FCC Adopts New Equipment Authorization Testing Standards

Cooley alert
April 5, 2023

The Federal Communications Commission has released a Report and Order updating its equipment authorization rules to incorporate new standards for testing devices subject to the rules. Radio frequency (RF) devices must be tested to ensure that they comply with the FCC’s technical requirements before they are marketed or imported in the United States. The new rules align with the FCC’s ongoing efforts to ensure new RF devices do not cause harmful interference to other devices. Most of the changes focus on amending site validation and testing requirements. However, the FCC also deleted outdated references and transition periods within the existing rules.

The FCC monitors and updates its technical requirements by incorporating best practices from standards-setting bodies. In this latest update, the FCC incorporated standards for testing for RF emissions established by the American National Standards Institute (ANSI), Accredited Standards Committee C63 (ANSC C63) and the International Organization for Standardization (ISO).

The FCC adopted the following standards:

  1. American National Standard Validation Methods for Radiated Emission Test Sites, 1 GHz to 18 GHz (ANSI C63.25.1-2018).
  2. American National Standard of Procedures for Compliance Testing of Unlicensed Wireless Devices (ANSI C63.10-2020).
  3. General requirements for the competence of testing and calibration laboratories (ISO/IEC 17025:2005(E)).
  4. American National Standard for Methods of Measurement of Radio-Noise Emissions from Low-Voltage Electrical and Electronic Equipment in the Range of 9 kHz to 40 GHz, Amendment 1: Test Site Validation (ANSI C63.4a-2017).

The new rules will be effective 30 days after the FCC’s order is published in the Federal Register. After the rules go into effect, there is a two-year transition period for test labs and manufacturers to comply with ANSI C63.10-2020 and ISO/IEC 17025:2005(E). The FCC did not adopt a transition period for ANSI C63.25.1-2018 or ANSI C63.4a-2017, because there are alternatives to those standards that will remain in the rules.

Product manufacturers and laboratories should review the new standards to ensure that devices are tested in compliance with the new rules. Failure to do so could result in product launch delays, devices being impounded as they are imported into the US, or sanctions for devices that are imported or sold without meeting the testing requirements.

As the FCC’s changes only apply to devices approved going forward, any devices that have previously been approved under the FCC’s prior rules can continue to be marketed in and imported into the US.

If you would like additional information on the new rules, please contact one of the Cooley lawyers listed below.

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