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E-Labeling RFID Devices Can Save Suppliers Cash

Doing it wrong can cost millions and trigger market exclusion.
By Ronald E. Quirk
Sep 27, 2017

In furthering its efforts to modernize radio frequency (RF) equipment regulations, the Federal Communications Commission (FCC) recently codified rules that permit the electronic labeling (e-labeling) of RF devices, including RFID devices, as long as they have the capacity to digitally display the required regulatory information.[1] While e-labeling can save RFID and other RF equipment suppliers money by, among other things, eliminating the cost of purchasing and affixing permanent labels to all their devices, the FCC will impose substantial fines and strict sanctions on suppliers that incorrectly implement e-labeling or otherwise violate its rules.

The FCC's Labeling Rules
The FCC requires that parties responsible for FCC compliance (typically, the manufacturer or importer), with limited exceptions, test and label RF devices before marketing or operating them in the United States.[2] Transmitting RF devices that require FCC certification (intentional radiators) and non-transmitting RF devices that require self-authorization by the FCC's new Supplier's Declaration of Conformity procedures (unintentional radiators) must display labels containing company identification information, as well as regulatory compliance statements.[3]

Historically, the FCC has required that RF devices have permanently affixed labels prominently displayed on them.[4] If the devices were too small to accommodate a proper label, the FCC permitted the information to be listed in the user's manual or on the box in which the device is contained.[5] The FCC also permitted e-labeling under certain limited circumstances.[6]

New E-Labeling Rules
The new rules codify the procedures that RF suppliers must follow if they wish to utilize e-labeling for their products. E-labeling is optional; suppliers may still use physical labels if they wish. The key provisions of the new rules are as follows:

• Information as to how to retrieve the compliance information and company identification via the e-labeling must be provided to the user, either in the instruction manual, or on the packaging material or the company's website. If the website is used, the packaging material must provide instructions indicating how to access the website.[7]

• No codes or special permission to access the e-labeling information may be used, and accessing that information may not require more than three steps from the device-setting menu.[8]

• The e-labeling information must be programmed by the responsible party and secured so that third parties cannot modify it.[9]

• The company's unique identifier and information about the website that contains the relevant information must be printed on the device or its packaging.[10]

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