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 straightforward. And to others a compliance nightmare. Hopefully, this blog will help you get on

Once you add 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 extra testing. Other considerations such as labelling requirements may need to be addressed.   Most companies don’t realize that they should be re-testing. The EMC testing component with the non-intentional RF components. Adding new circuitry to any product even if it does come with pre-existing certifications may change the product. It will still need evidence that the whole combined unit complies. Sometimes this is a full testing program or through pre-compliance testing results. Either method or show there have been no adverse EMI related effects 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 Subpart B, Section 15.212 – Modular transmitters. If the Bluetooth module is already FCC part 15 Subpart C section 15.247 modular approved then extra testing is not usually required. Yet, consideration of the highest used frequency within the device should be. It 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, Subpart B section 15.109 would change. .Now it would be 12.5GHz (the fifth harmonic of the 2.4GHz Bluetooth).   Remember existing certifications are based on strict end use requirements. These include the antenna type and antenna gain. If these parameters are changed i.e. higher gain antenna is used. Then it requires either retesting. Or a permissive change application via a Technical Certification Body (TCB). The host unit must be labelled as per the normal FCC labelling rule (FCC Subpart 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 enough to prove compliance or not need 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 like that of the FCC testing requirement. Yet, there are some clear distinctions. The Bluetooth module testing is usually in accordance with ISED RSS-210. And like the FCC labelling requirements requires “Contains IC ID: ‘IC ID of the Bluetooth module'” to be on the host unit. These labelling 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. But, as the transmitter is so low powered compliance can usually be demonstrated without extra 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 ICES modular approvals CE does not have such provisions. This implies that the radiated testing of the Radio performance such as spurious emissions should be repeated. With the Bluetooth module installed in the host. But, it may be possible to use the results from a trusted test laboratory test report. Avoiding 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. Which includes, radio performance testing. Some tests include RF power measurement power, Spurious emissions, Medium Utilization (MU) factor, Occupied Channel Bandwidth, Power Spectral Density. This doesn’t include the host combined with the Radio module. The date of the standard is extremely important. It has to be the accepted current dated reference as per RED. Older dated EN 300 328 versions may have used methods that have subsequently been revised or withdrawn, and no longer accepted.

Extra Guidance

Extra guidance for combining a radio device i.e. Bluetooth and non-radio equipment (host) can be sought in 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.

The host with the Bluetooth wireless module has to follow the most relevant product standard. The product standard is usually related to the primary function of the product. Along with the requirements of EN 301-489-1 & EN 301-489-17. Requiring cross-referencing the 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. Then this is also usually required to be monitored separately. Effectively the testing performed twice to ensure no unintentional transmissions occur. As per 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 than 20mW. Normal CE labelling applies and DoC requirements exist. Including the use of the correct directive i.e. the Radio Equipment Directive (RED).  

RCM EMC compliance when adding Bluetooth CE/RCM module in your product

Like CE compliance the wireless radio performance testing can be based upon EN 300 328. But also the use of FCC rules and testing may apply. The accepted standard in Australia is AS/NZS 4268. AS/NZS 4268 incorporates methods from the European Normative (EN) relevant standard. And now also the FCC rules. Depending upon the transmitter or receiver frequency, usage, modulation and transmitter power. 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: with an un-dated reference. Like the un-dated FCC rules also listed in AS/NZS 4268. The Radiocommunications (Low Interference Potential Devices) Class Licence 2015. Or “LIPD” as short, also lists a non-dated reference of ETSI EN 300 328. This allows the application to the latest current version of ETSI 300 328 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 through a non-dated (current) version of ETSI EN 300 328 or a minimum of 15 hopping frequencies. This implies that the minimum 15 hopping frequencies are no longer required if you comply with the (current) version ETSI EN 300 328.

AS/NZS 4268: 2017 UPDATE

Recent updates to the industry standard have meant some clarifications. With respect to the use of existing certifications for re-use in Australia. For further information on RCM Radiocommunications requirements for Australia check the blog post.

As with CE compliance requirements, the host combined with a module should be assessed. 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. 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) labelling requirements. And supplier responsibilities as per all applicable products apply.

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 agreement. For further information about the conditions which apply worldwide. For 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. We always recommend seeking professional help. Either through a trusted Technical Certification Body (TCB). And get an approval of compliance test plans and certification routes and options.

If you need Electromagnetic Compatibility (EMC) testing. For your host product that incorporates a Bluetooth module. for RCM compliance for FCC, ISED, CE or RCM compliance contact us and find out how we can help.