Published on April 2, 2019
In previous articles, we have discussed various technical requirements regarding certification of wireless devices; however, the actual testing is only part of the process of qualifying [TS1] wireless products in the United States and Canada. This article highlights key components of paperwork for the filing process.
To make this article concise, we will focus on products submitted for review by a Telecommunication Certification Body. Unless specifically noted, the information applies to both modular and product certification.
In the U.S., the Federal Communications Commission (FCC) is the governing body for wireless devices. Canada has a similar regulating body called Industry Canada (IC). Companies must register with the appropriate body.
FCC registration is a two-step process. First, the company applies for its FCC Registration Number (FRN), a unique number associated with the company for all transactions. Registration is free and can be done online using the CORES or by completing FCC Form 160. When registering online, note the FRN account number and password, as it is required for any account modifications.
After receiving its FRN, the company must then apply for a Grantee Code, a unique three-character identifier which the company will use for all its wireless products. The FRN and Grantee Code are specifically associated with the company’s address and with the individual designated as authorized signatory for the company. The FCC charges a small application fee for the Grantee Code. The company may pay online (recommended) by completing FCC Form 159, or it may pay by mail. The FCC must receive payment within 30 days of the company’s application or the associated Grantee Code will become invalid.
The authorized signatory need not be a president or vice president of the company. Because this individual is responsible for all of the company’s wireless applications, it is important that the address and authorized signatory remain up to date. If this information on file with the FCC is not current, it will hinder the filing process and delay receiving the Grant of Authorization.
Industry Canada has established a similar process for applying for a Canadian Company Number. All applicants apply online, where they receive their five-digit Canadian Company Number. Your company does not need to be located in Canada to receive a Canadian Company Number. For each filing, the company’s contact information and authorized signatory must be up to date and must match all documents submitted. Each company is allowed only one authorized signatory.
The FCC Grant of Authorization is attached to a specific product by the FCC ID number. The FCC ID number consists of a prefix containing three alphanumeric characters (Grantee Code) issued by the FCC and a suffix of up to 14 additional characters determined by the applicant and unique to each product. Available characters in both the prefix and suffix are A-Z and 0-9. Dashes are the only other acceptable character [TS2] . See Figure 1 for an example.
Industry Canada also requires that a specific Canadian Number be attached to each module or product. For Industry Canada, the prefix consists of the five-character Company Number, and the suffix is up to 11 characters that are user-defined for each product. Industry Canada allows only a single dash between the prefix and suffix. See Figure 2 for an example.
Requirements for ID labels vary between products and modules. The size of the product may also affect label requirements. Three main components are always required for products and modules: each label should contain the FCC ID Number, the Industry Canada ID Number, and the Model Number preceded by “Model [TS3]:”.See Figure 3 for an example. As indicated in the example, ID numbers are in all capital letters. Company logos or name are allowed but not required.
Labels for products that contain modules have a slight variation in that (1) Model Number for the module is not required and (2) the FCC ID and Industry Canada number must be preceded by either Contains or Contains Transmitter Module.
Label information must be permanently affixed via commercial label, engraving or silk-screen to the module or case for product certifications. If a label is used, the specification sheet for the label should be included in the filing packet. The specification sheet should provide details on physical properties, performance properties and chemical reagent.
This information should not be placed on any part of the case that is easily removable. It must be displayed in an easily visible manner.
Both the FCC and IC require an Agency Letter signed by the authorized signatory for each company. The letter simply states that the manufacturer acknowledges the appointment of individuals at the test lab to act as its agents in submitting the filing paperwork.
Both the FCC and Industry Canada also require the applicant to designate any information deemed to be confidential. When filings are complete, confidentiality letters are uploaded as public record and are therefore viewable online.
The FCC offers two types of confidentiality arrangements: permanent and short-term.
Short-term confidentiality is available for all items related to product certification. However, short-term confidentiality is limited to 180 days after the Grant of Authorization is issued. This essentially allows customers to maintain temporary control over sensitive information prior to the product launch or press release.
Permanent confidentiality is reserved for items or exhibits that are sensitive in nature, such as trade secrets or proprietary information. Some items do not qualify for permanent confidentiality, including test setup photos, external photos, and test reports. User manuals and internal photos may receive permanent confidentiality with expanded justification.
Industry Canada does not distinguish between short-term and permanent confidentiality. Items are simply marked Confidential when appropriate.
It is important that both the FCC and IC confidentiality letters match in terms of what is listed as confidential.
Industry Canada also requires several other signed documents. One of them, the Radio Equipment List, is an acknowledgment by the applicant that the information will be provided to Industry Canada and may be listed on the Industry Canada website. The letter also includes the applicant’s acknowledgment that any changes to the product must be documented and a notification sent to Industry Canada.
The second letter unique to Industry Canada is the Canadian Representative Letter, which provides Industry Canada with an in-country representative to act on behalf of the company if questions arise regarding the product application. For U.S. companies, the Canadian representative does not need to be a direct employee of the company; however, the representative must have their own company number. If your company is based in Canada, it is possible to have your company be both the Canadian representative and the grant holder. Let’s examine a few examples.
Example 1: LSR, a U.S. company based in Wisconsin, does not have a separate division or employee in Canada. LSR is then required to find a representative located in Canada willing to sign the Canadian Representative Letter and act on LSR’s behalf.
Example 2: LSR, a U.S. company based in Wisconsin, has a sales representative or another division in Canada. In this case, LSR would have two separate Canada Company Numbers: one for the U.S.-based portion and the second for the individual or division located in Canada.
Example 3: LSR is based in Canada. In this instance, a single Canadian Company Number would suffice for both the filing and the Canadian Representative Letter.
Additional documentation required for the filing includes the theory of operation, block diagram, schematics, and antenna data sheets.
The theory of operation differs from the product description. The theory of operation should provide an overview of how the product or module functions. It should highlight the specifications of the radio, including output power, channels and modulation type.
The block diagram is fairly self-explanatory. This diagram highlights key components of the product, particularly the radio communication aspect. One important element that is usually forgotten: crystal frequencies and locations must be highlighted.
For schematics, the latest revision should be submitted. It is important to include schematics for the entire product in addition to radio-specific portions. Schematics are generally compared against internal photos.
For external antennas, it is also necessary to supply appropriate data sheets.
For both product and modular certification, a user manual is required. There are slight differences in requirements for each type of certification; however, key components in each are the FCC and IC warning statements regarding labeling, modifications and RF exposure. Also, when shipping to Canada, the user manual should include the French translation of warning statements; this is a new requirement as of December 2010.
The 8pt modular letter is applicable only for modular, limited modular, split-modular and limited split-modular certifications. The letter acknowledges and demonstrates compliance to the eight requirements regarding modular approval. Again, this letter needs to be signed by the authorized signatory for the company. Details of requirements for modular approval can be found in CFR Title 47 Part 15.212.
A few ancillary documents and calculations required for the filing process include the emission designator, external photos, internal photos, test setup photos and MPE/SAR evaluation. Typically this information will be provided by the test laboratory, as it can be determined from test results or taken from test samples.
This article has highlighted the overall process and requirements for product and modular certification with the FCC and Industry Canada. As always, unique circumstances apply to each wireless application. Please feel free to contact LSR for further information and to generate a specific plan of action for your next product.
Thomas is the Vice-President of EMC Test Services at LSR. Tom has over 13 years of experience in EMC/RF Testing on a variety of products in the Industrial, Commercial and Medical Industry. Tom received a BS in Biomedical Engineering from the Milwaukee School of Engineering (MSOE) in 2000 and is an active member and contributor in IEEE.
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