FCC发布引用测试数据的法规-draft KDB 484596 D01

2016年12月8日FCC发布了draft版本的KDB 484596 D01，允许独立产品授权认证申请时引用数据， 此KDB适用于设计和内部印刷电路相同的产品申请不同的FCC ID时的情形。

　　1. 引用数据的报告有如下两种显示方法：

　　a、新产品的报告必须包含对引用数据的解释，在报告中清楚指明原FCC ID。 如果原FCC ID被dismiss，新产品需要申请C2PC。
　　b、新产品报告中需要有合理的解释说明原FCC ID是何时完成的FCC ID申请。

　　2. 测试数据概要大纲总结如下:

　　a、简介：简要说明原FCC ID。申请者需声明新的FCC ID引用的数据是符合法规的并对此负全责。
　　b、差异说明：简要描述两组产品的组件差异。
　　c、验证数据：提供一份抽测数据与原数据对比的摘要。抽测数据应当基于原FCC ID数据最差模式的测试结果。
　　d、参考部分：详细清单列出对原FCC ID报告的数据引用。

　　3. 对于DFS认证，需要先做PAG (KDB 443999)。

　　4. 数据引用只针对在同一个Grantee code下。如果A Grantee Code想引用B Grantee Code的数据，则A Grantee Code需要先申请FCC change in ID变成 B Grantee Code，再引用数据。

　　具体法规内容请参考以下FCC网站链接：https://apps.fcc.gov/eas/comments/GetPublishedDocument.html?id=421&tn=352969 

原文：

GUIDANCE FOR REFERENCING TEST DATA ACROSS SEPARATE EQUIPMENT AUTHORIZATION APPLICATIONS 

This guidance pertains to RF devices approved under separate FCC IDs that use the same internal printed circuit board layout, have a common design and components, and where the separate FCC IDs differ in the population or depopulation of components for the purposes of adding or removing transmitters or frequency bands of operation. Applicable test data for the common transmitter/bands that overlap the separate FCC IDs may be eligible to be referenced in a new equipment authorization application. Applications for certification based on this guidance are not subject to Pre-Approval Guidance (PAG) procedures (KDB Publication 388624) as long as all the items in this guidance document are followed by applicants and TCBs. 

1) General guidance

 a) All compliance tests must be performed on a reference device that is fully populated or contains a majority of the components. The test results for the reference device must document all of the required tests under all applicable rule parts and supported air-interfaces (e.g., Wi-Fi, BT, BLE, NFC, and simultaneous transmission testing per Section 15.31(k)). If no single configuration represents a fully populated reference unit, because of variations in available devices, then the device configuration that has the majority of common components may be used as the reference device.

 i) It may also be permissible to test multiple devices to establish the reference test data, to ensure that all components/layouts have been considered. 

b) Applications that intend to reuse the reference test data shall include spot check measurement data, to demonstrate that the referenced test data is valid. 

2) Referenced test report exhibits filed have two options: 

a) The test report exhibits for the new device must contain a reuse explanation that clearly identifies the test report exhibit(s) being referenced as contained in the separate source FCC ID application(s). 

    i) One risk in referencing test data from separate FCC ID filings is that the source filing(s) may have been dismissed (Section 2.917); in this case, a Class II permissive change is required to upload the referenced test data into the record of the new FCC ID. 

b) Test report exhibits in a new FCC ID filing must contain suitable explanations when referenced test data from a separate source FCC ID is also uploaded into the new FCC ID filing.

3) Guidance for reference test data Explanations: 

A separate reference test data explanation summary is required in each application (each equipment class) under a single FCC ID. Generally this should be an exhibit in the test report folder (exhibit type). The details and format are left to the applicant to organize the summary for clarity that best fits their situation. In some cases, within a single application, it may be appropriate to have more than one separate reference test data explanation summaries (as in the case for HAC) or separate summaries (as in the case for RF exposure) filed in the appropriate separate exhibit folder. A recommended outline for a test data summary is as follows:

  a) Introduction: An introductory statement identifying the FCC ID being referenced, and if appropriate the equipment class(s), rule parts, and frequency bands. A statement that the applicant takes full responsibility that the test data as referenced per d) below represents compliance for the new FCC ID. 

b) Explain the Differences: A brief description of the component differences among the different FCC IDs. 

c) Spot Check Verification Data Section: Provide a summary of spot check test data compared to the reference test data. 1 

d) Reference Section: A detailed matrix listing the cross references for the other FCC ID’s test report(s). The reference section should be organized along the lines as listed on the grant (i.e. rule parts, frequency range (MHz), and emission designator). Each listing then would reference the FCC ID, report title and location for the referenced test report. At this time, the details and format will be left to the applicant to organize the cross reference matrix that best clarifies the specific situation. In some cases this can be a simple matrix that cross references to one common merged report or may require breaking down the matrix listing into split references. The reference section needs to clearly allow the reader to understand what is being granted and where the test data is located for each listed item. 

4) Other considerations and requirements 

a) In general, test report(s) in an application are contained in multiple Form-731 line-entry records associated with equipment classes, initial grants, permissive changes, etc.; as such application records can be complex and confusing to novices and even experts. Please keep references simple and organized. Summarize and communicate the organization of the new versus referenced test data, making it clear what the data being referenced is, and what is new test data that is not being referenced.

  b) For DFS applications, please contact the FCC through a PAG (further to KDB Publication 443999). 

c) Reuse data can only be cross-referenced within the same Grantee Code. If a grantee (A) wants to use a separate grantee’s (B) test report, then grantee (A) must first do a change-in-FCC ID (Section 2.933) to the FCC ID of grantee (B) that is referenced. With documented permission from grantee (B), grantee (A) shall upload the source test report as an exhibit in the change-inFCC ID application. Next, grantee (A) can file a new FCC ID application for the depopulated or otherwise modified device configuration, including reference to the test report in the change-in-FCC ID application. 

d) Spot check test data included for the variants shall be based on worst-case results reported in the original FCC ID filing.

  e) For RF exposure purposes, each combination of frequency band, wireless mode, and exposure test conditions shall be considered separately. A KDB inquiry is recommended for complex device configurations to confirm appropriate RF exposure test cases.