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New requirements for data citation rules released by the FCC in the United States KDB 484596 D01



New requirements for data citation rules released by the FCC in the United States KDB 484596 D01

The FCC in the United States has issued a new requirement for data citation rules, KDB 484596 D01 Referencing Test Data v02. 484596 D01 Referencing Test Data v02 replaces 484596 D01 Referencing Test Data v01, providing guidance for referencing test data and allowing for referencing test data from test reports submitted in relevant equipment authorization applications. For similar devices with multiple model applications and differentiation, if EMC (RF) and RF exposure assessment data are cited to reduce testing volume, KDB inquiry consultation is required to obtain FCC authorization.



The updated content is as follows:

Update 1

Introducing extended clauses for EMC and RF exposure data referencing (incorporating guidelines previously provided in TCBC workshops (October 2020 and April 2021), Spot check data cannot exceed 25% compared to previous reference data.

Update 2

Based on the ECR KDB query program, new guidelines have been provided, and submitted ECR KDB reference data queries should meet the following standards:
When using ECR KDB inquiry, select "Equipment Compliance Review (ECR)" as the first category and "Data Reference" as the second category. Choosing incorrect categories will require correction, resulting in delayed processing.
Only assignees/applicants of the same Grantee Code can submit data reference ECR. Applicants can also choose to have testing laboratories, TCB, or other authorized agents submit ECRs on their behalf. Test data can only be referenced in applications under the same Grantee code. The selected product must be certified by the same assignee, or an ID change must be submitted to the same Grantee for the product in accordance with section 2.933.
After receiving a positive response from the FCC to the ECR inquiry (i.e. FCC "accepts"), the applicant can contact TCB and provide all the information required for the 731 form application (such as test data). This should be done for the product (if not yet certified) and variant devices.
The acceptance of ECR by the FCC does not imply recognition of the validity or accuracy of the provided data. This is just a technical proof that the variant device meets the data reference requirements.
A copy of the ECR KDB inquiry (indicating FCC acceptance) should be provided to TCB and uploaded along with the 731 form attachment as a supporting reason for the data reference process. If necessary, ECR queries can be uploaded as long-term confidential exhibits. TCB has the right to conduct a separate KDB investigation with the FCC to confirm the validity of ECR or any of its statements.
For requests for other variants, or to change the FCC ID for reference models certified by different assignees, a new, separate, and complete ECR is required. 


Update 3

Added examples to illustrate possible scenarios
7.1. Multi band Cellular Handset
Cellular phones (mobile phones) are certified to operate in multiple frequency bands within licensed commercial mobile radio service bands, such as part 22, part 24, part 25, and/or part 27 below 3GHz. The reference device has been certified for all bands, and the variant device will use a reduced set of bands. The variant device has the same components as the reference device, and frequency band reduction operations are implemented through software.
In this case, there is no need for a data reference process, as the testing on the reference device includes all bands, thus covering all possible use cases required for compliance demonstration. All phones usually have the same FCC ID, as the only difference is related to the software or firmware loaded.
If the frequency reduction function of a variant device is achieved by removing (i.e. removing) components from the reference device design, then for that variant device, as long as component removal does not cause significant changes in transmission mode compared to the reference device, it can allow for data reference processes. It should also be considered that for the reference RF exposure data, the most significant changes are usually related to changes in near-field emission modes, and these changes may be caused by minor modifications to PCB layout or component placement.
Reference device and variant device may or may not be under the same FCC ID: this is a manufacturer selection/application that requires FCC approval as part of the ECR KDB investigation. However, according to Article 2.907 (b) of the Rules, this does not affect the certification process.
7.2. DFS Data Referencing
If the client device meets the requirements of KDB 905462, DFS client devices are allowed to reference DFS data.
For example, the DFS testing reported by reference device includes 30 tests for each BW mode (20, 40, 80MHz) and each radar waveform. For approved variant devices (which may also have non DFS related changes), the DFS spot check test report may include the widest BW mode (80 MHz) and 10 tests per radar waveform to demonstrate the required pass percentage for each waveform.


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