An overview of the North American Regulatory Compliance requirements
Wi-Fi 6E has identical IEEE specifications as Wi-Fi 6, but has an “extended” spectrum in the 6 GHz band for unlicensed use. With Wi-Fi 6E, consumers have access to an additional 1200 MHz of spectrum. Consumers will need a Wi-Fi 6E router and a Wi-Fi 6E device, such as a smartphone or computer, to take advantage of the 6 GHz channels.
Any device that previously had 2.4 and 5 GHz Wi-Fi capabilities, i.e., Access Points (Indoor and Outdoor), and client devices like cellphones, tablets, etc., will want to take advantage of this added spectrum for better performance of their devices.
Benefits of Wi-Fi 6E:
The Federal Communications Commission (FCC) has made 1200 MHz of spectrum available in the 6 GHz band. This is a significant increase, as prior to 6 GHz, Wi-Fi 6 networks used 580 MHz of the 5 GHz spectrum allocation.
The frequency allotment of each Wi-Fi 6e U-NII band (Unlicensed National Information Infrastructure) that has been added is as follows:
Per the Federal Communication Commission regulations, the UNII-6 and -8 are dedicated for Indoor use only whereas U-NII-5 and -7 can be used both Indoors and Outdoors.
The FCC has rolled out the Certification guidance for Wi-Fi 6e Certification in two phases, Phase 1 and Phase 2. Certification for Phase 1 devices is now being accepted. Certification for Phase 2 devices is not available at this time and is dependent on when the Automated Frequency Coordination (AFC) system is finalized and approved.
The devices included in Phase 1 are Indoor Devices, and are listed below along with the associated (new) Equipment Classes (applicable to a Form-731).
These devices are under control of either a low-power indoor access point or Standard power access point. The indoor configuration is addressed in the Phase 1 test plan, whereas outdoor configuration will be addressed in Phase 2.
The devices included in Phase 2 are Standard Power Access Points and Associated Client Devices, and are listed below along with the associated Equipment Classes (applicable to a Form-731).
Phase 2 certification of dual client devices is allowed when under control of a standard power access point.
The applicable FCC Rule Part is still the same as 5 GHz Wi-Fi devices, however, the FCC has added specific requirements for devices operating in the newly added U-NII bands.
The requirements for all the measurements have been laid out in the Part 15 Subpart E §15.407 standard sections 4-10 and comprehensively in the FCC’s Office of Engineering and Technology Knowledge Database under KDB 987594. The rules and guidance respectively linked below.
Several of the test requirements remain the same for these new bands, however slight deviations in the measurement methods may be applicable. New requirements include maximum fundamental EIRP, fundamental EIRP power spectral density in any 1 MHz, in-band emissions masks and contention-based protocol.
The detailed rules and guidance are given in the above linked rule parts and KDB guidance. A brief reference guide to some of the limits is given below:
Table 1: Brief reference guide to some of the limits from Part 15 Subpart E §15.407 standard sections 4-10 and comprehensively in the FCC’s Office of Engineering and Technology Knowledge Database under KDB 987594. (This guide does not substitute the complete guidance given in the applicable rule parts and KDB.)
An accredited testing laboratory can perform the Phase 1 testing to support Certification, and even though Phase 2 Certifications are not currently being accepted, most of the Phase 2 testing for which guidance is available can be conducted in preparation for Phase 2 Certification. However, if there are any changes to the requirements for Phase 2 devices, whether specified measurement methods or regulations, additional testing may be required to address these deviations.
Once the FCC releases testing guidance for the Automated Frequency Coordination System, that testing will have to be conducted and that data compiled into the Phase 2 report along with the previously conducted testing. This will subsequently be submitted for Certification to the Telecommunication Certification Body (TCB).
All new devices with no prior Certification will have to be tested and go through the general TCB submittal for FCC to get Certification, which TÜV SÜD can provide.
Generally, the FCC does not allow the addition of a new Equipment Class to an existing grant, but in the case of Wi-Fi 6e there are exceptions for devices both approved under existing 5 GHz (NII) and for adding equipment classes when Phase 2 device are available for certification.
The FCC will permit any device certified in Phase 1 that also qualifies under Phase 2 to add equipment classes and file applications under the same FCC ID if it was initially filed as a composite device and no HW changes have been made.
TÜV SÜD’s testing and certification services allow manufacturers to ensure that their products comply with the FCC’s changing requirements without affecting their product development timelines. Our continuous compliance strategy guidance and TCB approval services help manufacturers meet their time-to-market targets without running the risk of having their products blocked by the authorities. TÜV SÜD provides FCC certification services for manufacturers and suppliers of radio and navigation equipment wishing to gain access to the US market.
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