FCC Certification for Milli based devices

Overview for partners ready to begin FCC testing for Milli based devices

FCC and ISED Requirements

The Federal Communications Commission (FCC) is the governing body for wireless devices in the United States. Similarly, the Innovation, Science and Economic Development Canada (ISED) (formerly Industry Canada or IC) is the governing body for wireless devices in Canada. Itron Milli5 is classified as a modular plug-in, frequency hopping spread spectrum (FHSS) radio device that operates in the 902-928 MHz unlicensed radio bands and must therefore comply with FCC CFR Part 15 Subpart C 15.247 and ISED RSS-247. Itron partners planning to integrate Milli5 in their products must obtain certification from FCC or ISED before they can sell these devices in the United States and Canada respectively.

Note: Since the FCC and ISED have almost identical rules guiding the 902-928 MHz unlicensed bands, for ease of understanding and writing, we will refer to all the requirements as FCC Requirements in the document below.

The following steps, options and tools are recommended guidelines for Itron partners pursuing FCC certification for their production ready devices based on Itron's Milli 5 LMA radio module.

FCC Certification Overview

  1. Partner Device is production ready

  2. Partner selects an Authorized Test Lab (TCB or Telecommunications Certifications Bodies can be found on this link)

  3. Authorized Test Lab performs required tests based on FCC requirements

  4. Authorized Test Lab submits results to FCC

  5. FCC certification is granted with Grant ID (search on this link with your Grant ID)

Partner FCC Process Options

Itron provides detailed guidlines and options for FCC certification in the Milli Datasheet.  Itron Milli5 is FCC Certified as Limited Modular Approval (LMA). LMA may be granted to a device which cannot meet all the requirements of a Single Modular Transmitter and if compliance can be demonstrated under the operating conditions in which the device will be used. Itron partners have the following options for FCC Certification using an LMA. Assuming that partner follows outlined requirements Option 2 provides partners the simplest path towards certification.

Option 1:   Use Itron's own FCC/IC Grant, without the need of an additional Certification by following these rules. Itron requires the partner to provide proof of compliance before issuing authorization. This option is only recommended if the partner device is almost identical to the submitted FCC/ISEC Grant of Itron. In any other case Option 2 or 3 is recommended.

In case Partner would like use this option, Itron requires compliance with the following:

  • Design to the strict guidelines for layout as described in 50 ohm PCB Design Guidelines (see relevant section of the Milli Datasheet)
  • Use an external antenna of the same as Itron tested with equal or less gain (see relevant section of the Milli Datasheet)
  • Deliver power regulation to Milli 5 as described in Recommended Operating Conditions (see relevant section of the Milli Datasheet).
  • Deliver buffered modulation/data inputs to Milli 5
  • Label the host device with, “Contains FCC ID: OWS-MIL51” and “Contains IC: 5975A-MIL51.”
  • The user’s manual for the partner device must contain the following information in a prominent location: "To comply with FCC & IC RF exposure requirement, the antenna used for this transmitter must be installed to provide a separation distance of at least 20 cm (8 in.) from all persons and must not be co-located or operating in conjunction with any other antenna or transmitter."

Itron requires from partners the following information based on the above points for proof of compliance (provided to Itron via e-mail):

  1. The partner device PCB Board design for review (preferable Gerber files) that meets the strict design guidelines for layout as described in the 50 ohm PCB Design Guidelines section of the Milli Datasheet.
  2. Completed test results regarding power output and spurious emissions (relevant FCC tests) with the antenna specifications intended to be used to Itron for review (the results needs to be similar compared to our own submitted test results – see link in the reference section for our test results)
  3. Once all documents are provided and received, Itron will review these within 5 business days and provides a response.
  4. If this can not be submitted or not approved, partner can not use option 1 and authorisation can not be granted. The partner has to use Option 2 or 3 (full FCC certification)
  5. If approved Itron will send partner a letter granting them permission to use the Itron FCC ID “OWS-MIL51”.

Option 2:  Apply for change of FCC ID via Class 2 Permissive Change (C2PC) application to existing FCC/ISED Limited Modular Approval (LMA) Grant for Itron Milli 5 to allow the use of a different antenna type

In case of Option 2 the following steps has to be followed:

  1. Partner follows 50 ohm PCB Design Guidelines (see relevant section of the Milli Datasheet)
  2. Selected and Authorized Test Lab performs tests conducted output power and radiated spurious emissions with the new (or existing) antenna at an ISO 17025 accredited FCC lab. These are the tests outlined under chapter 9.3 and 10.2 of Itron's complete FCC test report.
  3. Selected and Authorized Test Lab by Partner issues a SCS-F27 Authorization Letter to Itron via e-mail.
  4. Itron provides Authorization Letter to Partner in response to Step 3 via e-mail.
  5. Partner's Selected and Authorized Test Lab will submit the C2PC for Change in ID using partners Test Report and Itron's Authorization Letter.

Option 3:  Obtain Full FCC Certification for the new partner device

Partner can decide to choose to obtain own FCC Certification even if guidelines are followed or the partner device design does not follow strict guidelines for layout. Partner can follow the steps above and select a TCB to pursue this option. 

Tools

Itron provides an FCC compliance tool that can be used with the Hardware Developer Kit and is documented here. It details instructions and guidance how to setup and run the test required to meet FCC requirements.