Using pre-approved modules

Transcription

1 Using pre-approved modules Stuart Beck, Director of Certification, Nemko North America June

2 Overview What is a module? Selection considerations Case studies Resources 2

3 What is a module? A radio module is a stand-alone radio transmitter or transceiver on its own PWB with all radio functions built on the board. Sub-types Single modular Limited single Modular Split modular Limited split modular Not a reference design Complies with all applicable rules in its own right 3

4 What is a module? Single modular transmitter Demonstrates compliance independent of any host product Limited modular transmitter Demonstrates compliance when assessed with a specific type of host Ref: 47 CFR Part

5 What is a module? A radio module must meet 8 requirements in order to be certified as a module: Radio circuitry must be shielded Modulation/data inputs must be buffered Module board must have its own power supply regulation Module must be certified with specific antenna(s). Antennas must be either permanently attached or use unique connector Must be tested stand-alone Module must have its own label Module must comply with all specific rules applicable Module must comply with rf exposure requirements The customer must provide a declaration of how the module meets these criteria when making an application for certification (FCC/ISED) The filing must include clear instructions on how integrators must integrate the module to continue to comply. (Ref (vii)) 5

6 What is a module What if a module does not meet all 8 requirements? It could use an LMA Likely because no shield Maybe no voltage regulation Authorized with specific hosts in mind 6

7 Considerations on choosing a module Must have an up-to-date certification May have conditions not met in all products Distributors often sell inventory, not solutions for certification Consider technical support: certificates, reports Software tools for continuous transmission, frequency selection and modulation etc. 7

8 Considerations on choosing a module All of the restrictions and implementation requirements listed on the certification and included in the implementation guide must be followed to ensure compliance. Review conditions Review integration guide Perform end product test Once the radio module is placed in an end product the final product must meet electrical safety and Electromagnetic Compatibility (EMC) requirements 8

9 Considerations on choosing a module RF Exposure requirements relate to the end product and its use (i.e. handheld, held to the head, worn on the body) A radio module will likely be certified for use in a mobile exposure environment meaning that there will be a restriction that the device can only be 20 cm or further from the operator or nearby persons. If the module will be used in an end device that will be handheld or held to the head then it may be necessary to perform a Specific Absorption Rate (SAR) test. 9

10 Considerations on choosing a module RF Exposure requirements relate to the end product and its use (i.e. handheld, held to the head, worn on the body) First determine the application of the end product and then, using the rf power output and operating frequency of the transmitter, evaluate if the device will be exempted from SAR or not. A Class II Permissive Change must be used to remove the 20 cm separation restriction 10

11 Considerations for choosing a module Co-location A radio that is approved as a module will usually have a co-location restriction meaning that it cannot be located within 20 cm of another radio transmitter in the product if the two transmitters will transmit simultaneously. RFID + WiFi 11

12 Considerations for choosing a module RFID + WiFi Co-location (example conditions) The antenna(s) used for this transmitter must not transmit simultaneously with any other antenna or transmitter, except in accordance with FCC multi-transmitter product procedures. Always used with Grantee must provide installation and operating instructions for complying with FCC multi-transmitter product procedures. 12

13 Considerations for choosing a module RFID + WiFi Co-location If the radio module is to be co-located with another transmitter the modular approval can be modified to remove the co-location restriction through a Class II Permissive Change filing. Only one of the co-located transmitters needs to have its grant of approval modified. If the multi-transmitter product complies without modification of the grant, then verification and Class I Change (no filing) can be used 13

14 Considerations for choosing a module Co-location Additional testing to show that the interaction of the multiple modules complies with the technical requirements. RFID + WiFi 14

15 Who is responsible for compliance? The certificate holder is always responsible for compliance of the module The manufacturer is always responsible for compliance and labeling of the end product. Often preferable to have the original certificate holder update their grant through Class II permissive change (C2PC) Can always take control your self through Change in ID (multi-list) and then do your C2PC) 15

16 Labelling the end product Labelling is mandatory for the module Labelling is also mandatory for the host FCC ID:xxxyyy Contains : FCC ID:xxxyyy 16

17 Where is modular approval allowed? Many countries do not have a modular approval scheme and thus do not allow modular certification Some countries will allow for modular approval but only in specific types of end products (ITE and Household products) A country that does not allow for modular certification may allow the test data for the module to be used to gain certification on various end products but only allow one model per certificate. Some countries that allow modular approval: Canada/USA China (for radio modules that will be used in ITE or Household devices. EU (self-declaration for the end product) Japan 17

18 Case studies (FCC/ISED) Example 1 BT module + WiFi module Mobile configuration Example 2 WiFi module + GSM module BT module + GSM module Portable configuration 18

19 Case study 1 Example 1 BT module + WiFi module Mobile configuration Grants have co-location grant note Considerations for compliance RF exposure analysis Colocation analysis Output power compliance Sample calculations Type of certification application 19

20 Case study 1 RF Exposure Analysis Mobile configuration 20

21 Case study 1 Co-location analysis Sum of MPE ratios 21

22 Case study 1 Output power compliance FCC / Canada RSS-247 Limits Frequency F Power P Power Limit Antenna Gain G EIRP EIRP Limit MHz dbm W W dbi W W BT WiFi for frequency hopping systems that use at least 75 non-overlapping hopping channels 22

23 Case study 1 Sample Calculations - WiFi EIRP = 10 (P/10) x 10 (G/10) = 10 (20/10) x 10 (6/10) = 398 mw = 0.40 W FCC Power Density = EIRP / (4πD 2 ) = 398 / [4π(20 2 )] = mw/cm 2 Canada Power Density = EIRP / (4πD 2 ) = 0.40 / [4π(0.2)] = 0.79 W/m 2 FCC MPE Ratio = Power Density / Limit = / 1 = Canada MPE Ratio = Power Density / Limit = =0.79 / 5.35 =

24 Case study 1 Guidance from FCC Certification process decision D02 Module Q and A v01, Q&A13B Each module was originally certified for mobile device use only, without co-location considered. Now all both are combined in an end product and simultaneous transmission exists. The end product host is a mobile device only The installer performs a new MPE calculation and determines a new minimum compliance boundary, which may or may not be 20 cm in all directions. 24

25 Case study 1 Guidance from FCC Certification process decision Q13B1) Would it be sufficient for RF exposure compliance that the otherwise-undocumented end product combination is confirmed only through exclusion analyses done by the integrator? Q13B2) Alternatively, would Class I permissive change documentation be needed for any of the module grantees? Q13B3) Alternatively, would Class II permissive change filings be needed for any of the module grantees? A) Class I permissive change may apply (if conditions are met) In this case the RF exposure conditions and the co-location evaluation were still in compliance therefore no additional filing is necessary. In addition the co-location compliance was still met as well. 25

26 Case study 2 Example 2 WiFi module + GSM module BT module + GSM module Portable configuration Considerations for compliance RF exposure analysis Output power compliance Sample calculations Type of certification application 26

27 Case study 2 FCC RF exposure analysis FCC D01 General RF Exposure Guidance v General SAR test exclusion guidance SAR measurement is required for WiFi and GSM Frequency Power Power Distance 2 Threshold 3 Limit Threshold MHz dbm mw mm 1-g SAR WiFi GSM Multislot Class 12, Power Class 4, 33 dbm, 50% duty cycle frame average output power = 30 dbm D01 General RF Exposure Guidance v06, a) Standalone SAR test exclusion considerations 2 When the minimum test separation distance is < 5 mm, a distance of 5 mm according to 4.1 f) is applied to determine SAR test exclusion. 3 For 100 MHz to 6 GHz and test separation distances 50 mm, the 1-g and 10-g SAR test exclusion thresholds are determined by the following: [(max. power of channel, including tune-up tolerance, mw) / (min. test separation distance, mm)] [ f(ghz)] 3.0 for 1-g SAR, and 7.5 for 10-g extremity SAR, where f(ghz) is the RF channel transmit frequency in GHz Power and distance are rounded to the nearest mw and mm before calculation 27

28 Case study 2 FCC RF exposure analysis SAR measurement is only required for GSM Frequency Power Power Distance 2 Threshold 3 Limit Threshold MHz dbm mw mm 1-g SAR BT GSM Multislot Class 12, Power Class 4, 33 dbm, 50% duty cycle frame average output power = 30 dbm D01 General RF Exposure Guidance v06, a) Standalone SAR test exclusion considerations 2 When the minimum test separation distance is < 5 mm, a distance of 5 mm according to 4.1 f) is applied to determine SAR test exclusion. 3 For 100 MHz to 6 GHz and test separation distances 50 mm, the 1-g and 10-g SAR test exclusion thresholds are determined by the following: [(max. power of channel, including tune-up tolerance, mw) / (min. test separation distance, mm)] [ f(ghz)] 3.0 for 1-g SAR, and 7.5 for 10-g extremity SAR, where f(ghz) is the RF channel transmit frequency in GHz Power and distance are rounded to the nearest mw and mm before calculation 28

29 Case study 2 Sample calculation FCC BT Threshold FCC 1-g SAR threshold = (P max mw / minimum distance mm) x ( F GHz ) = (1.6/5) x ( 2.4) =

30 Case study 2 Canada RF exposure analysis CANADA RSS-102 Table 1: SAR evaluation Exemption limits SAR measurement is required for Wifi and GSM 1-g SAR Frequency Power Power Antenna Gain G EIRP Exemption Limit MHz dbm mw dbm mw mw WiFi GSM SAR measurement is only required for GSM 1-g SAR Frequency Power Power Antenna Gain G EIRP Exemption Limit MHz dbm mw dbm mw mw BT GSM Multislot Class 12, Power Class 4, 33 dbm, 50% duty cycle frame average output power = 30 dbm 30

31 Case study 2 Output power compliance FCC / RSS-247 Limits Antenna Gain G EIRP EIRP Limit Frequency Power P Power Limit MHz dbm W W dbi W W BT WiFi for frequency hopping systems that use at least 75 non-overlapping hopping channels Frequency Power P Power Antenna Gain G EIRP ERP ERP Limit MHz dbm W dbi W W W GSM

32 Case study 2 Type of certification filing SAR measurement was required therefore a C2PC is required to one of the grants. If the host integrator is not the certificate holder then a change in identification followed by a C2PC is appropriate for the module that does not qualify for SAR exemption 32

33 Summary Options for the integrator A RF exposure evaluation required Host manufacturer Procedure Options Verification Evaluation Approach Change in ID & Class II Permissive Change New FCC ID Grantee Procedure Not Applicable For situations to address RF exposure Permissive Change B Limited Module Not Applicable For situations to address the limitation Permissive Change C Simultaneous transmission If no additional filing is required, host manufacturer can use evaluation For situations to address the limitation Permissive Change From KDB D01 v02, Module Equipment Authorization Guide 33

34 Summary Summary Using pre-certified modules can be very cost effective, if: You understand the limitations; You choose wisely; You get cooperation from the module manufacturer; You confirm your analysis with the test laboratory and Certification Body early in the process 34

35 Summary Examine module certificate Test/analyze in host configuration OR Host config meets conditions? N Modify module certification New certification Y Label host with module info Label host and/or module with new ID 35

36 Useful resources FCC KDB D01 Module Certification Guide v02 FCC KDB D01 General RF Exposure Guidance v06 FCC Guidance on Permissive Changes ISED RSS Radio Frequency (RF) Exposure Compliance of Radiocommunication Apparatus (All Frequency Bands) ETSI Technical Report TR ETSI Technical Report TR

37 Thank you! 37