The 4 Biggest Misconceptions about Regulatory Testing and Compliance

Perspective Shift: From Barrier-to-Market to Partnership

In a recent webinar with the IEEE, Ryan Urness of Ezurio's (formerly Laird Connectivity) Test Services detailed the common misconceptions that OEMs have about the requirements for leveraging module certifications when integrating into a host device. These misconceptions are common, and the entire process can sometimes test the patience of manufacturers. At the end of development, sometimes over schedule and sometimes over budget, this last hurdle can prove complicated and leads to the perception of testing as a roadblock on the route to market. The full webinar is available here and explores the topics of this post in much greater detail. While primarily about FCC and IC certifications, much of the webinar and its content applies to other regulatory regions as well. 

As described in the webinar, it’s important to shift this perspective. The test house in this scenario is a valuable partner on the route to market, but only when the manufacturer and the test house are fully prepared and aligned on the scope of testing and requirements for their device. Pre-certifications may only be leveraged under the correct conditions, including whether the device is body-worn, if there are other collocated transmitters in the device, whether the correct antennas are used, the country or regulatory region in question, and more.  

In this post we summarize Ryan’s four major misconceptions that manufacturers have around the compliance testing process. Understanding these can change the process from a potential breakdown to a smoother route to market. 

#1: “Pre-Certified” Doesn’t Mean "No Need to Test"

A major misconception is what is actually meant by the idea of a pre-certified module. In general, a certified module provides several advantages. It provides confidence in conformity, reduces filing requirements after certification, and reduces administration and evaluation required when integrating into a host device. All of this means less effort, less paperwork, less cost, and a dramatically smoother process. 

However, critically, OEMs still have a responsibility and a requirement to test. Validating that the module’s emissions are still within specification is still necessary. Furthermore, pre-certifications are secured with some strings attached, such as overall power output limits, proximity to the body and other transmitters, and more. The use case matters: for example, a grant of authorization may require that OEMs provide a distance of 20cm from all persons and not to be co-located with other antennas or transmitters. If an OEM’s device does not meet these stipulations, that grant of authorization must be modified by the module manufacturer in order to be leveraged in that application. This is a back-and-forth and a partnership process, and OEMs should work with a manufacturer that is able and willing to validate their pre-certification to an OEM’s requirements. 

Further complicating this is that requirements change. For example, Specific Absorption Rate (SAR) requirements are currently in a transitional period – currently at 5mm separation and in the 2.4 GHz band, the output power may be no more than 10mW. But in the future, that same output power must be less than 3mW, and it may apply to products and devices that were previously exempt. These are the sorts of things that an experienced test house is aware of, but OEMs may not be. Discussing the product in detail with the test house and the scope of required testing long in advance of final compliance work is critical for OEMs. Getting on the same page means less surprises, and overall greater chances of success. 

#2: FCC Approval is Not Necessarily a Green Light for Canada

It’s generally understood that Canadian and US requirements for wireless requirements share a great amount of overlap. As neighboring countries, it makes sense for wireless requirements to be similar and to make it more likely that a product validated for one is compliant for the other. However, these requirements are not perfectly harmonized. They have differences in terms of spectrum usage, acceptable limits, and even the methodologies that must be used to measure and validate compliance. 

Additionally, Canadian testing requires in-country representation for the approval process if the applicant does not have an established location or presence in Canada. This is a service that can be secured for OEMs that do not operate in Canada, but it’s something OEMs need to know in advance in order to be effective. 

Furthermore, the date between the publication of the test reports and the application for certification for a design may not be longer than 12 months in Canada. This can cause frustrations and complications at the end of the process if, for example, a project runs over schedule and that window lapses as failures or roadblocks or redesigns chip away at the available time. 

There are many more variations in Canadian requirements that do not align with the FCC, including some completely new test requirements that do not exist in the FCC region. These are discussed in greater detail in the webinar. Again, as with the previous section, it’s important to communicate clearly with your test house about the regions you intend to deploy your final product. Assuming that FCC certification will be applicable to Canada will push many considerations to the end of the testing process and may result in failure. 

#3: Switching to a New Antenna is Not Just About Type and Gain

It’s very common for OEMs to substitute an antenna into their design that is not precisely the same antenna as one that was pre-approved. However, many OEMs think that it’s a simple matter of selecting an antenna with the same gain and of the same type, expecting that RF behavior is the same and therefore approvals should be the same. In fact, the requirements are more complicated than that. 

FCC rules allow that no retesting of a system is required if the new antenna is of the same type, equal or lesser gain, AND (critically) similar in-band and out-of-band characteristics. This last point is frequently overlooked, but it is a significant variable. 

When considering an antenna’s gain, OEMs must consider the peak or maximum gain, not just the average gain. If maximum gain is capable of exceeding the previous antenna’s maximum gain, this replacement will fail. When considering in-band and out-of-band characteristics, this includes the antenna’s impedance, directivity, and efficiency. If an antenna does not share these characteristics, the replacement will fail as well. 

Considering all this, it’s possible to pursue a Class II Permissive Change with a new antenna. But, once again, this is an additional exercise with additional testing and adds a significant workload, often at a point where development is far along and last minute surprises are especially unwelcome.  

#4: Ready to test? Think again…

The leading misconception which is responsible for the most delays and additional costs in certification testing is the simple concept of test readiness. When is your product ready to test? In reality, the groundwork required for test readiness begins well before this point, and if it’s incomplete, your product is far from ready to test. 

What does this ground work consist of? It’s more than having a functional product that can be placed in a lab. It’s answering fundamental questions about the testing procedures and scope in conjunction with the test lab. It’s having the necessary documentation in place which the lab can use to conduct those tests. And if the final device contains more than one radio, this becomes more complicated: if you only have full control of one radio in the device, you’ll be unable to test the interoperation of those two radios. Simply testing one radio, perhaps a new module in a previous system, is insufficient. 

Complete control of the radio for testing purposes also means more than just placing the operating product in a lab setting. You’ll need to be able to do things like place the radio in continuous transmit mode, have control over all modulation, channels, data rates, and bandwidths, and to place in receive mode on all channels. Having a functional product is a start, but being able to have very granular control over the radio’s operation in all kinds of configurations is necessary for test. This is the kind of functionality you’ll want to secure earlier, rather than later. 

Lastly, documentation is critical to have prior to certification. Documentation includes but is not limited to things like your product’s user manual, theory of operation, block diagram, internal photos, antenna datasheets, and more. In some cases, this can be leveraged from a module manufacturer or the provider of the antenna hardware, but there are other documents that you’ll have to provide yourself, including label examples and specifics to your hardware. In either case, it’s important to think about this ahead of testing in order to avoid delays.

Conclusion

This is only a summary, and a more detailed discussion of this topic is available in this webinar. However, the lesson is clear: Certifications require preparation, foresight, and ideally close collaboration with a testing facility to avoid frustration and delays down the line. This urgency is compounded by the fact that certifications testing happens at the end of a long design process where additional costs and delays are particularly disruptive to launching on time and within budget. 

At Ezurio, our test engineers work with you before, during and after EMC testing. We help troubleshoot and advise every step of the way. With a dedicated focus on wireless testing, we bring expertise to your project through a deep understanding of the various certification standards required for market entry across the globe.

Ezurio's number one goal is to keep things simple, speedy, and streamlined for our partners. We will take a step-by-step approach to getting your product certified: Understanding the requirements, developing test plans, troubleshooting failures, researching test standards, and conducting on-site EMC and RF testing for the US, Canada, and Europe. Learn more at: 

https://www.lairdconnect.com/services/emc-testing