guidance. As stated in Section 15.31 of the FCC Rules, any reasonable procedure may be used to show compliance with FCC Rules, but in case of dispute the Commission will use the procedures referenced in the FCC Rules. For radiated emissions measurements on a Part 18 device between 18 and 30 MHz, section 2.2.4 of MP-5 states that you may use either a shielded balanced loop antenna, a calibrated half-wave dipole antenna or any linearly polarized antenna that gives you results comparable to a dipole antenna. MP-5 is referenced in Section 18.311 of the Rules.

• FCC APPROVES FIRST SOFTWARE DEFINED RADIO
  11/19/2004
  
  Washington, D.C. – The FCC announced today it has approved, for the first time, use of a software defined radio device in the United States. This new class of equipment allows users to share limited airspace, increases flexibility and reduces interference concerns.
  Read more... (pdf, 88 KB)

• FCC ADOPTS RULES FOR BROADBAND OVER POWER LINES TO INCREASE COMPETITION AND PROMOTE BROADBAND SERVICE TO ALL AMERICANS
  10/18/2004
  
  Washington, DC - As part of its goal to promote access to broadband services for all Americans and to encourage new facilities-based broadband platforms, the Federal Communications Commission today adopted changes to Part 15 of its rules to encourage the development of Access Broadband over Power Line (Access BPL) systems while safeguarding existing licensed services against harmful interference.
  Read more... (pdf, 100 KB)

• FCC Public Notice
  10/18/2004
  
  FCC Clarifies Equipment Authorization Policy for Approving Music Devices that Connect to a Personal Computer
  
  This Public Notice is issued to clarify the equipment authorization requirements for electronic musical instruments, recorders, amplifiers, and other sound creation and enhancement devices that are intended for or are capable of use with a personal computer.
  Read more... (pdf, 91 KB)

• European Radio Approvals
  The ERC RECOMMENDATION 70-03 "RELATING TO THE USE OF SHORT RANGE DEVICES (SRD)" is critical for companies looking to export short range radio products to the EU. This document is a "roadmap" to the allowed power, frequencies and standards used for evaluating low power devices under the R&TTE Directive.
  (pdf, 392KB) New CEPT 70 03 document released for European Radio Approvals
  
  Contact AmericanTCB for information regarding European Wireless Approvals

• TCB Policy Reminder
  (pdf, 45 KB) FCC Policy on TCB Review Procedures

• FCC Allows Short-Term Confidentiality Requests
  6/15/2004
  
  Manufactures typically desire to have their FCC Authorization processed and obtained as quickly as possible, only to find that once the Grant of Authorization is issued that the application becomes publicly available. However sometimes there is a need by the manufacture to keep many aspects of the application confidential until the actual product launch or marketing release. In the past this ability has not been available in the FCC’s electronic system.

  The FCC has just upgraded their system to allow manufactures with this need to request short-term confidentiality.
  Read the memo... ( pdf, 255 KB)

• NOW ACCEPTING APPLICATIONS FOR INDUSTRY CANADA
  Industry Canada Applications are now being accepted. We are pleased to announce that we can now accept filings for Industry Canada for Wireless Certification to the RSS requirements of the Canadian Government.

• Opening of Asian office in Taipei, Taiwan
  April - AmericanTCB is pleased to announce the opening of its first Asian office in Taipei, Taiwan. To better serve our clients in Asia, we have opened an engineering office in Nei Hu district in Taipei. To celebrate our arrival in Taiwan, we are having a seminar and reception on April 21, 2004.

• Note to Test Labs from FCC Lab: Comparison Noise Emitters
   

  The FCC has issued an interpretation of noise sources used to validate Open Area Test Sites (OATS). The question was posed whether the broadband noise sources used to validate sites need equipment authorization or a license from the Commission. Follow. Question:   Is a Comparison Noise Emitter (CNE) that is used and marketed in the USA for evaluating anechoic chambers and Open Area Test Sites (OATS) subject to the FCC Rules and does it require an Equipment Authorization?  The CNE in question is a broadband noise source, typically a low power broadband noise-generator complete with a permanently attached antenna that operates over the frequency range of 9 kHz to 2 GHz. Answer:  A number of self-contained reference noise sources (e.g., CNE) and comb generators are marketed in the US for testing purposes.  Most are used in a shielded room, which is permitted by the FCC Rules.  Another use of a reference noise source is to evaluate anechoic chambers or OATS.  In this situation, it is used infrequently by a skilled technician to determine the suitability of a test site.  Although technically a reference noise source is not a digital device, the exemption in 47 CFR 15.103(c) for test equipment appears to be the appropriate classification for a reference noise source when it is used to evaluate radiated emissions test sites.  This interpretation of 15.103(c) is limited to a low power reference noise source that is used exclusively for evaluating anechoic chambers or OATS facilities by a skilled technician.  An equipment authorization is not required for a device operating under the 15.103 exemption.  Other types of reference noise sources must be used in a shielded enclosure for immunity and similar types of testing, or a license must be obtained under Part 5 of the Rules.   For details please contact our review staff directly.

• Attention: Effective Feb, 19 - All 5GHz 802.11a filings under the new 15.407 rules...
   

  All 5GHz 802.11a filings under the new 15.407 rules which include DFS and TPC must be filed with FCC. This is because this involves a new test methodology that is unique and unfamiliar to the Equipment Authorization branch of the FCC in Columbia, MD. The effective date for this Rule will be February 19, 2004, however a one-year phase in period does exist for equipment designed under the old rules. For details please contact our review staff directly.

• More Spectrum! FCC adds 255MHz for U-NII devices in the 5.470-5.725 GHz band  - Download ( pdf, 300 KB)