Taking radio products through compliance

Compliance requirements for radio products

Compliance requirements for radio products

Simon Hindle discusses compliance requirements for radio products

Simon Hindle is a Business Development Manager for TÜV SÜD. He has been in the industry for over 15 years and has worked with a wide range of customers taking radio products to the marketplace from chipset manufacturers looking to validate their designs, through to university spinouts taking a radio product to the market for the first time. 

We spoke to him about taking radio products through the different requirements in different regulatory regions. Here is what he had to say.

What compliance requirements are you likely to face as a Manufacturer?

There is a non-regulatory approach, this is an approach that we're very used to in Europe. Here a manufacturer effectively makes a claim of compliance; a declaration of conformity - they perform testing in order to generate evidence to substantiate that claim.

One the other hand there are regions that are regulatory in nature, such as the US, Canada, Japan, Korea, China and Brazil. These countries all require you to do some tests, make a submission to an authority who's going to grant you an approval. Whereas in Europe and some other regions like Australia and New Zealand have this non regulatory approach. Manufacturers are obligated to make a claim of compliance and substantiate that with test evidence.

What are the specifics of the regulatory framework you face in North America and Europe?

No matter where a manufacturer is looking to place a radio product, they are generally going to come up against three specific compliance requirements.

One is that the radio is well behaved; it is transmitting on the right channel with the right frequency in the right power. There is going to be an electromagnetic compatibility requirement. This means that the product is not going to cause interference to other equipment, and in certain regions, e.g., Europe, is going to be able to withstand interference placed upon it. And then there is a safety requirement. This is safety of electrical equipment and is quite far reaching. This looks at all the hazards that the product presents, not just electrical safety, but also chemical safety, RF exposure, mechanical safety and so on. 

If you're going to take your product into the US, you've got two regulatory authorities that you're going to have to deal with. You've got the FCC who is going to look after anything to do with RF, so RF exposure and RF performance of the radio and EMC. Then you've got the Occupational Health and Safety Administration (OSHA) who are going to look after the safety related aspects of your product.

In Europe, there is a different way of doing things. The onus there is on the manufacturer to perform tests. The tests are listed in the official journal; each of the directives has an official journal. For radio products that fall into the Radio Equipment Directive, you would look at the radio equipment directive Official Journal. You would identify the relevant standards that you would apply to your equipment in order to generate the evidence that allows you, as a manufacturer, to meet your obligations and substantiate your declaration of conformity.

What do you need to consider when designing a product with an RF module?

Those looking to take a radio product to the marketplace have got two main options when it comes to product design. They can start from scratch, design their products around an RF chipset or they can use somebody else's radio module which provides a fast and effective way to get a radio into a product. If you are designing from scratch, then you're going to have experience of high frequency design within your team. You're going to have more to do when it comes to the compliance phase - there's going to be more testing to do which ultimately leads to increased costs.

For those that don't have the skill set to take an IC through the design phase, radio modules are a cost-effective route for manufacturers to add connectivity to their products.

What compliance requirements do you need to consider when using radio modules?

Although radio modules provide manufacturers a straightforward way to add connectivity on to a product, manufacturers need to be cognizant of the fact that when they get to the compliance phase, there is guidance from the EU and the FCC, that remind manufacturers to ensure that their products meet with the legislation. In the past for North America, it was okay for you to drop a radio module into your product and then mark on your product, this product contains FCC ID of the module. Now, the guidance says that you need to do some tests to make sure that when you put your module into your product, that the product compliance is where it needs to be.

Why is it important to select the right module manufacturer for your product?

It is important to select the right module manufacturer when you're going to embed one of their modules into your product. You're going to basing quite a lot of the evidence that you put into your technical file on the evidence that the module manufacturer will provide you. There are a few things that you ask them when you're going through the decision process. In North America, it's straightforward to understand the Compliance Status module. You can go on to the FCCs website and enter the FCC ID of the module, and you will see a whole host of information about that module.

In Europe it’s not the same. Manufacturers who CE Mark their radio modules are obligated to provide you with a declaration of conformity. The first thing that you need to do is you need to have a look at that declaration of conformity and use it to make sure that the standards listed in that declaration of conformity are current against the current legislative requirements. Manufacturers are not obligated to provide you with test reports, however, you as the integrator of a module, are going to rely on some of them module evidence in your technical file. So, you really need to have access to those test reports.

You're also going to need to know how to put the module into its test modes. One of the things that you are required to do by the guidance document is to perform some tests on the end product that ensure that the product is compliant. The word ‘assess’ is used in the documentation, but effectively, you do an assessment by performing some limited testing on the RF performance of the product.

We've talked about how it's important for manufacturers integrating radiant modules, that they to get sufficient, relevant documentation from the module suppliers and test mode. This is incredibly important when we start to look further afield; into other regions where we want to move with these products. Lots of regions will require you to submit the test evidence for the radio module. This is the evidence that you've performed on the product in conjunction with the evidence for the radio module. Other regions are going to require you to send samples of your product with instructions on how it how to fire the test modes to enable those countries to perform testing on your product.

Why is it important to start working with your compliance partner at an early stage?

The key message is it's important for people looking to take radio products to the marketplace to start to talk to their compliance partners as early as possible in the process. We'll be able to help you identify requirements. We'll be able to give you guidance on what testing is required. We'll be able to help you with any documentation requirements. We can also support you when you're looking outside of North American or the European Union into further afield and provide you with services that allow you to take your product to the global marketplace. At TÜV SÜD, we have a fantastic team who are going to support you, and work with you to the complete compliance journey. Contact us to learn how we can help your organization.

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