In 1023, 2023, the FCC of the United States issued a new requirement for data citation rules, KDB484596D01 Referencing Test Data V 02. 484596D01 Referencing Test Data V02 replaces 484596D01 Referencing Test Data V01, which provides guidance for the reference of test data and allows the reference of test data in the test report submitted in the related equipment authorization application. For similar equipment with multi-model application and differentiation, if EMC(RF) and RF exposure assessment data are cited to reduce the test volume, KDB inquiry consultation must be submitted to obtain FCC authorization.
The update is as follows:
Update 1: The extended terms of EMC and RF exposure data citation are introduced (the previous guidelines provided in TCBC seminars (October 2020 and April 2021) are merged), and the data of Spot check can't exceed 25% compared with the previous reference data.
Update 2: The query procedure based on ECR KDB provides a new guide, and the submitted ECR KDB reference data query shall meet the following standards.
When taking ECR KDB inquiry, choose "equipment conformity review (ECR)" as the first category and "data reference" as the second category. Selecting an incorrect category will require correction, thus delaying processing.
Only grantee/applicant of the same Grantee Code can submit data reference ECR. Applicants can also choose to have the testing laboratory, TCB or other authorized agents submit ECR on their behalf. Test data can only be referenced in applications under the same Grantee code. The selected products must be certified by the same assignee, or the ID change must be submitted to the same Grantee according to the provisions of Section 2.933.
After receiving the FCC's positive reply to the ECR query (that is, the FCC "accepts"), the applicant can contact TCB and provide all the information (such as test data) required for the 731 form application. This should be done for products (if not yet certified) and variant devices.
FCC's acceptance of ECR does not mean that it recognizes the validity or accuracy of the data provided. This is only a technical proof that the variant equipment meets the data reference requirements.
A copy of the ECR KDB query (indicating FCC acceptance) shall be provided to TCB and uploaded together with the attachment of Form 731 as a supporting reason for the data reference process. If necessary, ECR queries can be uploaded as long-term confidential exhibits. TCB has the right to conduct a separate KDB investigation to FCC to confirm the validity of ECR or any statement therein.
A new, separate and complete ECR is required for requests of other variants, or for changing the FCC ID for reference models certified by different transferees.
Update 3: Added examples to illustrate possible scenarios.
★ 7.1. Multi-band Cellular Handset Multi-band Mobile Phone
A cellular phone (handset) is certified as a multiband operating in a licensed commercial mobile radio service band, for example, part 22, part 24, part 25 and/or part 27 below 3GHz. Reference device has been certified for all bands, and variant device will use a reduced set of bands. Variant device has the same components as reference device, and the band reduction operation is realized by software.
In this case, the data reference process is not needed, because the test on the reference device includes all bands, thus covering all possible use cases required for compliance demonstration. All mobile phones usually have the same FCC ID, because the only difference is related to the loaded software or firmware.
If the band reduction function of a variant device is obtained by removing components from the reference device design, the data reference process can be allowed for the variant device as long as the component removal does not lead to significant changes in the transmission mode compared with the reference device. It should also be considered that for the reference RF exposure data, the most significant changes are usually those related to the near-field emission mode, and these changes may be caused by minor modifications of PCB layout or component placement.
Reference device and variant device may or may not be under the same FCC ID: this is a manufacturer's choice/application, which needs to be approved by FCC as part of the ECR KDB investigation. However, according to Article 2.907(b) of the Rules, this does not affect the authentication procedure).
★ 7.2. DFS Data Referencing DFS data reference
If client device meets the requirements of KDB 905462, DFS client device is allowed to reference DFS data.
For example, the DFS test reported by reference device includes 30 tests for each BW mode (20, 40, 80MHz) and each radar waveform. For the approved variant device (which may also have non-DFS-related changes), the DFS spot check test report may include the widest BW mode (80 MHz) and 10 tests of each radar waveform to prove the required passing percentage of each waveform.
Warm tips
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