The Spring-2025 TCBC Workshop was recently held as a three-day event packed with presentations covering a wide range of topics relevant to wireless device manufacturers and other stakeholders.
Our notes are now available, capturing the essential information from the ISED presentations (Day 1) and FCC-day (Day 2) of the event.
ISED Updates
- Fee Updates: announcement of new equipment registration and amendment fees that took effect on the first day of the government fiscal year, based on the April 2024 consumer price index of 2.7%. Specifically, the new equipment registration fee is $804.14 per submission, and the equipment registration amendment fee is $402.07 per submission. For permissive change applications, the fee is $42.7.).
- ISED Blockchain Pilot Project Update: The pilot has been extended for another 6 months and remains free of charge for participants.
- New Option for Referencing Previous Test Data: A new option for finished products (including host certification) when referencing previous test data was presented. This includes referencing previously certified products within the same or a different ISED certification family, previously ISED certified modules, and potentially FCC certified products if they cover all applicable ISED requirements. Key requirements include the test report being less than one year old, submitting a request to ISED prior to referencing the data, attaching any approval for reusing test data to the application, and the upcoming availability of a new “finished product reuse test data involved” device type in SPECTRA. You would have missed the practical guidance on how to submit a request for permission to reuse test data, typically through the CB or test lab explaining the situation to ISED’s radio team.
- SPECTRA Code Drop 58 Changes: This includes significant changes related to RSS 102 RF exposure input fields, such as changes to the terminology for SAR evaluation and AR exposure valuation (now Field Reference Level – FRL). New questions for nerve stimulation and Applicable Power Density (APD) were added, and Limited Power Density (LPD) was changed to Incident Power Density (IPD). The yes/no answers have been replaced with more comprehensive options (measured, simulated, exempted, not applicable), and the test lab scope is now tied to these selections. There were also changes on the emission page, including specifying single frequency or frequency range and a revised power input section with separate fields for conductive power and field strength/radiated power.
- Guidance on Referencing Data and Permissive Changes: Clarifications on when referencing data for new IC IDs requires an inquiry to ISED and when it might not (e.g., similar physical design with modifications qualifying as a C2PC under the same ICID but chosen to be a new one). There was a discussion around Class 2 Permissive Changes (C2PC) and that they generally don’t require an inquiry for permission.
- RSS 248 C4PC Applications: explanation regarding the relaxation for C4PC applications for modules subject to RSS 248 integrated into host devices. Instead of requiring a C4PC for every host, one C4PC can cover a complete device class under RSS 248, provided all hosts within that class meet the specific requirements, and integration instructions are clear.
- Field Reference Levels (FRL) and Scope of Recognition: clarification that no recognition is required for testing labs to perform simple calculations to determine compliance with FRL. Provided a lab is recognized for the relevant RSS (non-RSS-102) of the device under test, no additional scope is needed for reports using FRL calculations. In the rare case where FRL measurements are used, RSS-102 issue 6 scope will suffice until RSS-102.FRL is published.
- Technical Standards Updates and Consultations: recently changed standards like RSS 222 (Whitespace Devices) and RSS 248 (6 GHz band including VLP-LAN). ISED shared information on ongoing consultations for RSS-102.SAR.MEAS/SIM, RSS-247 Issue 4, RSS-193 Issue 1 (mmWave), and RSS-102.IPD.MEAS/SIM. The importance of providing feedback during consultations was strongly emphasized.
- Adopted International Standards: announcement of the adoption of ANSI C63.2-2023 and ANSI C63.10a-2024 as normative reference standards.
- No Grandfathering and KDB Usage (Reminders): The policy of no grandfathering of equipment when new issues of standards are published was reiterated. This also applies to international standards incorporated by reference. ISED also commented on list of accepted FCC KDBs and the requirement to highlight their use in the technical brief. Prior consultation with ISED is required for KDBs not on the accepted list.
- Actions Against Non-Compliant Labs: announcement that ISED is taking more concrete steps, including potential suspensions, against labs performing lower quality work or engaging in fraudulent data reuse.
- Common Measurement Errors and Application Issues: A detailed presentation covered common issues leading to passbacks, including missing or incomplete documentation, inconsistencies, errors in test plots (especially RF alignment), missing correction factors, improper handling of duty cycle, use of non-accepted KDBs, RF exposure measurement errors (using outdated standards, incorrect dielectric scaling, not evaluating all edges), and nerve stimulation assessment errors.
- TAS Algorithm Usage: The requirement to meet all requirements of RSS 102 for certification filings, regardless of when a TAS algorithm was approved, was highlighted.
- ISED Spectrum Allocation Tool (SPAT): introduction and a live demonstration of the new ISED Spectrum Allocation Tool, designed to provide streamlined access to rules and regulations governing spectrum use and the relationship between policy documents and technical standards. The tool allows users to filter by service, frequency band, and document type, and includes a keyword search of all standards.
In essence, attending the workshop provided valuable real-time updates, in-depth explanations, opportunities for clarification through questions, and a first look at new tools and policy directions from ISED. From updates on cybersecurity labeling for IoT devices to changes in data referencing and RF exposure guidelines, the FCC provided crucial insights into the evolving regulatory landscape.
FCC Updates
1. IoT Cyber Labeling
The FCC adopted a Report and Order (R&O) on March 15, 2024, establishing a voluntary cybersecurity labeling program for wireless consumer Internet of Things (IoT) products. The FCC will act as the program owner and set the requirements for products to qualify for the FCC IoT Label. This label will inform consumers that the product meets minimum cybersecurity standards.
The FCC’s Public Safety and Homeland Security Bureau (PSHSB) is collaborating with Cybersecurity Label Administrators (CLAs) and other stakeholders to develop the program details. UL Solutions has been selected as the lead administrator. UL has also reviewed applications from entities interested in participating in the stakeholder process and established three committees to develop recommendations on:
- Technical Standards and Testing Procedures
- Label Design (size, placement on product/packaging, and online label via QR code)
- Post Market Surveillance and Certification Renewal
PSHSB will consider UL’s recommendations and issue Public Notices seeking comment. The PSHSB will then review the record and adopt recommendations, including standards and testing procedures, into the FCC’s rules. PSHSB will also work with accrediting bodies to establish the FCC scope of accreditation for CLAs and CyberLABs (test labs). CLAs and CyberLABs will need to obtain accreditation to ISO standards 17065 and 17025, respectively, and the FCC scope.
Manufacturers will have their products tested by recognized CyberLABs and then submit applications to CLAs, who will review the application and test reports to approve or deny the use of the FCC label. The program is currently focused on consumer wireless products and excludes categories regulated by other agencies, such as medical devices and motor vehicles. The FCC is also considering international reciprocal recognition of cyber standards and labels, including discussions with the EU regarding programs like the CRA.
2. Administrative Notes and Publication Update
Jim Szeliga from the Laboratory Division, Office of Engineering and Technology, provided updates on recent FCC publications. Key publications highlighted include:
- 996369 D01 Module Certification Guide v04r02 (11/15/2024): Corrects errors without changing interpretations or guidance.
- 935210 D02 Signal Boosters Certification v04r03 (11/20/2024): Removed Part 96 EUD provision.
- 206256 D01 Wireless Microphone Certification v03 (12/09/2024): Added requirements for WMAS and removed some database access requirements.
- 511808 D01 C-V2X v02 (02/24/2025): Accounts for FCC 24-123A, related to new rules for Cellular Vehicle-to-Everything (C-V2X) devices. New equipment classes (CVR, CVO, CVG) were introduced, and older classes (ITO, ITR) were discontinued.
- 987594 D03 U-NII 6 GHz QA v03 (02/24/2025): Added question 21 for Building Entry Loss (BEL) by AFCs. An update mentioned the addition of the “BX” grant number for standard access points in the 6 GHz band used indoors, allowing configuration for more power based on building loss.
- 484596 D01 Referencing Test Data v03 (03/21/2025): Underwent a major restructuring and is now assigned directly to the TCB, no longer requiring an ECR inquiry. Data referencing is now limited to component removal (depopulation only).
- 484596: This publication regarding data referencing will be covered in more detail in a subsequent presentation by Alfonso Tarditi.
- 484596 v03: Each variant must correspond to an FCC ID, and data referencing is only for new FCC IDs, not different models or SKUs under the same ID. The review of data referencing proposals is now fully performed by the TCB.
The presentation also provided statistics on the number of inquiries received by the Laboratory Division in 2024 (over 5700) and categorized them. An explanation of Persistent Inquiry Acceptance (PIA) exhibits required for Standard Access Points in the 6 GHz band was given, emphasizing the need for a clear narrative in the justification report describing the geolocation method and the establishment of the 95% confidence area. Requirements for OBU Geofencing in the 6 GHz band were also outlined, including the need for a narrative describing the geofencing mechanism and ensuring the GNSS system uses only U.S. licensed or approved satellites. Updates on Wireless Handset Hearing Aid Compatibility (HAC) requirements based on Report and Order FCC 24-112 were provided, noting the transition to ANSI C63.19-2019 compliance.
3. Data Referencing
Alfonso Tarditi presented on the revision of KDB 484596 D01 “Referencing Test Data” v03. The main changes include a major restructuring, with data referencing now limited to component removal (depopulation only). ECR inquiries are no longer required for data referencing proposals, and the review is fully performed by the TCB. Data referencing is only for new FCC IDs, not for different models or SKUs under the same ID. The parent device must be the fully populated version. Each variant must correspond to a separate FCC ID. The exhibits in TCB filings must clearly differentiate referenced data from new testing, and data referencing is only permitted for devices under the same Grantee code.
Several examples of acceptable and non-acceptable variants were discussed, with emphasis on depopulation being the key criterion. The importance of clear documentation for data referencing to facilitate review by TCBs and the FCC for market surveillance was highlighted. The KDB provides details on the steps required for TCBs to file an application using data referencing. A transition period for the new version (v03, published 03/21/2025) was mentioned, allowing its immediate use. However, using the older procedure (v02r03) still requires ECR KDB inquiries.
Discussions during the Q&A session clarified that this new data referencing KDB is specifically for depopulation scenarios and does not cover all instances of data reuse, such as permissive changes or changes in FCC ID with host-level modules.
4. Wireless Power Transfer (WPT)
A presentation covered clarifications on the applicability of KDB 680106 regarding RF exposure considerations for all RF devices, not just WPT devices, especially those operating below 4 MHz or with RF exposure limits below 100 kHz. It also addressed the validation of field estimations for WPT devices, recommending validation points be relatively close to the device under test (DUT). The concept of collocated devices, particularly wireless battery packs charging phones, was discussed, emphasizing that each device is evaluated independently in its intended operating environment without superimposing fields from other devices not being tested. The authorization of WPT devices under Part 15 and Part 18 was also covered, noting that Part 15 authorization for WPT at a distance has always been allowed without special concerns. Certain low-power WPT devices meeting specific conditions in the KDB can skip the ECR process.
5. EMC Updates
Dusmantha Tennakoon provided updates related to EMC. Key topics included:
- C-V2X: KDB publication 511808 D01 v02 was updated for new certification rules, with new equipment classes CVR, CVO, and CVG, and the discontinuation of ITO and ITR. The waiver order for LTE-based C-V2X devices has been terminated as of February 11, 2025, and all DSRC equipment must be sunset by December 14, 2026. Requirements for OBU geo-fencing certification were outlined.
- mmWave Devices under Part 30: Report & Order FCC 24-124 became effective on January 13, 2025, and KDB 842590 D01 was updated with tighter out-of-band emission (OOBE) limits in the 23.6-24 GHz region for devices operating in the 24 GHz band, with phase-in deadlines for meeting these limits.
- Wireless Microphones (Part 15/74): R&O FCC 24-22 allows Wireless Multichannel Audio Systems (WMAS) in broadcast bands on a licensed basis. KDB 206256 was updated, and grant note 08 should be used.
- Consumer Signal Boosters: Boosters operating in the 2.3 GHz band (LTE Band 30/5GNR n30) are prohibited.
- Contention Based Protocol (CBP): For measuring the power of the AWGN signal, method SA-1 in section 12.4.2.2 of C63.10:2020 should be used.
- Portable Earth-Station Transceivers (Part 25): Applicants must show devices are designed for use with satellite systems lawfully providing service in the U.S., such as GPS and Galileo.
6. Post Market Surveillance
Dusmantha Tennakoon also presented on TCB surveillance activities. The number of equipment authorizations continues to increase. An overview of 2024 surveillance data was provided, noting the number of grants, TCB participation, and instances where TCBs did not meet requirements, often due to incorrectly calculating the number of samples tested. Observations included the overall increase in authorizations and common errors in TCB surveillance summaries, particularly regarding the number of applications tested for EMC. The OET lab is increasing desk audits and continuing post-market surveillance testing in EMC, RF Exposure, and HAC, while also acquiring new testing capabilities. TCBs are expected to notify grantees about the requirement for production samples for surveillance testing and should use the sample selection criteria in KDB 6100077 D01. Obtaining production samples (not lab samples) for testing is crucial, and TCBs should explore methods like requesting vouchers or purchasing from the marketplace. Post-market surveillance testing by FCC-recognized labs can be done in countries with Mutual Recognition Agreements (MRAs).
7. RF Exposure PAG Updates
Alfonso Tarditi discussed updates to RF Exposure PAG items.
- ANTTUN PAG Item: The procedure to test antenna auto-tune has been simplified. For a device with ‘n’ states, if the autotuner selects state ‘k’, SAR should be measured at states ‘k-1’, ‘k’, and ‘k+1’. The SAR at the autotuned state (‘k’) should be higher than the adjacent states to confirm proper function. A single-point measurement on the chosen and adjacent states is used for verification, ensuring the SAR is highest at the autotuned state within expected tolerances.
- PHANTM PAG Item: A new procedure simplifies the introduction of non-standard phantoms for SAR evaluations. Non-standard phantoms can be authorized via a KDB Inquiry under the Persistent Inquiry Approval (PIA) procedure, avoiding the need for a Phantom PAG for each application using the approved phantom. A PIA needs to demonstrate that the probe system can reliably measure in the non-standard phantom and can be referenced in future applications. This PIA is a KDB inquiry (ECR subcategory ECR PIA) and not a PG submitted to the TCB.
8. Interim Simplified RFX Guidance for Portable Devices
Alfonso Tarditi presented interim simplified guidance for RF exposure testing of portable devices under §2.1093, intended as an alternative to some content in KDB publications 447498, 616217, and 648474. Key changes include:
- Body exposure for all devices (including laptops/tablets) tested at distances not to exceed 5 mm, unless an “on-body” holder is available and shown in grant exhibits.
- Filed grant exhibits must identify and show the holder, with a descriptive statement in the grant comments. User documentation must state that FCC compliance testing was done with that holder and provide the separation distance.
- Other exposure conditions like “hotspot” mode (1-g SAR at 10 mm) and head exposure (1-g SAR at contact) remain.
This guidance aims to ensure consistency across various portable devices while minimally deviating from current procedures.
9. Review of TCB PAG Submissions
Len Knight reviewed common issues found in tagged or untagged PAG submissions. Key points included:
Dynamic Time Averaging (TAS) Mechanisms: For devices employing TAS, a complete, detailed, and substantial description of the mechanism is required in the operational description to validate the SAR test report.
UN6GHz Test Reduction: Guidance on test reduction for partial RUs and full RUs is available in previous TCB workshop presentations. Due to the large bandwidth, PSD measurements of partial RUs in one part of the band may not represent another part. Clear documentation of test reduction methods, including supporting plots for power spectral density, is needed.
UN6GHz In-Band Emissions Mask: The measurement method is in section J of KDB 987594 D02. For larger bandwidths and partial RUs, compliance is hard to determine by “eyeballing” plots; using a spectrum analyzer with a Pass/Fail function is preferred.
Contention Based Protocol (CBP): The CBP section of the test report must clearly state if channel puncturing or bandwidth reduction is used for incumbent avoidance (channel puncturing should be for network optimization, not incumbent avoidance).
Channel Prioritization: For VLP devices in the 6 GHz band, the operational description must detail how the device prioritizes frequencies above 6105 GHz. Simply stating the chipset has built-in prioritization is insufficient.
General Concerns (RBW/VBW): Software capture programs should display resolution bandwidth (RBW) and video bandwidth (VBW) as these are vital for confirming measurement procedures. These values should be readily available near the plots.
Power and PSD EIRP Tables: For UN6GHz devices with EIRP limits, tabular summaries should include both power and antenna gain. For MIMO devices, values from all chains and a summation should be included.
Modular Approval Cover Letter: A brief, clear description of each modular requirement, whether it is met, and how, is necessary. If the module grantee is not the manufacturer of the end product, this must be clearly stated in the cover letter and user manual. A sensor test plan should be included, even if the module grantee and end product manufacturer are the same.