When considering the requirements to access the global market for radio equipment, the EU and the USA are, usually, the first to be taken into account, mainly due to the importance of their markets and to their technical requirements, being the basis of most national regulations.
EU and FCC test reports/certificates are widely accepted in many countries by the National Authorities in charge of providing the needed Approvals, as a baseline to prove product compliance. However, there are important countries (such as China, Russia and Brazil, among others) which have their own Approval Schemes with specific sets of testing requirements, not based on FCC or European standards.
Even in those countries where the Radio Regulation is based on EU/FCC test reports, acceptance and approval processes are usually not automatic. Certification processes and requirements differ from country to country, which can easily turn into unplanned costs and delays unless an efficient approval strategy has been considered from the beginning of the product development phase.
Product families are a perfect example of the effect these issues can have.
First of all, spectrum use and management is a national matter and its regulation tends to differ from country to country, which will have an impact on hardware and software versions of a given product family. For instance, car key fobs operate at 315 MHz in Japan and at 433 MHz in EU. A manufacturer planning to sell a key fob model in both markets may have to develop two different product variants. A strategy that considers different HW/SW versions, depending on the target markets, can simplify development and homologation activities.
Secondly, when planning for an international radio type approval for a family of products, all target countries must be considered from the start, even if the manufacturer is not planning on gaining access to all of them at once. For example, if the target market is only the US or the EU, family approval can be obtained through testing a ‘representative’ model variant, together with an assessment by the Certification Body and a declaration by the manufacturer stating that the rest of the models included in the family do not vary in terms of performance or regulatory compliance (a typical example is when variants are defined solely based on their colour).
However, this strategy may not be cost-efficient should the company want to gain access to additional target markets, as family approvals are not permitted in several markets (Mexico, Brazil and China, etc.). In practice, this means that if a manufacturer of automotive head units or telematics units assigns a different product reference to different models of the same family, certification costs will multiply when trying to gain access to those specific markets.
An effective way to avoid this scenario is by approving a regulatory “dummy” model that contains all the functionalities and radio services (such as Bluetooth, Wi-Fi, Wireless Power Transfer, Cellular…) of the whole product family.
This “dummy” model must cover all of the variants’ technical requirements applicable to radio approval processes, namely Radio Frequency (RF), Electromagnetic Compatibility (EMC), Electrical Safety and RF Exposure/SAR. Additional differences between models that do not affect RF approval, such as color or buttons’ configuration, must be defined in products’ documentation.
The ‘dummy’ model should be listed in the EU and FCC reports, so that they may then be used as proof of compliance in other countries without family approval. This approach cannot be used for every country as some have specific requirements, but it is one of the key strategies to approach international radio type approval.
It is important to make clear that said dummy model could be an actual model variant of a given family as long as it covers all the radio services and electrical/electronic functionalities included in the remaining variants.
In future articles we will talk about other key strategies, such as modular approval. Applus+ regulatory experts can help you determine the most cost-effective strategy to approve product families, for both new products and those already on the market but that need to be modified or expanded. Contact us to get started!
By Davide Brandano, Radio Type Approval Manager at Applus+ Laboratories
Applus+ Laboratories runs global conformity programs for radio and telecom equipment. We draw on our status as a recognized Certification Body for the world’s key markets as well as on our global sites and agreements with local National Authorities and Laboratories to assess conformity in other countries. For more information about our radio type approval services.