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RFID Device Suppliers: Beware the FCC's New Authorization, Marketing and Importation Rules

The Federal Communications Commission has voted to approve new rules impacting how RF equipment, manufacturers, vendors, importers and distributors may conduct business.
By Ronald E. Quirk

Measurement Requirements for RF Equipment Authorization

Current Rules
The FCC will accept measurement data in accordance with three types of measurement procedures: OET bulletins or reports published in its Knowledge Database (KDB), those published by national engineering societies and acknowledged by the FCC, and current measurement procedures accepted by the FCC.

New Rules
1. Acknowledgement has been added to permit reliance on advisory information contained in the FCC's online KDB publications.

2. References have been added to specific sections of American National Standard for Compliance Testing of Transmitters (ANSI) C63.4-2014 and ANSI C63.10-2013, to address certain measurements for some unlicensed devices.

3. The current rules for RF measurement of composite systems have been combined into a single rule, while some references to applicable regulations have been retained.

4. ANSI C63.26 is the new standard for compliance testing for licensed devices. References to this standard will replace measurement in FCC rules for RF power output, modulation characteristics, occupied bandwidth, spurious emission at antenna terminals, field strength of spurious radiation, frequency stability and frequency spectrum.

E-Labeling
The FCC has very strict rules about properly labeling RF devices before they are placed on the market. Manufacturers of RF devices and other responsible parties have been subject to fines and sanctions by the FCC for improper labeling of their devices.

Current Rules
The FCC requires that all RF equipment have "permanently affixed" labels containing specific compliance information. The information varies, depending on the category of the device. If the device is too small to accommodate a proper label, the FCC permits the information to be listed in the user's manual or on the box in which that device is contained. The "FCC identifier" must be on the device itself, regardless of how small the device is.

New Rules
Any RF device that is equipped with an integrated electronic display screen, or one without such a screen that can operate in conjunction with a device that has a screen, may display any labeling information required by the FCC.

Conclusion
This is a high-level overview of some of the FCC's equipment regulation changes. Due to the complexity and comprehensive nature of the proposed regulation changes, an exhaustive report is beyond the scope of this article. All information provided in this article is informational only, and should not be relied upon as legal advice. Decisions should not be made without first seeking the advice of experienced telecommunications counsel.

If you would like additional information concerning the RF equipment rule changes or related matters, please contact IoT attorney Ronald E. Quirk, Jr. at (703) 714-1305 or req@commlawgroup.com. Ronald is the head of the Internet of Things & Connected Devices Practice Group at Marashlian & Donahue PLLC, The CommLaw Group, where he focuses his practice on serving the comprehensive needs of the burgeoning and complex IoT industry, including contracts and commercial law, privacy and cybersecurity, spectrum access, equipment authorization, tax, regulatory compliance planning and more. His career has spanned more than 20 years, including several years at AMLAW 100 firms and the FCC.

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