Pieter Robben

ACB

FCC/TCB Market Surveillance

FCC/TCB market surveillance

• Market surveillance on products which have been

certified for use in the USA is carried out by several

entities:

- Federal Communications Commission (FCC)

- Telecommunications Certification Bodies (TCBs)

FCC market surveillance

• Carried out or initiated by the FCC OET Laboratory

• Carried out or initiated by the FCC Enforcement

Bureau

• Carried out based on received complaints

• Targeted projects

• New technologies

• Oversight of TCBs

• Random sampling

TCB market surveillance

• TCB’s must carry out market surveillance activities as

described in, and based on, KDB 610077

• January 11, 2011 revision of KDB 610077 clarified

the required non-compliance reporting by TCBs

• June 8, 2011 revision of KDB 610077 clarified the

audit counting method which is to be used by TCBs

• October 25, 2011 clarification of follow up and

reporting requirements

FCC surveillance policy summary

• The TCB must audit 5% of the number of issued

scope A and B certifications per year

• The TCB must audit 2% of the number of issued

scope C approvals per year

• The TCB must audit 1% of the issued certifications

with SAR testing per year

• The TCB must actually test products

FCC surveillance policy summary

• Audits should be performed by TCBs throughout the

surveillance year and not all audits should be

performed at the end of the surveillance year or in the

year following the surveillance year

• The number of audits by TCBs must be based on the

number of issued Grants and not on the number of

unique FCC ID’s

• The sampling percentage required must be based on

the number of Grants issued by the TCB in the

surveillance year

FCC surveillance policy summary

• When an audit sample has not been tested it does not

count as an audit

• In case of found non-compliance the TCB must

inform the FCC and Grantee code holder immediately

and a resolution/follow-up should be submitted to the

FCC within 30 days

• The TCB must notify the FCC of non-responsive

applicants or applicants unwilling to send audit

samples (not marketed in USA is not a valid reason

for not providing an audit sample)

FCC surveillance policy summary

• The TCB must work with the applicant until the issue

is resolved

• If an issue cannot be resolved, the TCB must send a

summary to FCC which identifies all attempts to

resolve the issue

TCB selection criteria for audit sampling

• When selecting the samples to be audited

consideration may be given to the following factors:

- New technologies

- New applicant

- New test laboratory

- Products likely to exhibit non-compliances

TCB selection criteria for audit sampling

- Request from the FCC or IC for an audit to be

performed on specific product types

- Potential impact on licensed radio services, the

public switched telephone network (PSTN) or

user from a non-compliant device.

Typical items to be checked/audited

• Labeling of product

• User manual

• Comparison of sample product with certified product

• Antenna power (conducted)

• Radiated field strength

Typical items to be checked/audited

• Transmitter radiated/conducted spurious emissions

• Frequency band edge compliance

• Occupied bandwidth

• RF power spectral density

• SAR (specific absorption ratio)

Common items which fail checks/audits

• Labeling of product

- Label missing

- FCC ID missing on label

- Modular approval (host) label information

incorrect or missing

- Required warnings and information missing

Common items which fail checks/audits

• User manual

- User manual not made available for audit

- User manual not made available in English

- Required information to the user missing or

incorrect

Common items which fail checks/audits

• Comparison of sample product with certified product

- Sample product does not match the product

which was certified

- Modifications to ensure compliance are not

present in the final product

- Product was or has been revised

Common items which fail checks/audits

• Antenna power is higher than for the product which

has been certified

• Other items such as occupied bandwidth, frequency

band edge compliance

• Most items which fail checks/audits are

administrative items such as labeling and user manual

• Problem issues are detected in approximately 30% of

the total number of audits per year

Common problems concerning audit activities

• Requests for audits remain unanswered

• Materials are missing when audit samples are

received for testing

• Instructions for placing test samples in “test modes”

where required for audit testing are missing or

incomplete

• Test samples are not submitted for audit testing for

several other reasons (e.g. the product is no longer

manufactured or the product never has been

marketed)

Implications of audits for a certification body

• Many issued certificates implies many audits per year

• Many audits impose a relatively high cost on a

certification body

• Cost and time for audits will even increase due to

simple and sometimes unnecessary non-compliances

which are found

• Audits take up a lot of time in the testing laboratory

due to complications during testing (e.g. “test modes”

are not implemented or accessible)

Questions ?

Thank you for your attention