With most of the world experiencing a phenomenal growth of electronic products, the electronics industry wants to reduce the burdens of testing and obtaining product approvals for global markets. Such efforts are already underway.
The FCC’s new provisions for personal computer (PC) equipment and their peripherals are advancing U.S. interests about mutual recognition agreements (MRAs) and streamlining the equipment approval process. These new equipment-authorization processes may serve as a model for other equipment currently subject to FCC approval.
Several domestic and international forces drive the need to streamline and improve product-approval processes. In the past, most manufacturers planned the time required for FCC approval so there was little orno actual delay in the product reaching the market. For example, product approval was performed in parallel with other necessary tasks, such as actual production or preparation for shipping.
But with the rapid pace of today’s technology, many electronic products today have a life cycle of only six months. As a result, manufacturers must reduce the FCC applications-processing time. At the same time, the federal government and the FCC are focusing efforts on providing services to efficiently meet the needs of customers.
The FCC has taken several steps to improve the equipment-authorization process. These include reducing processing time from 55 days to 35 days, developing (with industry) a standardized test report for computer equipment and a two-week approval for permissive changes, sponsoring workshops, and improving access to information on the equipment-approval process. More improvements are expected, such as implementation of electronic fee payment and filing of applications, increased availability of information over the Internet, and access to a data base of rule interpretations.
While improvements to theprocess are interesting, two areas are of landmark importance:
International MRAs that may require significant changes to the existing equipment authorization processes.
Deregulation of the equipment-authorization process for PCs and PC peripherals.
This equipment makes up approximately 55% of all applications currently filed (not including applications for telephone equipment registration filed under Part 68).
Digital Device Deregulation
ET Docket No. 95-19—On May 9, 1996, the FCC adopted a Report and Order in ET Docket No. 95-19 amending Parts 2 and 15 of the Commission’s Rules to streamline the equipment authorization requirements for PCs and PC peripherals. This action followed careful consideration of the comments filed in response to the Notice of Proposed Rule-Making.
The Report and Order permits PCs and PC peripherals to be authorized based on a manufacturer’s or supplier’s Declaration of Conformity (DoC). The DoC states that the product complies with all FCC requirements.
The Report and Order also permits marketing of PCs assembled from separate components authorized under a DoC. In such cases, no more testing of the completed assembly is required.
Declaration of Conformity—Under the new Rules, the manufacturer or supplier issues a DoC for its PC equipment to show that it meets FCC requirements. With the DoC procedure, the responsible party, normally the manufacturer or importer, performs measurements at an accredited laboratory to ensure that the equipment complies with the appropriate technical standards.
The manufacturer must include a copy of the DoC with the literature that accompanies the equipment. The declaration must contain this information:
Unique identification of the product; for example, name and model number.
A statement that the product complies with Part 15 of the FCC regulations.
The identification, by name, address and telephone number, of a responsible party located in the United States.
The party responsible for ensuring compliance must submit, upon request, documentation verifying compliance, including test reports, to the FCC within 14 days of receiving such a request.
The new process provides many important benefits to manufacturers of PCs and PC peripherals. For instance, manufacturers can authorize their equipment quickly and avoid delays associated with the previous FCC equipment-authorization process.
By reducing time to market, manufacturers compete more effectively. Also, manufacturers do not risk premature disclosure of information about their new products that occurred with the previous FCC process. Before the new process, information about product approvals was public after the equipment authorization was granted.
The DoC plan may advance the acceptance of U.S. product approvals for PCs and their associated peripherals in other countries. This new procedure could provide U.S. manufacturers with easier access to foreign markets, creating jobs and enhancing U.S. economic growth.
Labeling Requirement—Under the DoC procedure, the new, simplified FCC ID label on PC equipment includes a compliance logo. The new logo increases public awareness of the FCC technical standards and testing requirements for PCs and PC peripherals.
Accreditation of Test Laboratories—The new Rules stipulate that parties using the DoC process must employ an accredited laboratory to perform the compliance measurements. The FCC requires laboratory accreditation under the National Institute of Standards and Technology’s National Voluntary Laboratory Accreditation Program (NIST/NVLAP). A two-year transition period permits laboratories to obtain NVLAP accreditation.
To facilitate the accreditation of laboratories, the FCC recognizes accreditations performed by either NIST/NVLAP or the American Association of Laboratory Accreditors. Authority also is delegated to the Chief of the Office of Engineering and Technology to recognize additional accrediting organizations and to determine the continued acceptability of individual accrediting organizations and accredited laboratories.
Accreditation bodies must be approved by the FCC’s Office of Engineering and Technology to perform such accreditation based on International Organization for Standardization/International Electrotechnical Commission (ISO/IEC) 58, “Calibration and Testing Laboratory Accreditation Systems—General Requirements for Operation and Recognition.” The laboratories must be accredited to ISO/IEC Guide 25, “General Requirements for the Competence of Calibration and Testing Laboratories.”
The accreditation requirement is applied to all laboratories, including manufacturers’ laboratories. No persuasive evidence shows that manufacturers’ laboratories are more likely to perform compliance testing in a manner that is more lenient than independent laboratories. Excluding manufacturers’ laboratories from the required accreditation places small manufacturers who must use independent test laboratories at a disadvantage.
The laboratory-accreditation requirement ensures the testing quality needed by foreign administrations to accept U.S. test results. In the interests of promoting free trade, the FCC works closely with the administrations of other countries to develop MRAs regarding acceptance of the accreditation of both U.S. and foreign laboratories.
At the same time, it is unfair to accept the accreditation of labs from foreign countries that either do not accept U.S. accreditations or that impose additional barriers on U.S. companies. For purposes of the DoC procedure, the FCC accepts accreditation of foreign laboratories from countries with whom the United States has an MRA to accept the accreditation of U.S. laboratories. Foreign manufacturers using nonaccredited laboratories may continue to seek equipment approval for personal computing devices under the FCC certification procedure.
A specific transition period is not necessary since the FCC allows certification of PC equipment on an indefinite basis. While currently accredited laboratories may have some initial advantage because they perform testing under the DoC procedure sooner than others, this advantage should be mitigated by the decision to permit additional parties to accredit laboratories. The FCC also does not penalize manufacturers and importers that take advantage of the DoC process by delaying implementation of that procedure.
Further Action in Docket 95-19—This proceeding greatly benefits the computer industry and consumers. Notably, manufacturers now have the opportunity to self-declare conformity to the FCC Rules, saving considerable time and expense. The provision to permit systems integrators to declare conformity based on use of authorized components also makes compliance with the FCC Rules practical for small manufacturers and vendors.
These developments represent significant changes in the current FCC equipment authorization program. If MRAs are concluded, rule-making could be required to propose specific ways to implement them. The new DoC procedure for PC equipment may serve as a model for other equipment covered by MRAs.
This article is based on “Streamlining the FCC Equipment Authorization Process in Response to Changing Global Markets” by Julius P. Knapp and Art Wall, Federal Communications Commission, which appeared in the IEEE 1996 International Symposium on Electromagnetic Compatibility, Santa Clara, CA, Aug. 19-23, 1996 pp. 1-10. © 1996 IEEE.
Copyright 1997 Nelson Publishing Inc.