IoT and Other RF Device Suppliers Take Note: The FCC's New Authorization and Importation Rules Are Now Effective

The CommLaw Group has issued a client advisory regarding the Federal Communications Commission's new rules for radio frequency equipment authorization.
By Ronald E. Quirk

Electronic Labeling
The new FCC rules include provisions to implement the E-LABEL Act, which requires the FCC to allow manufacturers of RF devices that have the capability to digitally display labeling and regulatory information to use electronic labeling instead of affixing physical labels to the equipment.

The FCC requires that labeling and regulatory information, when digitally displayed, should be accessible in no more than three steps. Examples include: (a) user accessing the device settings menu; (b) accessing a submenu of legal information; and (c) accessing a further submenu of FCC compliance information. Accessing the applicable information must not require any sort of code or permission.

In order to ensure that the labeling and regulatory information is provided effectively to the purchaser, the user must be provided with clear instructions on how the access the required information in either the packaging material or another easily accessible format at time of purchase. This information must be also available on the responsible party's website.

Measurement Procedures and Standards
Historically, the FCC accepted measurement data in compliance testing that comports with three types of procedures: (a) FCC bulletins; (b) reports published by national engineering societies and accepted by the FCC; and (c) any measurement procedure accepted by the FCC.

The FCC's new rules permit measurement data to include references to information available in its Knowledge Database publications. Responsible parties may also now reference specific sections of the ANSI C63.26 as a standard for compliance testing of licensed devices.

The Devil Is in the Details
This is high-level overview of the key RF equipment rule changes. The rules themselves are varied and complex; a detailed analysis of the planned changes is beyond the scope of this article. Due to the comprehensive nature of these rule changes, all stakeholders in the RF equipment marketplace should become informed about them in order to ensure compliance therewith. The FCC has been brutal on RF equipment suppliers that market or import equipment that is not in compliance with its rules.

If you would like additional information about the FCC's RF equipment rules, including suggestions for best practices, please contact IoT attorney Ronald E. Quirk, Jr. at (703) 714-1305 or req@commlawgroup.com. Further information about Marashlian & Donahue's Internet of Things and Connected Devices practice is available here.

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