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As the rules change or new procedures are developed, please note that these interpretation and/or guidance may not apply; you should always refer to the latest rules and guidance documents to determine what equipment authorization procedures should be followed. For the latest guidance on specific topics or you don't know where to start, please feel free to contact GTG experts.

Ultimate Guide to Radio Frequency Devices
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GTG provide professional, efficient and reliable testing and certification services for radio frequency (RF) devices.

Radio frequency (RF) devices have revolutionized our world in ways we never thought possible. These seemingly small gadgets have the power to transmit and receive data wirelessly, connecting our devices and enabling communication on a global scale. From smartphones to satellite communication, RF devices have become an integral part of our daily lives, making them one of the most groundbreaking technological innovations of our time. With the ability to transmit signals over long distances and through obstacles, the potential of RF devices is limitless, and we can only imagine what the future holds for this incredible technology.

What is an RF device?

The FCC regulates radio frequency (RF) devices contained in electronic-electrical products that are capable of emitting radio frequency energy by radiation, conduction, or other means. These products have the potential to cause interference to radio services operating in the radio frequency range of 9 kHz to 3000 GHz.

Almost all electronic-electrical products (devices) are capable of emitting radio frequency energy. Most, but not all, of these products must be tested to demonstrate compliance to the FCC rules for each type of electrical function that is contained in the product. As a general rule, products that, by design, contain circuitry that operates in the radio frequency spectrum need to demonstrate compliance using the applicable FCC equipment authorization procedure (i.e., Supplier’s Declaration of Conformity (SDoC) or Certification) as specified in the FCC rules depending on the type of device. A product may contain one device or multiple devices with the possibility that one or both of the equipment authorization procedures apply. An RF device must be approved using the appropriate equipment authorization procedure before it can be marketed, imported, or used in the United States.

The following discussions and descriptions are provided to help identify whether a product is regulated by the FCC and whether it requires approval. The more difficult issue, but not covered in this document, is how to categorize an individual RF device (or multiple components or devices within an end product) to determine the specific FCC rule part(s) that apply, and the specific equipment authorization procedure or procedures that need to be used for FCC compliance purposes. This determination requires technical understanding of the product, as well as knowledge of the FCC rules.

Categories of radio frequency devices

Incidental Radiators (Part 15, Subpart A)

An incidental radiator (defined in Section 15.3 (n)) is an electrical device that is not designed to intentionally use, intentionally generate or intentionally emit radio frequency energy over 9 kHz. However, an incidental radiator may produce byproducts of radio emissions above 9 kHz and cause radio interference. A product that is classified as an incidental radiator device is not required to obtain an equipment authorization. Nonetheless, incidental radiator are regulated under the general operating conditions of Section 15.5 and if there is harmful interference the user must stop operation and remedy the interference. Manufacturers and importers should use good engineering judgment before they market and sell these products, to minimize possible interference (Section 15.13).

Examples of products that are classified as incidental radiators include: AC and DC motors, mechanical light switches, basic electrical power tools (that do not contain digital logic).

Unintentional Radiators (Part 15, Subparts B and G)

An unintentional radiator (defined in Section 15.3 (z)) is a device that by design uses digital logic, or electrical signals operating at radio frequencies for use within the product, or sends radio frequency signals by conduction to associated equipment via connecting wiring, but is not intended to emit RF energy wirelessly by radiation or induction.

Today the majority of electronic-electrical products use digital logic, operating between 9 kHz to 3000 GHz and are regulated under 47 CFR Part 15 Subpart B.

Examples include: coffee pots, wrist watches, cash registers, personal computers, printers, telephones, garage door receivers, wireless temperature probe receiver, RF universal remote control and thousands of other types of common electronic-electrical equipment that rely on digital technology. This also includes many traditional products that were once classified as incidental radiators – like motors and basic electrical power tools that now use digital logic.

Products that only contain digital logic may also be specifically exempted from an equipment authorization under Section 15.103.

Intentional Radiators (Part 15, Subparts C through F and H)

An intentional radiator (defined in Section 15.3 (o)) is a device that intentionally generates and emits radio frequency energy by radiation or induction that may be operated without an individual license.

Examples include: wireless garage door openers, wireless microphones, RF universal remote control devices, cordless telephones, wireless alarm systems, Wi-Fi transmitters, and Bluetooth radio devices.

Industrial, Scientific, and Medical Equipment (Part 18)

When electronic-electrical products are used for providing RF energy for other than telecommunications applications, such as for the production of physical, biological, or chemical effects, such as heating, ionization of gases, mechanical vibrations, and acceleration of charged particles, these devices fall under the FCC rules 47 CFR Part 18.

Examples include: fluorescent lighting, halogen ballasts, arc welders, microwave ovens, and medical diathermy machines.

Note: A general consumer medical device does not typically come under this classification; rather Part 18 applies for medical equipment only when it is designed to generate and use RF energy locally for medical or therapeutic purposes.

Equipment Operating in Licensed Radio Services

Products that use licensed radio spectrum, from fixed microwave links to cellular telephones to mobile broadband services, are considered RF devices and are subject to equipment authorization.

Examples of licensed radio equipment subject to Certification include: low power TV transmitters, cell phones/smart phones, base stations, licensed point-to-point microwave radios, private land mobile transmitters, aviation and marine radios.

Radio spectrum allocation, regulatory responsibility for the radio spectrum is divided between the Federal Communications Commission (FCC) (non-Government uses) and the National Telecommunications and Information Administration (NTIA) (Government agencies usage). At present only frequency bands between 9 kHz and 275 GHz have been allocated (i.e., designated for use by one or more terrestrial or space radiocommunication services, or for the radio astronomy service under specified conditions). OET maintains the FCC’s Table of Frequency Allocations, which is a compilation of allocations. The FCC’s Table of Frequency Allocations is codified at Section 2.106 of the Commission’s Rules. For a more detailed description go to the Table of Frequency Allocations Chart.

RF equipment authorization guide

Radio Frequency (RF) devices are required to be properly authorized under 47 CFR part 2 prior to being marketed or imported into the United States. The Office of Engineering and Technology (OET) administers the equipment authorization program under the authority delegated to it by the Commission. This program is one of the principal ways the Commission ensures that RF devices used in the United States operate effectively without causing harmful interference and otherwise comply with the Commission’s rules. All RF devices subject to equipment authorization must comply with the Commission’s technical requirements prior to importation or marketing.

Equipment that contains an RF device must be authorized in accordance with the appropriate procedures specified in 47 CFR part 2, subpart J as summarized below (with certain limited exceptions). These requirements not only minimize the potential for harmful interference, but also ensure that the equipment complies with the rules that address other policy objectives – such as human RF exposure limits and hearing aid compatibility (HAC) with wireless handsets.

The Commission has two different approval procedures for equipment authorization – Certification and Supplier’s Declaration of Conformity (SDoC). The required procedure depends on the type of equipment being authorized as specified in the applicable rule part. In some instances, a device may have different functions resulting in the device being subject to more than one type of approval procedure.

Steps to obtain an RF equipment authorization

The following steps summarize the process to obtain the required equipment authorization for your product (device):

The following steps summarize the process to obtain the required equipment authorization for your product (device):

1. Determine FCC rules that apply to your product.

  • Determine if device is a Radio Frequency (RF) device subject to the FCC rules.
  • Determine all applicable technical and administrative rules that apply to the device requiring an equipment authorization.
  • The technical requirements are generally specified in the applicable FCC rule parts and the administrative rules are specified in 47 CFR part 2, subpart J.

2. Determine which Equipment Authorization Procedure(s) is required for your product.

If a device is subject to FCC rules, determine the specific type of equipment authorization that applies to the device. Become familiar with all the basic marketing, equipment authorization, and importation rules. In some instances, a device may have different functions resulting in the device being subject to more than one type of approval procedure.

Determine the applicable equipment authorization procedure for your device.

  • Supplier’s Declaration of Conformity (SDoC)
  • Certification

3. Perform compliance testing at an authorized testing laboratory.

Perform the required tests to ensure the device complies with the applicable technical requirements (as determined in step 1).

The qualifications of the testing laboratory used to demonstrate compliance is based on the approval procedure you are required to use (as determined in step 2):

Supplier’s Declaration of Conformity (SDoC)

Equipment approved using SDoC is required to be tested, however, it is not necessary to use an FCC-recognized accredited testing laboratory. However, as minimum the testing laboratory used is required to maintain a record of the measurement facilities as specified in Section 2.948 and a record of the measurements made as specified in Section 2.938.

Certification

Equipment approved under the Certification procedure is required to be tested by an FCC-recognized accredited testing laboratory. [For a list of currently FCC-recognized accredited testing laboratory see https://apps.fcc.gov/oetcf/eas/reports/TestFirmSearch.cfm]

4. Obtain the required approval.

After the testing is complete and your device is found to be in compliance, finalize the approval process based on the applicable approval procedure:

Supplier’s Declaration of Conformity (SDoC)

  • The responsible party, as specified in the rules, warrants that each unit of equipment complies with the applicable FCC rules.
  • The responsible party maintains all of the required documentation demonstrating compliance with the applicable FCC rules.
  • The responsible party prepares a compliance information statement to be supplied with the product at the time of marketing.

Certification

  • The responsible party, typically the manufacturer, obtains an FCC Registration Number (FRN) for a device requiring Certification. The FRN is a 10-digit number used to identify the individual or organization doing business with the FCC. The same FRN will be used for future approvals.
  • After obtaining an FRN, the responsible party obtains a Grantee Code from the Commission by applying at the Grantee Registration website. A grantee code is required the first time a party applies for certification, and can be used for all future approvals.
  • The responsible party files with a Telecommunication Certification Body (TCB) an application for a grant of certification. An application for equipment authorization requires submission of information about the product, as listed in Section 2.1033. The applicant must submit the required information to a Telecommunication Certification Body (TCB) for review as part of the certification process. [For a list of FCC recognized TCBs see https://apps.fcc.gov/oetcf/tcb/reports/TCBSearch.cfm]
  • The Telecommunication Certification Body (TCB) reviews all of the supporting information and the evaluation results to determine if the product complies with the FCC requirements.
  • Once the Telecommunication Certification Body (TCB) makes a decision to certify the product the supporting information is uploaded to the FCC Equipment Authorization Electronic System (EAS) – Database.
  • A grant of certification is issued by the Telecommunication Certification Body (TCB) on the FCC Equipment Authorization Electronic System (EAS) – Database.

5. Label product with the required information and include compliance information in the user manual. Maintain compliance information and records.

  • Label the product and provide the required customer information.
  • For more information see Labeling Guidelines – the Knowledge Database (KDB) Publication 784748.
  • Maintain all documentation as part of the responsibility for the retention of records and ensure that the manufactured products are in compliance.
  • Section 2.938 – Requirements for the retention of records of equipment subject to FCC approval.

6. Ready to manufacture, import and market your product.

  • When importing products into the United States, follow the FCC importation requirements.
  • Importation – Frequently Asked Questions.
  • Marketing of radio frequency devices prior to equipment authorization.

NOTE – Determining all applicable technical and administrative rules requires a technical understanding of the electrical functions of the device and an understanding of the FCC rules. For assistance, we recommend that you work with one of the FCC recognized accredited testing laboratories like GTG or Telecommunication Certification Bodies (TCBs). Questions can also be submitted through the Knowledge Database (KDB).

7. Modifications to approved products.

Changes to your product design may require an additional approval. The Knowledge Database (KDB) Publication 178919 gives general guidance when making changes to a previously approved product. See the permissive change rules in Section 2.1043 for:

  • Modifications that may be made to an RF device without filing for a new equipment authorization;
  • Three different types of permissive changes; and
  • Identifies when a permissive change filing with the Commission is required.
Sources: Our articles are written in part based on publicly available information, and our own practical experience relating to product testing, compliance and certification. These are some of the primary sources we use:
  1. https://www.fcc.gov/oet/ea/rfdevice
  2. https://www.fcc.gov/engineering-technology/laboratory-division/general/equipment-authorization
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