Issue 3

Providing information and fielding questions for wireless manufacturers are some of the many activities that we perform at ATCB. Packets provides an overview of just a small portion of the communiqués that run in and out of our office.

China GB Standards for WLAN
Are you ready to comply?

China Safety
Requirements Update.

FCC Part 15 Rules Changes
New FCC Part 15 rules, published in late July, are based on the second Report and Order FCC 03-149 that was...

Cellular Applicants take note:
FCC PART 22H/24E BLOCK EDGE REQUIREMENTS

Happy Anniversary:
20 Years of FCC Rules on Digital Devices

Famous Quotes on the Computing Market

New FCC Enforcement Policy
Fish & Richardson, P.C. a Washington DC based legal firm that specializes in enforcement law, informed EMC test labs recently that the FCC is evidently taking a much more serious approach to enforcing its equipment authorization rules than has typically been...

China GB Standards for WLAN:
Are you ready to comply?
China WLAN standards (GB15629.11 and GB15629.1102), published on May 12, 2003, will be implemented on December 1, 2003, announced by MII, SAC, and CCEM on July 9.

These two standards are referenced to IEEE 802.11/802.11b but with many differences. One major difference from international standards is the “Encryption”. GB standards requires WAPI Encryption Technique instead of WEP (Wired Equivalent Privacy) on WLAN. 

Currently for MII approval, international standards are used for testing and certification. Although major WLAN providers are said not to be ready to comply with new GB standards, from December 1, all WLAN products operating in the frequency bands of 2.4GHz and 5GHz, including Router, AP, terminal, etc, must comply with new GB standards to be approved in China. Back to Top

Courtesy of SIEMIC China Certification Services,
a Subsidary of SIEMIC, Inc., www.siemic.com

China Safety
Requirements Update.
Issued by SAC on July 29, technical code (29 020) for all kinds of electric devices used in voltage from 50V ac to 1500V ac and 75V dc to 1500V dc must comply with the new general safety requirements in designing, manufacturing, and selling.

Products under CCC Mark must first be evaluated against this general safety code in additional to the product specific GB Standards.

For more information and to find out how SIEMIC can help you to access the China Market, contact us at info@siemic.com.  Back to Top

Courtesy of SIEMIC China Certification Services,
a Subsidary of SIEMIC, Inc., www.siemic.com

FCC Part 15 Rules Changes
New FCC Part 15 rules, published in late July, are based on the second Report and Order FCC 03-149 that was released on July 17, 2003. The main changes with the most impact are as follows:

1) Part 15.231 is still limited to devices that transmit control signals but it now allows data to be sent with the control signal. Also, the total duration of transmission for polling and supervision transmissions used for security or safety applications has been increased from 1 sec to 2 sec per hour.

2) Part 15.225 limits for RFID devices have been increased and the frequency range has also expanded. In addition the FCC will now allow powered RFID tags to be approved as a system along with the tag reader under one FCC ID.

3) The DoC label has changed. There is no longer the requirement to display “For Home or Office Use” Also, the wording “Tested to Comply with FCC standards” is no longer required. The label now requires just the FCC logo and the Trade Name and Model Number.

4) The information to the User can now be provided in a form other than paper as long as the manual is only provided in this other form (i.e., a CD or over the Internet).

5) Measurement standards have been changed: ANSI 63.4-2001 (except for section 4.1.5.2, section 5.7, section 9, and section 14) is now the accepted measurement standard replacing the ANSI 63.4-1992. (Still use a loop for measurements below 30MHz). ANSI C63.17-1998 is the measurement standard for Unlicensed PCS devices. Other Measurement Procedures are deleted as they were no longer being used.

6) Low powered devices operating below 490kHz with emissions at least 40dB below the limit no longer need to be certified but can now be approved through the verification procedure.

7) Filing of the test site information is no longer required. This used to be done every 3 years. The NVLAP accreditation will handle this and provide the necessary information to the FCC.

Keep in mind, this is just a summary of the changes most important to our customers and there are other changes to Part 15, Part 2 and Part 90. For more information or help with interpreting the changes give us a call at 703 847-4700.  Back to Top

Cellular Applicants take note:
FCC PART 22H/24E BLOCK EDGE REQUIREMENTS
The FCC Office of Engineering and Technology (OET) recently decided that the Rules require compliance to be shown at ALL block edges for Part 22H and 24E devices whether portable, mobile or base transmitters. In the past, the Commission had relied on just the upper and lower band edge plots/data tables to represent block edge compliance for radiated and conducted emissions for all blocks. However, the potential use of these blocks requires the submission of plots/data tables for all blocks. Therefore, the OET will be requiring all test labs and TCBs to submit plots or data showing compliance for all block edges in accordance with the following paragraph.

Each block will require 2 plots/data tables: one upper edge, and one lower edge, for the worst-case modulation type only. The worst-case modulation type may be determined by the applicant or test lab through preliminary testing. For Cellular transmitters, this will require 8 plots/data tables to be submitted for the 4 blocks. For PCS transmitters, this will require 12 plots/data tables to be submitted for the 6 blocks. The plots/data tables should represent compliance with out-of-block emissions as tested using spectrum analyzer settings specified in 22.917(b) or 24.238, as appropriate. Back to Top

Happy Anniversary: 20 Years of FCC Rules on Digital Devices
The rules governing unintentional emissions from computing devices under Part 15 became mandatory in October 1983. The original ruling, stemming from reports of increased interference from devices, came under FCC Docket 20780. The FCC Rules were enacted to reduce radiated and conducted emissions from consumer and office products (Class B and Class A environments, respectively) and was colloquially referred to as the EMC Engineer Employment Act of 1983.

The original Rules covered the frequency range up to 1GHz and at that time computers operated at a few MHz with Intel 8086 microprocessors running the IBM PC and the Motorola 68000 running the Apple Lisa (soon to be retooled as the Macintosh). The IBM XT was released in 1983, sporting an 8086 microprocessor and with a slot for an 8087 math co-processor. A complete system selling for $5000, included a 10MB hard disk, 128K of RAM, one floppy drive, monochrome monitor and a printer.

From the late 1980s through the early 1990s, the PC boom, spurred by the open format of the IBM PC bus and operating system, allowed anyone with a screwdriver to make a computer. This created a huge surge in FCC Certifications because, at the time, every configuration of PC and every computer peripheral needed to have an FCC ID number. The applications to the OET swelled and the turn-around time took up to two months; enforcement was reasonably vigorous as computer companies sprouted up like mushrooms after a summer rain. The commission changed the requirement to allow manufacturers to “self-declare,” rather than go through the formal Certification process. Certification is now required only for intentional emitters (radio transmitters).

Fast-forward to 2003, the present version of the Pentium 4 clocks at 3.2 GHz and contains over 55 million transistors. The microprocessor
frequency has increased by a factor of 800. The upper limit for the FCC rules is now based on 5 times the highest operating frequency in the device, which extends the testing of devices well into the GHz range. Other critical updates have occurred in Part 15 (see above), which have broadened the development and use of wireless devices. Back to Top

In 1965, Gordon Moore, co-founder of Intel speculated that the numbers of transistors per square inch that could be etched into an integrated circuit would double every year. The trend has slowed down some, with the doubling occurring at every 18 months to two years. Conventional wisdom has it that the upper limit achievable by improvements in current technology will occur before 2020. With even that barrier in mind, transistor counts of up to 1Billion+ are conceivable in the next 5 years and clock speeds to 10 GHz and higher are certainly on the near horizon. Who knows what the upper end may be? Back to Top

Famous Quotes on the Computing Market
1943
“I think there is a world market for maybe five computers.”
Thomas Watson
Chairman of IBM.

1949
“Computers in the future may weigh no more than 1.5 tons.”
Popular Mechanics
forecasting the relentless march
of science

1977
“There is no reason anyone would want a computer in their home.”
Ken Olson, president
Chairman and founder of Digital Equipment Corp.

1981
“640k ought to be enough for anybody.”
Bill Gates
Back to Top

New FCC Enforcement Policy
Fish & Richardson, P.C. a Washington DC based legal firm that specializes in enforcement law, informed EMC test labs recently that the FCC is evidently taking a much more serious approach to enforcing its equipment authorization rules than has typically been the case in the past. We provide portions of that information your reference.

This should be a concern to all manufacturers, distributors as well as EMC test labs. The FCC’s enforcement options for unlawful equipment include equipment seizure, civil fines, and possibly even jail for “knowing violations” of law.

The FCC sent a letter dated July 7, 2003 to a company that allegedly marketed unlawful recording equipment, an unintentional radiator. In the past, this would ordinarily have prompted a short letter of inquiry permitting a narrative response. Instead, the FCC’s inquiry leaves no stone unturned, and is one of the most comprehensive enforcement letters we have ever. We understand from staff within the FCC’s Enforcement Bureau that this is to be a standard approach in the future.

Accordingly, manufacturers should now be extra vigilant to ensure their products comply with all FCC rules to avoid the onerous burdens of responding to an FCC investigation.

In the letter, the FCC asked for details regarding the following information:
1) number of units acquired for sale;
2) number of units distributed;
3) identity and contact information for the importer;
4) FCC authorization under which the equipment was imported;
5) compliance information regarding the FCC’s radiated emission limits;
6) efforts taken to comply with the FCC’s radiated emission limits;
7) authorization procedure for the equipment and the basis for selecting that procedure;
8) a copy of the equipment manual;
9) labeling information; and,
10) the same information regarding any functionally equivalent equipment.

Perhaps equally indicative of the FCC’s seriousness is the two-an-a-half pages of instructions for how to respond to the agency’s inquiry. The instructions read like a discovery request in a litigation matter, and include the following requirements:
1) submission of a detailed “privilege log” for any information the respondent withholds;
2) answers must be updated with any new information for two years;
3) identification of the FCC inquiry to which each document is responsive;
4) identification of the person from whose files each document was retrieved; and,
5) submission of an affidavit under penalty of perjury verifying the truth of the response. Back to Top

If you have any questions regarding this matter contact Fish & Richardson, P.C. at 202/783-5070.