Opening the Door William H. Graff, AmericanTCB

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Opening the DoorWilliam H. Graff, AmericanTCB
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Opening the Door

• William H. Graff
• President and Director of Engineering
• 886 920399260
• whgraff_at_atcb.com
• Major Chen
• Manager East Asia Branch Office
• 886 922145866
• major_at_atcb.com
• Jerry Lee
• Manager China Branch Office
• 86 13510719330
• 86 13641223938
• jerry_at_atcb.com

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Why are there regulations?

• The radio frequency spectrum is limited, natural
  resource.
• This resource must be protected from pollution
• This pollution can be either natural or man-made.

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FCC ????????FCC RULES REDUCE ELECTROMAGNETIC
INTERFERENCE
Noise
Radiated
Conducted
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1920s American Electronics

• Public fascination in early experiments with
  voice over radio waves created a demand for radio
  receivers and broadcast content.
• Manufacturers began mass production of radio
  receivers in response to public demand.

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Confusion in the marketplace

• Radio transmitters and receivers were created in
  a completely unregulated and immature market.
• Broadcasters and consumers increasingly found
  themselves troubled by interference.

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Realization and maturity

• Eventually the radio spectrum became almost
  unusable by consumers and broadcasters
• Increased public awareness of interference led to
  political pressures.

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Decisions

• In 1934 the Congress of the United States
  declared the airwaves the property of the people
  and created the FCC as the responsible agency for
  managing the radio frequency spectrum.

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Fast forward to Today

• Today the FCC has dominion over all devices which
  create or use radio frequency energy within the
  frequency range of 10KHz to 300GHz. The core
  mission of the FCC remains regulating
  interference pollution.

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Classifications

• Transmitters used for communication.
• Licensed and protected
• Unlicensed unprotected Low Power
• Computers and Radio Receivers.
• Unintended Radio Sources
• Industrial, Scientific and Medical
• RF sources not used for communications, but used
  for work

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Important Exceptions

• FCC does not regulate safety. This is handled by
  private enterprise.
• FCC does not set consumer performance standards.
• FCC has in place regulations for telephone
  terminal equipment, but in recent years has
  transferred much to the private sector.

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International Regulations

• Most other developed countries have copied in
  some fashion the regulatory model of the FCC.
  Many have included performance and safety issues
  into their regulatory scheme.

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International cooperation

• Since radio waves cannot be kept within political
  borders, international cooperation has proven
  essential as equipment which utilizes RF energies
  has evolved. Coordination of limits and spectrum
  assignments has proven very useful.

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A Success Story

• International cooperation has been greatest in
  the standardizing of emission limits from
  computing equipment.
• Test laboratories across the world have a nearly
  universal standard for characterizing unintended
  RF pollution.

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Acceptance of Test Data

• International agreements between governments have
  allowed test data from one country to be accepted
  by another.
• For USA, a laboratory listed with the FCC
  database is eligible to submit data to be used
  for Certification.

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Mutual Recognition Agreements

• MRAs take the process one step closer. They allow
  countries to authorize equipment on their own
  without the need for excessive regulation.
• Laboratories in countries with MRAs with USA can
  perform Declaration of Conformity if accredited.
  For USA this equipment is marked with FCC Logo.

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Important Note MRA and China

• Since no MRA yet exists with US and China, test
  laboratories cannot do complete equipment
  authorizations on their own. However, they are
  still free to submit test data leading to
  Certification.
• i.e China laboratories cannot yet perform a DofC
  for the US market

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Equipment Authorizations

• Manufacturers should be aware of the different
  types of Equipment Authorizations
• Certification
• Declaration of Conformity
• Verification

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Certification

• Certification is a process where a product is
  tested to applicable FCC radio law, and the Test
  Report along with all applicable exhibits are
  submitted to an authorized agency.
• Documents are reviewed.
• If accepted, a Grant will be issued and the
  device will be listed in FCC database.

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FCC Website and Database
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What is a Grant?

• A Grant of Equipment Authorization is a document
  which shows acceptability to US radio law.
• It is required by Customs before a device can be
  imported into the USA.
• Grants are only issued once all Exhibits are
  received and approved

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Required Exhibits (always)

• Application Form
• External Photographs
• Internal Photographs
• Schematics
• Electrical Block Diagram
• Operational Description
• Label and Location
• Test Report
• Test Setup Photographs
• Manual

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Additional Exhibits (rule dependent)

• Confidentiality Request Letter
• RF Safety Report (SAR or MPE)
• Rule specific attestations
• Parts List
• Tune-Up Procedure

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So how does the process work?
CERTIFICATION
Create report with Technical Information
Send report, Exhibits and Application to ATCB
Test Product at quality laboratory
Receive Grant with FCC ID Number
Grant
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Steps Required for New Applicant

• Get an FRN
• (Federal Registration Number)
• Get a Grantee code
• (Online cost is 55USD)
• Have product tested by listed laboratory
• Submit data and all required exhibits to ATCB
• Answer questions promptly
• Receive Grant
• Sell product

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Obtain an FRN

• The FRN consists of a 10 digit number that
  uniquely identifies anyone who does business with
  FCC
• It is an important number that will be used in
  all transactions by the Applicant with FCC. Save
  it and keep it safe
• Start at http www.fcc.gov
• Click on link at left side of screen
• Answer questions asked by the program

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Purchase a Grantee Code

• An FCC ID consists of a Grantee Code assigned by
  the Commission followed by 14 alphanumeric
  characters of the Applicants choosing. Any valid
  character 09, AZ, plus - is acceptable. The
  Grantee Code is the Applicants unique identifier
  within the FCC equipment authorization database

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Ready for Submission

• You should now have all the basic pieces for
  submission to the FCC using the TCB process.
• Kindly provide all required Exhibits along with
  the Test Report at your earliest convenience.
• Typical turn around time assuming all documents
  are complete and accurate should be within 3
  business days or less.

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Success!

• Once a valid Grant has been received and the
  Equipment Authorization process has been
  completed, it is now legal to sell the product in
  the USA.

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What if I try and cheat?

• The FCC is capable under law to make substantial
  penalties for any infraction of the law. These
  penalties can be as much as 11,000 for each item
  improperly sold.
• The FCC has as much power as Federal tax
  collectors (IRS) to take action against egregious
  violations.

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Penalties can be severe

• Deliberate attempts to circumvent the process are
  viewed as serious violations.
• Even unknowing violations are viewed harshly.
• Product seizure, fines, and potential jail time
  are all possible.

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How to choose a laboratory

• Look for an Accredited laboratory.
• or
• Look on the FCC website for a listed lab
• https//gullfoss2.fcc.gov/oetwl/index.html

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How to choose a TCB

• Experience, Experience, Experience
• There is no substitute for experience with the
  FCC rules.
• AmericanTCB is one of the first 13 original TCBs
  to become operational in June, 2000
• To date, we have Certified over 4000 products

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Advantages of using ATCB

• Easy to use secure electronic internet interface
• Easy to track your Certification progress
• Archive of all your product Certification files
  maintained for 10 years

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Support

• ATCB views a large portion of its mission is
  education. We hold seminars all over the world.
• ATCB will help you gain a clearer understanding
  of the FCC Rules.
• ATCB will happily assist in training of your
  staff. If you are making better filings our life
  becomes easier too.

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Questions?

• whgraff_at_atcb.com
• major_at_atcb.com
• jerry_at_atcb.com