Considering adding Bluetooth to your product? Not sure what Bluetooth EMC compliance is required. EMC compliance when adding Bluetooth to your host product may seem to some straight forward and to others a compliance nightmare. Hopefully this blog will help you get on track!
Once you add a Bluetooth to your product your product will need to re-assessed for compliance. This simple addition of such a well used technology can lead to additional testing and other considerations such as labeling requirements.
Most companies don’t realize that they should be re-testing the for the EMC testing component with respect to the non-intentional RF components. Adding new circuitry to any product even if it does come with pre-existing certifications will still need evidence that the whole combined unit complies. Sometimes this is done as a full testing program or through pre-compliance testing results. Either method must indicate their has been no adverse EMI related affects i.e. causes failure to comply with the limits.
Why do so many companies now incorporate Bluetooth into their products? We know the answer “Everything is better with Bluetooth”.
FCC EMC compliance when adding Bluetooth FCC approved module in your product
For the North America (FCC) compliance they have what is known as modular approvals for certain types of transmitters. Provided they meet the requirements for that type of transmitter and also FCC Part 15 Sub-part B, Section 15.212 – Modular transmitters. If the Bluetooth module is already FCC part 15 Subpart C section 15.247 modular approved then additional testing is not usually required. However consideration of the highest used frequency within the device would now in most cases be the operating frequency of the Bluetooth module itself. With this in mind the upper range of the frequency band under considering for FCC Part 15, Sub-part B section 15.109 would now be 12.5GHz (the fifth harmonic of the 2.4GHz Bluetooth).
Remember existing certifications are based upon strict end use requirements including antenna type and gain etc. If these parameters are changed i.e. higher gain antenna is used then either retesting or a permissive change application via a Technical Certification Body (TCB) would be required. The host unit must be labelled as per the normal FCC labeling requirement (FCC Sub-part A, section 15.19). Additionally included on the host would be a label stating that “Contains FCC ID: ‘FCC ID of the Bluetooth module‘”. RF exposure of any product with intentional radiators must be considered for FCC compliance. With Bluetooth been such a low powered transmitter using the existing module certifications. It should be sufficient to demonstrate compliance or not require assessment via exemption.
ICES EMC compliance when adding Bluetooth ICES approved module in your product
For Canadian compliance i.e. Innovation, Science and Economic Development (ISED) it is based on testing very similar to that of the FCC testing requirements. However there are some clear distinctions. The Bluetooth module testing is done in accordance with ISED RSS-210 and like the FCC labeling requirements requires “Contains IC ID: ‘IC ID of the Bluetooth module‘” to be on the host unit. These labeling requirements can be found in ISED RSP -100 (Section 3 of RSP -100, Issue 11, January 2016). The main distinction lies with the RF exposure, there are no exemptions based upon RF power. However as the transmitter is so low powered compliance can usually be demonstrated without additional testing. Achieved by using the output levels in the RSS-210 test report along with the intended distance to the body.
CE EMC compliance when adding Bluetooth CE labelled module in your product
Unlike FCC and IC modular approvals CE does not have such provisions. This implies that technically the radiated testing of the Radio performance such as spurious emissions etc, should be repeated with the Bluetooth module installed in the host. However it maybe be possible to use the results from a trusted test laboratory test report to avoid re-testing or only performing partial testing such as the radiated RF components of testing. A Bluetooth wireless module has to comply with EN 300 328 (radio performance testing including RF power measurement power, Spurious emissions, Medium Utilization (MU) factor, Occupied Channel Bandwidth, Power Spectral Density etc this doesn’t include the host combined with Radio module). The date of the standard is extremely important, it has to be the accepted current dated reference. Older dated EN 300 328 versions may have used methods that have subsequently been revised, that are no longer accepted.
The host with the Bluetooth wireless module has to comply with the most relevant product standard for the primary function of the product along with the requirements of EN 301-489-1 & EN 301-489-17. This usually requires cross referencing the applicable requirements of the product standard and the EN 301 489 standards. This includes testing of emissions with the host and module combined. Additionally it requires immunity testing of the product whilst verifying the basic performance of the product (it’s functionality) along with the status and quality of the RF communication link i.e. the Bluetooth. If a standby/idle mode is available for the wireless communication link this is also usually required to be monitored separately (testing performed twice) to ensure no unintentional transmissions occur. As per with the FCC RF exposure, due to the nature of the transmitter and the expected low RF output power it will no doubt be exempt from EN 62479 RF assessment based on been lower then 20mW. Normal CE labeling apply and DoC requirements exist including the use of the correct directive i.e. the Radio Equipment Directive (RED).
Additional guidance for combining a radio device (i.e. Bluetooth etc.) and non-radio equipment (host) can be found in the working document; ETSI EG 203 367, V1.1.0 (2016-03) Guide to the application of harmonised standards covering articles 3.1b and 3.2 of the Directive 2014/53/EU (RED) to multi-radio and combined radio and non-radio equipment.
RCM EMC compliance when adding Bluetooth CE/RCM module in your product
Similar to CE compliance the wireless radio performance testing is essentially based upon EN 300 328. The accepted standard in Australia is AS/NZS 4268. AS/NZS 4268 incorporates methods from the European Normative (EN) relevant standard depending upon the transmitter or receiver frequency, usage, modulation and transmitter power. Typically for Bluetooth a valid report to the correct AS/NZS 4268 accepted listed dated version of EN 300 328 is accepted. Currently AS/NZS 4268: 2012 lists ETSI EN 300 328: v1.7.1 as the dated reference. However ETSI EN 300 328: v1.7.1 is now superseded and the standard has been revised a few times subsequently, i.e. v1.8.1, v1.9.1 and v2.1.1 etc. The Radiocommunications (Low Interference Potential Devices) Class Licence 2015 or “LIPD” as short, now lists a non dated reference of ETSI EN 300 328. This allows the the latest current version of ETSI 300 328 to be used to show compliance against the LIPD. In row 55 of the LIPD i.e. Frequency hopping transmitters in the frequency range of 2400MHz to 2483.5MHZ with a maximum EiRP of 500mW. Compliance can be achieved through an undated (current) version of ETSI EN 300 328 or a minimum of 15 hopping frequencies. This implies that the minimum 15 hopping frequencies is no longer required if you comply with the (current) version ETSI EN 300 328. The ACMA are aware of the need to update AS/NZS 4268 with a revised dated or non-dated version of the standard and the Standards Australia committee RC-006 are working towards this. We believe the ACMA have now allowed suppliers to show compliance with the current version of the standard. The Australian Communications and Media Authority (ACMA) explanatory statement has further information about the changes.
2017 UPDATE: AS/NZS 4268: 2017 has now been published. This new version of the standard has some changes including more guidance upon the use of existing certifications such as FCC and ETSI standards. An FCC test report or an ETSI test report may be able to be used as evidence in full to demonstrate compliance. This means that their are presently two routes of using existing compliance evidence, A) a valid FCC test report or B) a valid ETSI test report. A combination ‘mix and match’ hybrid of the FCC and ETSI reports is not allowed. With the variations in the required testing for FCC and ETSI compliance, it may require less testing or be deemed easier to comply via the FCC or the ETSI requirements. It is accepted that either route is acceptable, however the supplier must ensure that device operates in accordance with the LIPD.
An example of how to show compliance would be that the supplier can demonstrate compliance to all of the applicable requirements included in the FCC rules or the ETSI standards listed in AS/NZS 4268:2017, including testing at extreme temperatures, voltage extremes etc. However, if the FCC rules or the ETSI standard does not specify such testing (i.e. testing at extreme temperatures is not required) then this is not required. It must be remembered that if an SRD transmitter operates in Australia outside of the parameters, authorised by the LIPD class licence, then the transmitter will be unlicensed and the end user could be prosecuted for offence(s) under the Radiocommunications Act 1992.
As with CE compliance requirements the host combined with module should be assessed against the requirements of the most relevant product standard for the primary function of the product. Each combination of host and different radio module should be assessed for EMC (non intentional RF) compliance even if Radio-communication approvals exist for that portion of the RCM compliance requirements. Typically harmonics (EN 61000-3-2) and Flicker (EN 61000-3-3) or immunity testing is usually not required. Also as per the FCC and CE usually the RF exposure compliance requirements (Radio Protection Standard (RPS) 3) can be met through an RF exposure testing exemption. Normal Regulatory Compliance Mark (RCM) labeling requirements and supplier responsibilities as per all applicable products apply.
Applying the Bluetooth Logo?
You may or not be aware that there are conditions surrounding the use of the Bluetooth logo. To sell, brand or re-brand a product using any of the Bluetooth® trademarks (including the word “Bluetooth”) you must declare that your product satisfies the requirements of the Bluetooth license agreements. For further information regarding the conditions (applies worldwide) of using the Bluetooth Logo trademark please visit the website.
Note: If you are a retailer or supplier who is simply selling or distributing another company’s Bluetooth product and you are not adding any logos, branding or representing the product as your own, you do not need to qualify or declare the product.
If you incorporate more than one intentional radiator/wireless radio device in your product the entire compliance and certification process will instantly become more complex than the outlined basics within this blog. We always recommend seeking professional assistance through a trusted Technical Certification Body (TCB) for approval of test plans and certification routes and options.
If you require Electromagnetic Compatibility (EMC) testing your host product that incorporates a Bluetooth module for RCM compliance for FCC, IC, CE or RCM compliance contact us and find out how we can help.