Wireless modules: Compliance issues

In an increasingly connected world, the preponderance of wireless technologies is set to continue to grow apace. Consequently, manufacturers are adding wireless modules into products, beyond the more traditional market of laptops and mobile phones, including them in everything from domestic fridges to industrial machinery. 

Many manufacturers are assuming that because the wireless module is compliant as an independent unit, no further action on their behalf is required. However, this may not be the case.

In the European Union it is mandatory that radio equipment meets the ‘essential requirements’ of the Radio and Telecommunications Terminal Equipment Directive 1999/5/EC (R&TTE), which will be superseded by the Radio Equipment Directive (2014/53/EC) in June 2016. 

In order to reduce both costs and time to market for new equipment, many manufacturers are relying on the use of wireless modules which already meet some or all of the R&TTE essential requirements. However, once these modules are integrated into another product, this changes the regulatory requirements as the host product falls within the scope of the R&TTE Directive.

Guidance from the R&TTE Compliance Association states that when an R&TTE compliant module is integrated into a final host product, no further radio testing is necessary on the host product, provided the module is integrated in accordance with the manufacturer’s instructions. But, the host product must always meet the other essential requirements of the Directive, namely the safety and EMC aspects. 

However, integrating a wireless module is not always as straightforward as it may seem.  The most common method of demonstrating compliance with the R&TTE essential requirements is by using ‘Harmonised Standards’. These are written and published under an EU mandate, and provide a ‘presumption of conformity’, provided they are applied in full.  

As Harmonised Standards constantly evolve, they effectively have an expiry date and become superseded by more up-to-date standards, which may well have different requirements. Manufacturers may therefore need to perform a gap analysis between the two sets of standards in order to bring their products up to speed with the latest requirements. 

Global rules

For European compliance, ensure that the wireless module you are integrating is fully compliant with the latest Harmonised Standards and is integrated in accordance with the manufacturer’s supplied instructions. While the module manufacturer should be aware of the integration rules, as a minimum the final/host product manufacturer should check the module’s DoC to ensure that it lists Harmonised Standards which are in date. 

It is also important to have access to the module manufacturer’s technical file in case you, as the final product manufacturer, are asked to prove compliance by a country’s market surveillance authority. 

Remember that products containing wireless transmitters must also comply with national radio regulations no matter where in the world they are used. A product containing a wireless transmitter must not be shipped to a non-EU country without checking the regulations.

The USA and Canada have formal approval processes in place, so the routes to compliance are reasonably clear compared to Europe. However, the Federal Communications Commission (FCC) rules can be difficult to understand. 

When all FCC requirements are met and the device is certified, the FCC grant will state that the device has modular approval. The manufacturer should then display a label on the product which states that an approved wireless module is contained within it. 

The Industry Canada rules for modules are broadly similar to those of the FCC and are laid down in RSS-GEN Section 3.

For USA and Canada, host product manufacturers should check the conditions of the module grant and ensure that the product is not breaking those conditions. Once again, follow the module manufacturer’s guidance on integration and do not assume that because the wireless module itself is compliant, no further action is required once it is integrated into another product. In any country, the market surveillance authorities can come down hard on manufacturers that supply non-compliant products to the market. Ignorance of the rules is no excuse.