Re: [PSES] NFC (near field communication): FCC Approach?
Probably worth noting that a lot of RFID is not NFC and operates at much higher frequencies (915+ MHz). Brent DeWitt Milford, MA From: Michael Derby [mailto:micha...@acbcert.com] Sent: Monday, October 22, 2018 5:46 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] NFC (near field communication): FCC Approach? Correct! A*. RED applies to 13.56 MHz NFC (RFID). EN 300 330, EN 301 489-3, and the most applicable safety standard for your device. Under the old R, NFC did have a dedicated standard (I think it was EN 302 291), but that standard did not proceed to RED, and now NFC is incorporated into EN 300 330. Michael. Michael Derby Senior Regulatory Engineer Director ACB Europe Certification Resource for the Wireless Industry Web: www.acbcert.com <http://www.acbcert.com/> e-mail: <mailto:micha...@acbcert.com> micha...@acbcert.com Mobile phone: (+44) 7939 880829 (UK area code) Corporate office phone: USA: (+1) 703 847 4700 From: MIKE SHERMAN [mailto:msherma...@comcast.net] Sent: 22 October 2018 21:51 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] NFC (near field communication): FCC Approach? Thanks to all for the quick education! Now, follow up question: RED. Seems to me that this does use RF to communicate, so it seems to fall into scope of RED. Agree? Disagree? thanks, Mike Re: [PSES] NFC (near field communication): FCC Approach?On October 20, 2018 at 2:40 AM Michael Derby wrote: I agree with Michael that this needs to be tested and authorised (certified) to FCC 15.225. Another Michael. From: Heckrotte, Michael [mailto:michael.heckro...@ul.com] Sent: 20 October 2018 04:00 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] NFC (near field communication): FCC Approach? Digital devices that have a power consumption not exceeding 6 nW are exempt from specific technical standards per FCC Rules 15.103(f). There are no such exemptions for intentional radiators. See FCC Rules 15.225 for radiated emission limits applicable to radio devices operating on 13.56 MHz. Best Regards, Mike From: Ken Javor Sent: Friday, October 19, 2018 5:54 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] NFC (near field communication): FCC Approach? I don’t know what the FCC rules are on something like this – others on this forum are much better informed on that topic - but if the ERP is 0 dBm (1 mW), then at three meters away the field intensity would be 58 mV/m, or 95 dBuV/m. Now this is at 13.56 MHz, where there is no FCC RE limit. But the FCC Class B three meter limit at 30 MHz is something like 40 dBuV/m (someone jump in if I got this wrong) so that means the third harmonic must be 55 dB down from the fundamental. That is certainly doable, but I wouldn’t take it for granted without some sort of verification. Ken Javor Phone: (256) 650-5261 _ From: MIKE SHERMAN Reply-To: MIKE SHERMAN Date: Fri, 19 Oct 2018 17:22:50 -0500 To: Subject: [PSES] NFC (near field communication): FCC Approach? Esteemed fellow listers -- I'm looking at a very low power, intermittent NFC card reader/writer. Alkaline battery operated device. NFC is only energized for 10 seconds at a time on demand, and range to read/write is less than 1 cm from the surface of the device. I'm not an EE, but my simplified thought process is: "I can barely get this to couple magnetically with a card sitting on its surface. How could I possibly interfere with broadcast services or other equipment?" So, oh wise ones, from your experience what actions with respect to FCC are reasonable to do? For example, radiated emissions testing seems to me like a total waste of time and money. More technical details: maximum input power to the NFC chip is 17 mW. Chip is coupled to a flat 30mm x 40mm "NFC Ferrite Antenna (13.56 MHz)" that my EE describes as "zero gain." We're rating RF output as 0 mW (i.e., rounding off, it's a lot closer to 0 mW than to 1 mW). Looking forward once again to interesting wisdom from this group. Mike Sherman Graco Inc. - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) <http://www.ieee-pses.org/list.html> <http://www.ieee-pses.org/list.html> List rules: http://www.ieee-pses.org/listrules.html
Re: [PSES] NFC (near field communication): FCC Approach?
Correct! A*. RED applies to 13.56 MHz NFC (RFID). EN 300 330, EN 301 489-3, and the most applicable safety standard for your device. Under the old R, NFC did have a dedicated standard (I think it was EN 302 291), but that standard did not proceed to RED, and now NFC is incorporated into EN 300 330. Michael. Michael Derby Senior Regulatory Engineer Director ACB Europe Certification Resource for the Wireless Industry Web: www.acbcert.com <http://www.acbcert.com/> e-mail: <mailto:micha...@acbcert.com> micha...@acbcert.com Mobile phone: (+44) 7939 880829 (UK area code) Corporate office phone: USA: (+1) 703 847 4700 From: MIKE SHERMAN [mailto:msherma...@comcast.net] Sent: 22 October 2018 21:51 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] NFC (near field communication): FCC Approach? Thanks to all for the quick education! Now, follow up question: RED. Seems to me that this does use RF to communicate, so it seems to fall into scope of RED. Agree? Disagree? thanks, Mike Re: [PSES] NFC (near field communication): FCC Approach?On October 20, 2018 at 2:40 AM Michael Derby mailto:micha...@acbcert.com> > wrote: I agree with Michael that this needs to be tested and authorised (certified) to FCC 15.225. Another Michael. From: Heckrotte, Michael [mailto:michael.heckro...@ul.com] Sent: 20 October 2018 04:00 To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> Subject: Re: [PSES] NFC (near field communication): FCC Approach? Digital devices that have a power consumption not exceeding 6 nW are exempt from specific technical standards per FCC Rules 15.103(f). There are no such exemptions for intentional radiators. See FCC Rules 15.225 for radiated emission limits applicable to radio devices operating on 13.56 MHz. Best Regards, Mike From: Ken Javor mailto:ken.ja...@emccompliance.com> > Sent: Friday, October 19, 2018 5:54 PM To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> Subject: Re: [PSES] NFC (near field communication): FCC Approach? I don’t know what the FCC rules are on something like this – others on this forum are much better informed on that topic - but if the ERP is 0 dBm (1 mW), then at three meters away the field intensity would be 58 mV/m, or 95 dBuV/m. Now this is at 13.56 MHz, where there is no FCC RE limit. But the FCC Class B three meter limit at 30 MHz is something like 40 dBuV/m (someone jump in if I got this wrong) so that means the third harmonic must be 55 dB down from the fundamental. That is certainly doable, but I wouldn’t take it for granted without some sort of verification. Ken Javor Phone: (256) 650-5261 _ From: MIKE SHERMAN mailto:msherma...@comcast.net> > Reply-To: MIKE SHERMAN mailto:msherma...@comcast.net> > Date: Fri, 19 Oct 2018 17:22:50 -0500 To: mailto:EMC-PSTC@LISTSERV.IEEE.ORG> > Subject: [PSES] NFC (near field communication): FCC Approach? Esteemed fellow listers -- I'm looking at a very low power, intermittent NFC card reader/writer. Alkaline battery operated device. NFC is only energized for 10 seconds at a time on demand, and range to read/write is less than 1 cm from the surface of the device. I'm not an EE, but my simplified thought process is: "I can barely get this to couple magnetically with a card sitting on its surface. How could I possibly interfere with broadcast services or other equipment?" So, oh wise ones, from your experience what actions with respect to FCC are reasonable to do? For example, radiated emissions testing seems to me like a total waste of time and money. More technical details: maximum input power to the NFC chip is 17 mW. Chip is coupled to a flat 30mm x 40mm "NFC Ferrite Antenna (13.56 MHz)" that my EE describes as "zero gain." We're rating RF output as 0 mW (i.e., rounding off, it's a lot closer to 0 mW than to 1 mW). Looking forward once again to interesting wisdom from this group. Mike Sherman Graco Inc. - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to mailto:emc-p...@ieee.org> > All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) <http://www.ieee-pses.org/list.html> <http://www.ieee-pses.org/list.html> List rules: http://www.ieee-pses.org/listrules.html For help, send
Re: [PSES] NFC (near field communication): FCC Approach?
Thanks to all for the quick education! Now, follow up question: RED. Seems to me that this does use RF to communicate, so it seems to fall into scope of RED. Agree? Disagree? thanks, Mike > Re: [PSES] NFC (near field communication): FCC Approach?On October 20, 2018 > at 2:40 AM Michael Derby wrote: > > > I agree with Michael that this needs to be tested and authorised > (certified) to FCC 15.225. > > > > > > Another Michael. > > > > > > > > > > From: Heckrotte, Michael [mailto:michael.heckro...@ul.com] > Sent: 20 October 2018 04:00 > To: EMC-PSTC@LISTSERV.IEEE.ORG > Subject: Re: [PSES] NFC (near field communication): FCC Approach? > > > > Digital devices that have a power consumption not exceeding 6 nW are > exempt from specific technical standards per FCC Rules 15.103(f). > > > > There are no such exemptions for intentional radiators. See FCC Rules > 15.225 for radiated emission limits applicable to radio devices operating on > 13.56 MHz. > > > > > > Best Regards, > > Mike > > > > From: Ken Javor mailto:ken.ja...@emccompliance.com > > Sent: Friday, October 19, 2018 5:54 PM > To: EMC-PSTC@LISTSERV.IEEE.ORG mailto:EMC-PSTC@LISTSERV.IEEE.ORG > Subject: Re: [PSES] NFC (near field communication): FCC Approach? > > > > I don’t know what the FCC rules are on something like this – others on > this forum are much better informed on that topic - but if the ERP is 0 dBm > (1 mW), then at three meters away the field intensity would be 58 mV/m, or 95 > dBuV/m. Now this is at 13.56 MHz, where there is no FCC RE limit. But the > FCC Class B three meter limit at 30 MHz is something like 40 dBuV/m (someone > jump in if I got this wrong) so that means the third harmonic must be 55 dB > down from the fundamental. That is certainly doable, but I wouldn’t take it > for granted without some sort of verification. > > Ken Javor > Phone: (256) 650-5261 > > > > - > > From: MIKE SHERMAN mailto:msherma...@comcast.net > > Reply-To: MIKE SHERMAN mailto:msherma...@comcast.net > > Date: Fri, 19 Oct 2018 17:22:50 -0500 > To: mailto:EMC-PSTC@LISTSERV.IEEE.ORG > > Subject: [PSES] NFC (near field communication): FCC Approach? > > Esteemed fellow listers -- > > > > I'm looking at a very low power, intermittent NFC card reader/writer. > Alkaline battery operated device. NFC is only energized for 10 seconds at a > time on demand, and range to read/write is less than 1 cm from the surface of > the device. > > > > I'm not an EE, but my simplified thought process is: "I can barely get > this to couple magnetically with a card sitting on its surface. How could I > possibly interfere with broadcast services or other equipment?" > > > > So, oh wise ones, from your experience what actions with respect to FCC > are reasonable to do? For example, radiated emissions testing seems to me > like a total waste of time and money. > > > > More technical details: maximum input power to the NFC chip is 17 mW. > Chip is coupled to a flat 30mm x 40mm "NFC Ferrite Antenna (13.56 MHz)" that > my EE describes as "zero gain." We're rating RF output as 0 mW (i.e., > rounding off, it's a lot closer to 0 mW than to 1 mW). > > > > Looking forward once again to interesting wisdom from this group. > > > > Mike Sherman > > Graco Inc. > - > > > This message is from the IEEE Product Safety Engineering Society emc-pstc > discussion list. To post a message to the list, send your e-mail to > mailto:emc-p...@ieee.org > > > All emc-pstc postings are archived and searchable on the web at: > http://www.ieee-pses.org/emc-pstc.html > > Attachments are not permitted but the IEEE PSES Online Communities site > at http://product-compliance.oc.ieee.org/ can be used for graphics (in > well-used formats), large files, etc. > > Website: http://www.ieee-pses.org/ > Instructions: http://www.ieee-pses.org/list.html (including how to > unsubscribe) <http://www.ieee-pses.org/list.html> > http://www.ieee-pses.org/list.html > List rules: http://www.ieee-pses.org/listrules.html > > For help, send mail to the list administrators: > Scott Douglas mailto:sdoug...@ieee.org > > Mike Cantwell mailto:mc
Re: [PSES] NFC (near field communication): FCC Approach?
I agree with Michael that this needs to be tested and authorised (certified) to FCC 15.225. Another Michael. From: Heckrotte, Michael [mailto:michael.heckro...@ul.com] Sent: 20 October 2018 04:00 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] NFC (near field communication): FCC Approach? Digital devices that have a power consumption not exceeding 6 nW are exempt from specific technical standards per FCC Rules 15.103(f). There are no such exemptions for intentional radiators. See FCC Rules 15.225 for radiated emission limits applicable to radio devices operating on 13.56 MHz. Best Regards, Mike From: Ken Javor mailto:ken.ja...@emccompliance.com> > Sent: Friday, October 19, 2018 5:54 PM To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> Subject: Re: [PSES] NFC (near field communication): FCC Approach? I don't know what the FCC rules are on something like this - others on this forum are much better informed on that topic - but if the ERP is 0 dBm (1 mW), then at three meters away the field intensity would be 58 mV/m, or 95 dBuV/m. Now this is at 13.56 MHz, where there is no FCC RE limit. But the FCC Class B three meter limit at 30 MHz is something like 40 dBuV/m (someone jump in if I got this wrong) so that means the third harmonic must be 55 dB down from the fundamental. That is certainly doable, but I wouldn't take it for granted without some sort of verification. Ken Javor Phone: (256) 650-5261 _ From: MIKE SHERMAN mailto:msherma...@comcast.net> > Reply-To: MIKE SHERMAN mailto:msherma...@comcast.net> > Date: Fri, 19 Oct 2018 17:22:50 -0500 To: mailto:EMC-PSTC@LISTSERV.IEEE.ORG> > Subject: [PSES] NFC (near field communication): FCC Approach? Esteemed fellow listers -- I'm looking at a very low power, intermittent NFC card reader/writer. Alkaline battery operated device. NFC is only energized for 10 seconds at a time on demand, and range to read/write is less than 1 cm from the surface of the device. I'm not an EE, but my simplified thought process is: "I can barely get this to couple magnetically with a card sitting on its surface. How could I possibly interfere with broadcast services or other equipment?" So, oh wise ones, from your experience what actions with respect to FCC are reasonable to do? For example, radiated emissions testing seems to me like a total waste of time and money. More technical details: maximum input power to the NFC chip is 17 mW. Chip is coupled to a flat 30mm x 40mm "NFC Ferrite Antenna (13.56 MHz)" that my EE describes as "zero gain." We're rating RF output as 0 mW (i.e., rounding off, it's a lot closer to 0 mW than to 1 mW). Looking forward once again to interesting wisdom from this group. Mike Sherman Graco Inc. - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to mailto:emc-p...@ieee.org> > All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) <http://www.ieee-pses.org/list.html> <http://www.ieee-pses.org/list.html> List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas mailto:sdoug...@ieee.org> > Mike Cantwell mailto:mcantw...@ieee.org> > For policy questions, send mail to: Jim Bacher mailto:j.bac...@ieee.org> > David Heald mailto:dhe...@gmail.com> > - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to mailto:emc-p...@ieee.org> > All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) <http://www.ieee-pses.org/list.html> List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas mailto:sdoug...@ieee.org> > Mike Cantwell mailto:mcantw...@ieee.org> > For policy questions, send mail to: Jim Bacher mailto:j.bac...@ieee.org> > David Heald mailto:dhe...@gmail.com> > This e-mail may contain privileged or
Re: [PSES] NFC (near field communication): FCC Approach?
Hello Mike, The radiated emissions measurements I've made on NFC card readers and tags have been overwhelmingly quiet. Certainly no significant emissions from the intentional radiator part. The biggest contributor to any radiated emissions test was the system digital controller and emissions from USB or equivalent. Since the system is unlikely to exist in isolation you'll have to consider this part. Hope this helps James MIKE SHERMAN wrote >Esteemed fellow listers -- > > >I'm looking at a very low power, intermittent NFC card reader/writer. Alkaline >battery operated device. NFC is only energized for 10 seconds at a time on >demand, and range to read/write is less than 1 cm from the surface of the >device. > > >I'm not an EE, but my simplified thought process is: "I can barely get this to >couple magnetically with a card sitting on its surface. How could I possibly >interfere with broadcast services or other equipment?" > > >So, oh wise ones, from your experience what actions with respect to FCC are >reasonable to do? For example, radiated emissions testing seems to me like a >total waste of time and money. > > >More technical details: maximum input power to the NFC chip is 17 mW. Chip is >coupled to a flat 30mm x 40mm "NFC Ferrite Antenna (13.56 MHz)" that my EE >describes as "zero gain." We're rating RF output as 0 mW (i.e., rounding off, >it's a lot closer to 0 mW than to 1 mW). > > >Looking forward once again to interesting wisdom from this group. > > >Mike Sherman > >Graco Inc. > >- > >This message is from the IEEE Product Safety Engineering Society emc-pstc >discussion list. To post a message to the list, send your e-mail to > > >All emc-pstc postings are archived and searchable on the web at: >http://www.ieee-pses.org/emc-pstc.html > >Attachments are not permitted but the IEEE PSES Online Communities site at >http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used >formats), large files, etc. > >Website: http://www.ieee-pses.org/ >Instructions: http://www.ieee-pses.org/list.html (including how to >unsubscribe) >List rules: http://www.ieee-pses.org/listrules.html > >For help, send mail to the list administrators: >Scott Douglas >Mike Cantwell > >For policy questions, send mail to: >Jim Bacher: >David Heald: - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas Mike Cantwell For policy questions, send mail to: Jim Bacher: David Heald:
Re: [PSES] NFC (near field communication): FCC Approach?
I'm not smart enough to add to the topic, but I sense something not to be over looked: MIKE SHERMAN wrote: > I'm not an EE and > We're rating RF output as 0 mW (i.e., rounding off, it's a lot closer to 0 mW > than to 1 mW). and Heckrotte, Michael wrote: > Digital devices that have a power consumption not exceeding 6 nW are exempt > from specific technical standards per FCC Rules 15.103(f). Not to over looked is the disparity in unit. Thinking between 0 mW and 1 mW is in linear unit. However radio frequency emissions are usually expressed in logarithmic unit. The commonly encountered range of RF power expressed in logarithmic term is between -100 dBm to +60 dBm. In linear terms they are 10 nW to 1 kW. That's a huge range, and more specifically, there is a lot of difference between 0 mW and 1 mW. From what Michael wrote about, 6 nW is more about 160,000 times smaller than 1 mW and yet is not exempted. Heckrotte, Michael also wrote: > There are no such exemptions for intentional radiators. See FCC Rules 15.225 > for radiated emission limits applicable to radio devices operating on 13.56 MHz And an NFC device intentionally radiate RF energy in order to communicate wirelessly. Sincerely, Alfred Lee On October 19, 2018 3:22:50 PM PDT, MIKE SHERMAN wrote: >Esteemed fellow listers -- > > >I'm looking at a very low power, intermittent NFC card reader/writer. >Alkaline battery operated device. NFC is only energized for 10 seconds >at a time on demand, and range to read/write is less than 1 cm from the >surface of the device. > > >I'm not an EE, but my simplified thought process is: "I can barely get >this to couple magnetically with a card sitting on its surface. How >could I possibly interfere with broadcast services or other equipment?" > > >So, oh wise ones, from your experience what actions with respect to FCC >are reasonable to do? For example, radiated emissions testing seems to >me like a total waste of time and money. > > >More technical details: maximum input power to the NFC chip is 17 mW. >Chip is coupled to a flat 30mm x 40mm "NFC Ferrite Antenna (13.56 MHz)" >that my EE describes as "zero gain." We're rating RF output as 0 mW >(i.e., rounding off, it's a lot closer to 0 mW than to 1 mW). > > >Looking forward once again to interesting wisdom from this group. > > >Mike Sherman > >Graco Inc. > >- > >This message is from the IEEE Product Safety Engineering Society >emc-pstc discussion list. To post a message to the list, send your >e-mail to > >All emc-pstc postings are archived and searchable on the web at: >http://www.ieee-pses.org/emc-pstc.html > >Attachments are not permitted but the IEEE PSES Online Communities site >at http://product-compliance.oc.ieee.org/ can be used for graphics (in >well-used formats), large files, etc. > >Website: http://www.ieee-pses.org/ >Instructions: http://www.ieee-pses.org/list.html (including how to >unsubscribe) >List rules: http://www.ieee-pses.org/listrules.html > >For help, send mail to the list administrators: >Scott Douglas >Mike Cantwell > >For policy questions, send mail to: >Jim Bacher: >David Heald: -- Sent from my Android phone with K-9 Mail. Please excuse my brevity. - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas Mike Cantwell For policy questions, send mail to: Jim Bacher: David Heald:
Re: [PSES] NFC (near field communication): FCC Approach?
Digital devices that have a power consumption not exceeding 6 nW are exempt from specific technical standards per FCC Rules 15.103(f). There are no such exemptions for intentional radiators. See FCC Rules 15.225 for radiated emission limits applicable to radio devices operating on 13.56 MHz. Best Regards, Mike From: Ken Javor Sent: Friday, October 19, 2018 5:54 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] NFC (near field communication): FCC Approach? I don't know what the FCC rules are on something like this - others on this forum are much better informed on that topic - but if the ERP is 0 dBm (1 mW), then at three meters away the field intensity would be 58 mV/m, or 95 dBuV/m. Now this is at 13.56 MHz, where there is no FCC RE limit. But the FCC Class B three meter limit at 30 MHz is something like 40 dBuV/m (someone jump in if I got this wrong) so that means the third harmonic must be 55 dB down from the fundamental. That is certainly doable, but I wouldn't take it for granted without some sort of verification. Ken Javor Phone: (256) 650-5261 From: MIKE SHERMAN mailto:msherma...@comcast.net>> Reply-To: MIKE SHERMAN mailto:msherma...@comcast.net>> Date: Fri, 19 Oct 2018 17:22:50 -0500 To: mailto:EMC-PSTC@LISTSERV.IEEE.ORG>> Subject: [PSES] NFC (near field communication): FCC Approach? Esteemed fellow listers -- I'm looking at a very low power, intermittent NFC card reader/writer. Alkaline battery operated device. NFC is only energized for 10 seconds at a time on demand, and range to read/write is less than 1 cm from the surface of the device. I'm not an EE, but my simplified thought process is: "I can barely get this to couple magnetically with a card sitting on its surface. How could I possibly interfere with broadcast services or other equipment?" So, oh wise ones, from your experience what actions with respect to FCC are reasonable to do? For example, radiated emissions testing seems to me like a total waste of time and money. More technical details: maximum input power to the NFC chip is 17 mW. Chip is coupled to a flat 30mm x 40mm "NFC Ferrite Antenna (13.56 MHz)" that my EE describes as "zero gain." We're rating RF output as 0 mW (i.e., rounding off, it's a lot closer to 0 mW than to 1 mW). Looking forward once again to interesting wisdom from this group. Mike Sherman Graco Inc. - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to mailto:emc-p...@ieee.org>> All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) <http://www.ieee-pses.org/list.html><http://www.ieee-pses.org/list.html> List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas mailto:sdoug...@ieee.org>> Mike Cantwell mailto:mcantw...@ieee.org>> For policy questions, send mail to: Jim Bacher mailto:j.bac...@ieee.org>> David Heald mailto:dhe...@gmail.com>> - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to mailto:emc-p...@ieee.org>> All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe)<http://www.ieee-pses.org/list.html> List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas mailto:sdoug...@ieee.org>> Mike Cantwell mailto:mcantw...@ieee.org>> For policy questions, send mail to: Jim Bacher mailto:j.bac...@ieee.org>> David Heald mailto:dhe...@gmail.com>> This e-mail may contain privileged or confidential information. If you are not the intended recipient: (1) you may not disclose, use, distribute, copy or rely upon this message or attachment(s); and (2) please notify the sender by reply e-mail, and then delete this message and its attachment(s). Underwriters Laboratories Inc. and its affiliates disclaim all liability for any errors, omissions, corruption or virus in this message
Re: [PSES] NFC (near field communication): FCC Approach?
I don¹t know what the FCC rules are on something like this others on this forum are much better informed on that topic - but if the ERP is 0 dBm (1 mW), then at three meters away the field intensity would be 58 mV/m, or 95 dBuV/m. Now this is at 13.56 MHz, where there is no FCC RE limit. But the FCC Class B three meter limit at 30 MHz is something like 40 dBuV/m (someone jump in if I got this wrong) so that means the third harmonic must be 55 dB down from the fundamental. That is certainly doable, but I wouldn¹t take it for granted without some sort of verification. Ken Javor Phone: (256) 650-5261 From: MIKE SHERMAN Reply-To: MIKE SHERMAN Date: Fri, 19 Oct 2018 17:22:50 -0500 To: Subject: [PSES] NFC (near field communication): FCC Approach? Esteemed fellow listers -- I'm looking at a very low power, intermittent NFC card reader/writer. Alkaline battery operated device. NFC is only energized for 10 seconds at a time on demand, and range to read/write is less than 1 cm from the surface of the device. I'm not an EE, but my simplified thought process is: "I can barely get this to couple magnetically with a card sitting on its surface. How could I possibly interfere with broadcast services or other equipment?" So, oh wise ones, from your experience what actions with respect to FCC are reasonable to do? For example, radiated emissions testing seems to me like a total waste of time and money. More technical details: maximum input power to the NFC chip is 17 mW. Chip is coupled to a flat 30mm x 40mm "NFC Ferrite Antenna (13.56 MHz)" that my EE describes as "zero gain." We're rating RF output as 0 mW (i.e., rounding off, it's a lot closer to 0 mW than to 1 mW). Looking forward once again to interesting wisdom from this group. Mike Sherman Graco Inc. - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) <http://www.ieee-pses.org/list.html> List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas Mike Cantwell For policy questions, send mail to: Jim Bacher David Heald - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas Mike Cantwell For policy questions, send mail to: Jim Bacher: David Heald:
Re: [PSES] NFC (near field communication): FCC Approach?
Sounds similar to an electronic watch (not a smart watch), which is considered EMC-benign in Europe. John Woodgate OOO-Own Opinions Only J M Woodgate and Associates www.woodjohn.uk Rayleigh, Essex UK On 2018-10-19 23:22, MIKE SHERMAN wrote: Esteemed fellow listers -- I'm looking at a very low power, intermittent NFC card reader/writer. Alkaline battery operated device. NFC is only energized for 10 seconds at a time on demand, and range to read/write is less than 1 cm from the surface of the device. I'm not an EE, but my simplified thought process is: "I can barely get this to couple magnetically with a card sitting on its surface. How could I possibly interfere with broadcast services or other equipment?" So, oh wise ones, from your experience what actions with respect to FCC are reasonable to do? For example, radiated emissions testing seems to me like a total waste of time and money. More technical details: maximum input power to the NFC chip is 17 mW. Chip is coupled to a flat 30mm x 40mm "NFC Ferrite Antenna (13.56 MHz)" that my EE describes as "zero gain." We're rating RF output as 0 mW (i.e., rounding off, it's a lot closer to 0 mW than to 1 mW). Looking forward once again to interesting wisdom from this group. Mike Sherman Graco Inc. - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to mailto:emc-p...@ieee.org>> All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas mailto:sdoug...@ieee.org>> Mike Cantwell mailto:mcantw...@ieee.org>> For policy questions, send mail to: Jim Bacher mailto:j.bac...@ieee.org>> David Heald mailto:dhe...@gmail.com>> - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas Mike Cantwell For policy questions, send mail to: Jim Bacher: David Heald:
[PSES] NFC (near field communication): FCC Approach?
Esteemed fellow listers -- I'm looking at a very low power, intermittent NFC card reader/writer. Alkaline battery operated device. NFC is only energized for 10 seconds at a time on demand, and range to read/write is less than 1 cm from the surface of the device. I'm not an EE, but my simplified thought process is: "I can barely get this to couple magnetically with a card sitting on its surface. How could I possibly interfere with broadcast services or other equipment?" So, oh wise ones, from your experience what actions with respect to FCC are reasonable to do? For example, radiated emissions testing seems to me like a total waste of time and money. More technical details: maximum input power to the NFC chip is 17 mW. Chip is coupled to a flat 30mm x 40mm "NFC Ferrite Antenna (13.56 MHz)" that my EE describes as "zero gain." We're rating RF output as 0 mW (i.e., rounding off, it's a lot closer to 0 mW than to 1 mW). Looking forward once again to interesting wisdom from this group. Mike Sherman Graco Inc. - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas Mike Cantwell For policy questions, send mail to: Jim Bacher: David Heald: