ISED Canada standard RSS-102 Iss 6

ISED Canada standard RSS-102 Iss.6 (Radio Frequency Exposure Compliance of Radiocommunication Apparatus) is mandatory from Dec 15th 2024 when Iss.5 is phased out after a 1-year transition period.

Issue 6 is available here RSS-102i6

What are the most notable revisions from a manufacturer’s perspective?

New exemption and test limits for Nerve Stimulation (NS) devices.

Nerve Stimultion assessment applies to transmitters operating <10 MHz where the instantaneous effect of RF fields on human nervous system is more concerning than prolonged thermal heating impact, such as measured when SAR testing.  Previously utilised supplementary procedure SPR-002 did not contain exemption methods.  Instead, RSS-102 Iss.5 simply had exemption limits from SAR for devices below 300 MHz, and exemption limits to Routine Evaluation for >10 MHz.  This left manufacturers of all transmitters operating at <10 MHz needing to meet the RF Field Strength Limits (e-field and h-field) in RSS-102 Iss.5 Table 4, commonly by way of testing.

RSS-102 Iss.6 however introduces exemption calculation methods under Section 6.2 that may be utilised and can help possibly avoid testing if your device is of inductive nature (the exemption only applies to inductive devices).  E.g. RFID reader system – such as those utilised in door entry with passive tags - operating at say 120 kHz.  Table 10 indicates exemption limits for such devices, when considering both the separation distance and the Ampere turns of the primary radiated coil.

Non-inductive devices will still need to meet the e-field and h-field limits as given in RSS-102 Iss.6 Section 5.3.1, Tables 5 and 6.  Note however that the test limits here have reduced, as shown (uncontrolled environment):

Manufacturers compliant to the previous limit, but not compliant to the new limit, might require re-evaluation testing.  Speak with your commercial representative for assistance in either case.

Revised exemption limits for Specific Absorption Rate (SAR)

When comparing RSS-102 Iss.5 Section 2.5.1 (Table 1) SAR exemption limits to RSS-102 Iss.6 Section 6.3 (Table 11), ISED have reduced all levels at which devices are now SAR exempt.  For example (uncontrolled environment):

Manufacturers should be reminded that ALL devices placed on the Canadian market must meet the requirements of the latest relevant standard at the time.  Devices certified prior to Dec 15th 2024 will be required in all cases to ensure continued compliance.  Note however that it is enough to write some form of record of assessment and keep on file locally, manufacturers are not expected to file re-evaluations with ISED when exemption is still applicable.  However, it is very possible that some manufacturers who previously were exempt, no longer are.  In the above example, operating at 2450 MHz and with a tune-up adjusted maximum output power of 3.5 mW was previously exempt, it is not anymore.

Manufacturers compliant to the previous limit, but not compliant to the new limit, might require re-evaluation testing.  Speak with your commercial representative for assistance in either case.

New exemption limits for Absorbed Power Density (APD)

With expansion into frequency bands above 6 GHz, such as WiFi 6/6E, RF Exposure procedures needed to come up to speed by offering better exemption criteria for such devices, where previously only a broad exemption applied.  See RSS-102 Iss.5 Section 2.5.2 “above 6 GHz and the source-based, time-averaged maximum e.i.r.p. of the device is equal to or less than 5 W”

RSS-102 Iss.6 Section 6.4 now offers consideration of operating frequency and separation distance, as shown in Table 12.

Revised maximum separation distance for body worn SAR measurements

Reduced from 15 mm to 10 mm.  This might be applicable for manufacturers of devices that utilise a belt clip, or some other mechanical means by which the device was previously tested at up to 15 mm.  

Contact TÜV SÜD UK for further guidance about how these changes impact you.