Re: [PSES] Frequency range & transitted power for RED

[Scott Xe]

Dear Michael,

 

Thanks for your useful example of WiFi devices!  The permissible limit is 20 
dBm or 100 mW.  Where can we find it for different type of products?

 

Can you shed light why <20 dBm is considered useless.  That is the design to 
allow for this type of products.  Each designer can fully utilise the allowable 
power for optimising the performance of the product.

 

I agree on rated power for each product to be quoted.  Did you mean the 
tolerance +/- 1 dB is subject to the upper limit and lower limit of mass 
production.  Each product may vary depending on the complexity of the product.

 

What are about Bluetooth devices?  I have learnt the permissible limit is 13 
dBm or 20 mW but did not find the reference.  However I read a test report of 
EN 62479 on a Bluetooth speaker.  It was measured max E.I.R.P. = -7.9 dBm or 
0.16 mW in 2.4 GHz.  The manual and the RED compliance cert are stated <20 dBm. 
 It seems not right, isn’t it?  If the limit is used in mass production, the 
devices may be faulty and still fall into the limit.

 

For frequency range, did the compliance test verify it?  If so, where I can 
find the test result so I can put appropriate statement on manual accordingly.

 

Thanks and regards,

 

Scott

 

 

From: Michael Derby 
Date: Tuesday, 18 April 2017 at 6:22 PM
To: 'Scott Xe' , 
Subject: RE: [PSES] Frequency range & transitted power for RED

 

Hi Scott,

 

The most common, and most recent, guidance is that the user manual should list 
the rated power of the product.

 

For example, let’s say you have a WiFi device in the 2.4 GHz band, and the 
power (e.i.r.p.) is rated at 14 dBm +/- 1 dB..

Let’s say that you measure 13.8 dBm e.i.r.p. in the test lab.

We know the limit in the standard is 20 dBm.

 

It would not be necessary to state 13.8 dBm exactly.   That value only applies 
to the one unit you tested, and of course it means you cannot plan your user 
manual until you tested!

 

Similarly, it would be rather useless to state “<20 dBm” in the user manual; 
because of course we all know that.

 

The user manual should therefore state:   14 dBm, +/- 1 dB.   (the rated power)

 

You can use common terms, like GSM 900, or LTE Band 1.   But be careful with 
some things, like “5 GHz WLAN” because that would not be specific enough…. 
Because there are so many 5 GHz WLAN bands (some of which are permitted in the 
EU and some are not)

 

I am not sure I understand the second part of your question:

“With a compliance report, where do we check if they fall into the permissible 
limits?”

 

Are you testing to the standards?   Or are you checking the accuracy of the 
user manual statements?

 

 

Michael.

 

 

Michael Derby 

Senior Regulatory Engineer 

Director 

ACB Europe 

 

Certification Resource for the Wireless Industry 

Web:   www.acbcert.com 

  

e-mail:micha...@acbcert.com 

Mobile phone:   (+44) 7939 880829   (UK area code) 

Corporate office phone: USA:   (+1) 703 847 4700 

 

 

 

 

 

 

 

From: Scott Xe [mailto:scott...@gmail.com] 
Sent: 17 April 2017 10:27
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Frequency range & transitted power for RED

 

In user manual, it is required to give the info on frequency range & 
transmitted power.  What is the right info to give there?  With a compliance 
report, where do we check if they fall into the permissible limits?  The 
products are Bluetooth speakers and keyboard/mouse with a RF dongle.

 

Thanks and regards,

 

Scott

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Re: [PSES] Frequency range & transitted power for RED

[Scott Xe]

Dear Charlie,

 

Appreciate your guidance but I need more specific details to follow.  Pls see 
further queries in inline message below.

 

Thanks and regards,

 

Scott

 

From: Charlie Blackham 
Date: Tuesday, 18 April 2017 at 4:57 PM
To: Scott Xe , "EMC-PSTC@LISTSERV.IEEE.ORG" 

Subject: RE: Frequency range & transitted power for RED

 

Scott

 

Current (final draft) guide says:

 

Manufacturers have different alternatives to fulfil these requirements. For 
example, any of the following options could be added to the instructions:

· the nominal frequency and transmitted power (radiated and/or 
conducted) used by the radio equipment, as reflected in the Technical 
Documentation (where I can find the permissible limits to comply with), or

· for radio equipment using standardized technologies, e.g. GSM/3G/LTE, 
indication of the frequency band in the way they are commonly well-known (such 
as GSM 900, 1800). Where different power levels are possible, the nominal 
maximum power would be stated (For Bluetooth devices and RF devices running at 
2.4 GHz what is the permission limits?).

 

Regards

Charlie

 

Charlie Blackham

Sulis Consultants Ltd

Tel: +44 (0)7946 624317

Web: www.sulisconsultants.com

Registered in England and Wales, number 05466247

 

From: Scott Xe [mailto:scott...@gmail.com] 
Sent: 17 April 2017 10:27
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Frequency range & transitted power for RED

 

In user manual, it is required to give the info on frequency range & 
transmitted power.  What is the right info to give there?  With a compliance 
report, where do we check if they fall into the permissible limits?  The 
products are Bluetooth speakers and keyboard/mouse with a RF dongle.

 

Thanks and regards,

 

Scott

-


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Re: [PSES] Frequency range & transitted power for RED

[Charlie Blackham]

Scott

Current (final draft) guide says:

Manufacturers have different alternatives to fulfil these requirements. For 
example, any of the following options could be added to the instructions:
·the nominal frequency and transmitted power (radiated and/or 
conducted) used by the radio equipment, as reflected in the Technical 
Documentation, or
·for radio equipment using standardized technologies, e.g. GSM/3G/LTE, 
indication of the frequency band in the way they are commonly well-known (such 
as GSM 900, 1800). Where different power levels are possible, the nominal 
maximum power would be stated.

Regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: 
www.sulisconsultants.com
Registered in England and Wales, number 05466247

From: Scott Xe [mailto:scott...@gmail.com]
Sent: 17 April 2017 10:27
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Frequency range & transitted power for RED

In user manual, it is required to give the info on frequency range & 
transmitted power.  What is the right info to give there?  With a compliance 
report, where do we check if they fall into the permissible limits?  The 
products are Bluetooth speakers and keyboard/mouse with a RF dongle.

Thanks and regards,

Scott
-


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Re: [PSES] Frequency range & transitted power for RED

[Michael Derby]

Hi Scott,

 

The most common, and most recent, guidance is that the user manual should list 
the rated power of the product.

 

For example, let’s say you have a WiFi device in the 2.4 GHz band, and the 
power (e.i.r.p.) is rated at 14 dBm +/- 1 dB..

Let’s say that you measure 13.8 dBm e.i.r.p. in the test lab.

We know the limit in the standard is 20 dBm.

 

It would not be necessary to state 13.8 dBm exactly.   That value only applies 
to the one unit you tested, and of course it means you cannot plan your user 
manual until you tested!

 

Similarly, it would be rather useless to state “<20 dBm” in the user manual; 
because of course we all know that.

 

The user manual should therefore state:   14 dBm, +/- 1 dB.   (the rated power)

 

You can use common terms, like GSM 900, or LTE Band 1.   But be careful with 
some things, like “5 GHz WLAN” because that would not be specific enough…. 
Because there are so many 5 GHz WLAN bands (some of which are permitted in the 
EU and some are not)

 

I am not sure I understand the second part of your question:

“With a compliance report, where do we check if they fall into the permissible 
limits?”

 

Are you testing to the standards?   Or are you checking the accuracy of the 
user manual statements?

 

 

Michael.

 

 

Michael Derby 

Senior Regulatory Engineer 

Director 

ACB Europe 

 

Certification Resource for the Wireless Industry 

Web:   www.acbcert.com   

  

e-mail:  micha...@acbcert.com 

Mobile phone:   (+44) 7939 880829   (UK area code) 

Corporate office phone: USA:   (+1) 703 847 4700 

 

 

 

 

 

 

 

From: Scott Xe [mailto:scott...@gmail.com] 
Sent: 17 April 2017 10:27
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Frequency range & transitted power for RED

 

In user manual, it is required to give the info on frequency range & 
transmitted power.  What is the right info to give there?  With a compliance 
report, where do we check if they fall into the permissible limits?  The 
products are Bluetooth speakers and keyboard/mouse with a RF dongle.

 

Thanks and regards,

 

Scott

-


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Re: [PSES] RED, "Radio Equipment" and USB Dongle and the like

[Michael Derby]

Hi Mike,

 

I have added comments in red text below…

 

Michael.

 

 

Michael Derby 

Senior Regulatory Engineer 

Director 

ACB Europe 

 

Certification Resource for the Wireless Industry 

Web:   www.acbcert.com   

  

 

 

From: Mike Sherman - Original Message - [mailto:msherma...@comcast.net] 
Sent: 17 April 2017 03:02
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] RED, "Radio Equipment" and USB Dongle and the like

 

Esteemed colleagues:

I'm trying to map the boundaries of "radio equipment" under RED by examples. Do 
you agree with the following two examples?

 

EXAMPLE 1: USB Dongle

I use a USB dongle to add WiFi to an old laptop. The dongle is the radio 
equipment, but the laptop was not and does not become one by the addition of 
this dongle.

MD:  Correct.   The USB dongle is not installed within the laptop, and it is 
easily removed from the laptop.   The Dongle is the Radio (RED) product and the 
laptop is the non-radio (EMCD+LVD) device.

 

EXAMPLE 2: SD Card Format WiFi

I use a WiFi card in the form factor of an SD card to add WiFi picture 
transmission to an old digital camera. The WiFi card is radio equipment, but 
the camera was not and does not become one by the addition of this card.

MD:  This would depend on the installation of that card.   If the WiFi card is 
easily removed from the camera (such as with a card slot and easy access), then 
I think you are correct.

However, if the WiFi card is incorporated into the camera and permanently fixed 
within it (such that it might need tools to remove it); then the camera becomes 
a radio.

 

 

Thanks,

 

Michael.

 

 

thanks to all,

Mike Sherman

Graco Inc.

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