Hi Charlie, Ok I got it. So if it was wireless power transfer at 13.56 MHz with No communication then it doesn't fall under the RED.
I believe that 13.56 MHz NFC WLC can be both power and communication to control the charging however, although I guess they could use BLE to control the charging and NFC be strictly used for WPT. If I am reading things correctly there is a static mode of operation and a negotiated mode of operation, so you would need to know which technology is being used to determine what standards applies. Thanks. Larry K. Stillings Compliance Worldwide, Inc. Test Locally, Sell Globally and Launch Your Products Around the World! FCC - Wireless - Telecom - CE Marking - International Approvals - Product Safety 357 Main Street Sandown, NH 03873 (603) 887 3903 Fax 887-6445 complianceworldwide.com<https://complianceworldwide.com/> Follow us on social media [cid:[email protected]] linkedin.com/company/compliance-worldwide-inc [cid:[email protected]] twitter.com/complianceww Privileged/Confidential Information may be contained in this message. If you are not the addressee indicated in this message (or responsible for delivery of the message to such person), you may not copy or deliver this message to anyone. In such case, you should destroy this message and kindly notify the sender by reply email. Please advise immediately if you or your employer do not consent to Internet email for messages of this kind. Opinions, conclusions and other information in this message that do not relate to the official business of my firm shall be understood as neither given nor endorsed by it. From: Charlie Blackham Sent: Friday, April 23, 2021 11:22 AM To: Larry K. Stillings <[email protected]>; [email protected] Subject: RE: 13.56 MHz NFC WLC ETSI Standard? Larry RFID and EAS are forms of "radio communication" so fall within scope of the Radio Equipment Directive (RED), and the applicable article 3.2 Harmonised Standard Wireless Power Transfer by itself does not fall within scope of the RED, it does not have to meet the RED article 3.2. Any communication as part of the power transfer (such as hand-shaking) would fall under RED article 3.2 ETSI EN 303 446-1 V1.2.1 and EN 303 446-2 V1.2.1 provide guidance on testing combined radio and non-radio equipment - the radio aspects has to meet the radio standards and the non-radio aspect the EMC standard and EN 555032 should be considered if the highest frequency in the radio put the EMC upper frequency above upper frequency of the applicable EMC standard (not required in this case) Best regards Charlie Charlie Blackham Sulis Consultants Ltd Tel: +44 (0)7946 624317 Web: https://sulisconsultants.com/ Registered in England and Wales, number 05466247 From: Larry K. Stillings <[email protected]<mailto:[email protected]>> Sent: 23 April 2021 16:09 To: Charlie Blackham <[email protected]<mailto:[email protected]>>; [email protected]<mailto:[email protected]> Subject: RE: 13.56 MHz NFC WLC ETSI Standard? Hi Charlie, Ok thanks. I was under the assumption that if we are applying ETSI EN 300 330 to a product then the fundamental transmission would have to meet the H-Field 42 dBuA/m or 60 dBuA/m limit spectrum mask limit in Annex I and not unlimited power despite being in an ISM band. I also am assuming that any harmonics generated by the NFC WLC technology would only have to meet the spurious emissions limits in Table 6 from 30 to 1000 MHz and not have to meet the EN 55032 Class A or Class B limits for anything transmission related to the transmitter as explained in EN 303 446-1 and -2. Larry K. Stillings Compliance Worldwide, Inc. Test Locally, Sell Globally and Launch Your Products Around the World! FCC - Wireless - Telecom - CE Marking - International Approvals - Product Safety 357 Main Street Sandown, NH 03873 (603) 887 3903 Fax 887-6445 complianceworldwide.com<https://complianceworldwide.com/> Follow us on social media [cid:[email protected]] linkedin.com/company/compliance-worldwide-inc [cid:[email protected]] twitter.com/complianceww Privileged/Confidential Information may be contained in this message. If you are not the addressee indicated in this message (or responsible for delivery of the message to such person), you may not copy or deliver this message to anyone. In such case, you should destroy this message and kindly notify the sender by reply email. Please advise immediately if you or your employer do not consent to Internet email for messages of this kind. Opinions, conclusions and other information in this message that do not relate to the official business of my firm shall be understood as neither given nor endorsed by it. From: Charlie Blackham Sent: Friday, April 23, 2021 10:53 AM To: Larry K. Stillings <[email protected]<mailto:[email protected]>>; [email protected]<mailto:[email protected]> Subject: RE: 13.56 MHz NFC WLC ETSI Standard? Larry ETSI EN 303 417 is for Wireless Power Transmission rather than low frequency communication and is looking at bands that aren't currently ISM or are restricted in some regions. It's looking at wireless charging for vehicles and other uses with the power transfer running up into kW. 13.56 MHz is already an ISM band with unrestricted power, so 13.56 MHz NFC WLC technology doesn't need a new standard to be developed EN 300 330 V2.1.1 is the appropriate standard, and there's no power limit for the 13.553 - 13.567 MHz band Best regards Charlie Charlie Blackham Sulis Consultants Ltd Tel: +44 (0)7946 624317 Web: https://sulisconsultants.com/ Registered in England and Wales, number 05466247 From: Larry K. Stillings <[email protected]<mailto:[email protected]>> Sent: 23 April 2021 15:32 To: [email protected]<mailto:[email protected]> Subject: [PSES] 13.56 MHz NFC WLC ETSI Standard? Hello All, I was curious if anyone new of any work going on with ETSI to develop or add a standard specifically for 13.56 MHz NFC WLC technology? Looks like to me right now the appropriate standard would be ETSI EN 300 330 V2.1.1 Not sure if they are intending to add the 13.56 MHz band to the ETSI EN 303 417 standard in a future edition, as the scope still stops with the 6.78 MHz band. Or maybe develop a new standard all together or add a new part to EN 300 330 for NFC WLC technology? Larry K. Stillings Compliance Worldwide, Inc. Test Locally, Sell Globally and Launch Your Products Around the World! 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