Re: [PSES] 802.11 built into a product for Australia

[Kevin.Richardson]

Hi Peter,

It might be easier to discuss this off-line as it can be quite complicated 
however, the basic elements are these:
-  an item that cannot operate on its own and requires a ''host'' or ''parent'' 
device in order to operate (i.e. requires powering etc. from the host and 
connection to and antenna etc.) is exempt from ACMA regulations (radcoms, EMC 
etc.) and therefore is not required to be marked with the RCM;

-  the host or parent device must, with the intentional radiator included, be 
tested and comply plus be marked with the RCM;

-  AS/NZS 4268 has many categories of equipment type and several of them over 
802.11 devices however, only 2 of the 802.11 categories (i.e. Row 45A & 45B) 
refer to compliance with ETSI standards (ETSI EN 300 328-1) by way of Note 5 to 
Table 1 of AS/NZS 4268;

-  you will note that in Note 5, the penultimate sentence states ''A compliant 
test report to ETSI EN 300 328-1 shall be sufficient to show compliance with 
this standard.''  This means that providing you have a test report to ETSI EN 
300 328-1 that states the device complies you can use that test report to claim 
complacent with AS/NZS 4268 (i.e. compliance with AS/NZS 4268 is stated on the 
Australian Declaration of Conformity by the Australian supplier or their Agent 
in terms of compliance).

Hope this helps.

Best regards,
Kevin Richardson

Stanimore Pty Limited
Compliance Advice & Solutions for Technology
(Legislation/Regulations/Standards/Australian Agent Services)
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-Original Message-
From: Peter Tarver [mailto:ptar...@enphaseenergy.com] 
Sent: Wednesday, 11 November 2015 12:13 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] 802.11 built into a product for Australia

We are marking a product with the RCM and have done relevant emissions testing 
for the complete product.  The intent from the start has been to leverage the 
testing and certifications the supplier obtained to reduce the amount of 
testing needed for the end product (a "modular approach" in a global scale).

An IEEE 802.11 intentional radiator is incorporated into the product.  The 
product incorporates a supplier's reference design that has been tested against 
relevant ETSI standards for EU deployment.  These ETSI standards are referenced 
 by AS 4268.  However, we do not have a test report that explicitly mentions AS 
4268 or a certificate indicating compliance with AS
4268 from the supplier.

In reading the Radiocommunications Labeling Notice, a 2014 revision adds AS 
4268 as a requirement.

I am asking the supplier to obtain at least a certificate showing compliance 
with AS 4268, but they are pushing back, indicating they would need to mark 
their chipset with the RCM.  This is an inappropriate use of the RCM, since it 
apples to complete products.  The supplier has not been able to identify the 
marking the claim is needed for their chipset.  The
802.11 intentional radiator is not being used for audio signals.

I am asking for the certificate or an amended report that explicitly mentions 
AS 4268 to avoid having to go through unnecessary gyrations should the 
compliance status of the intentional radiator come into question.  My intent is 
also to no have to explain why the ETSI testing covers the requirements in AS 
4268 to a bureaucrat with limited technical knowledge and to also satisfy 
customer requests for evidence of compliance.

Am I asking too much of the supplier?


Regards,

Peter L. Tarver

-

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Website:  

[PSES] 802.11 built into a product for Australia

[Peter Tarver]

We are marking a product with the RCM and have done relevant emissions
testing for the complete product.  The intent from the start has been to
leverage the testing and certifications the supplier obtained to reduce
the amount of testing needed for the end product (a "modular approach" in
a global scale).

An IEEE 802.11 intentional radiator is incorporated into the product.  The
product incorporates a supplier's reference design that has been tested
against relevant ETSI standards for EU deployment.  These ETSI standards
are referenced  by AS 4268.  However, we do not have a test report that
explicitly mentions AS 4268 or a certificate indicating compliance with AS
4268 from the supplier.

In reading the Radiocommunications Labeling Notice, a 2014 revision adds
AS 4268 as a requirement.

I am asking the supplier to obtain at least a certificate showing
compliance with AS 4268, but they are pushing back, indicating they would
need to mark their chipset with the RCM.  This is an inappropriate use of
the RCM, since it apples to complete products.  The supplier has not been
able to identify the marking the claim is needed for their chipset.  The
802.11 intentional radiator is not being used for audio signals.

I am asking for the certificate or an amended report that explicitly
mentions AS 4268 to avoid having to go through unnecessary gyrations
should the compliance status of the intentional radiator come into
question.  My intent is also to no have to explain why the ETSI testing
covers the requirements in AS 4268 to a bureaucrat with limited technical
knowledge and to also satisfy customer requests for evidence of
compliance.

Am I asking too much of the supplier?


Regards,

Peter L. Tarver

-

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.

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