CE Testing Requirements for Host Products: Navigating US, Canadian and EU Regulations

In the world of electromagnetic compatibility (EMC) and radio equipment regulations, products incorporating pre-approved wireless modules “host products “are a special and often misunderstood beast. If you’re a manufacturer looking to get into the US, Canada or the EU markets, understanding these requirements isn’t just nice to have, it’s necessary.

This article will go over the CE testing requirements for host products in the US, Canada and the EU, clearing up common misconceptions and highlighting the differences and similarities.

What are Host Products in EMC and Radio Regulations?

A host product in EMC and radio regulations is an electronic device that can incorporate wireless modules that already have regulatory approvals (FCCID, CE-Mark ISED ID). A good example is a laptop computer that can take various wireless cards. These versatile devices add extra layers of compliance complexity.

It’s important to understand host products when navigating EMC and Radio testing requirements across regions. This is the basis for compliance in multiple markets and regulatory environments and the directive that applies.

FCC Regulations for Host Products in the United States

In the US the Federal Communications Commission (FCC) regulates EMC and radio frequency devices. Host products fall under several FCC rules and here’s what you need to know:

1. Part 15 Compliance

Most host products fall under FCC Part 15 rules which covers both unintentional and intentional radiators. These rules ensure that electronic devices do not interfere and can coexist with other electronic devices.

2. Modular Approvals

A host product using a certified module needs to ensure the module operates within the conditions it was originally certified for. Modular approvals where a wireless module can be pre-certified and then inserted into various host products. But even with modular approval the host product may need additional testing to be compliant overall.

3. Class A vs. Class B

Devices are classified as Class A (industrial/commercial) or Class B (residential), with Class B having tighter emission limits. Knowing your product’s classification is key to determining the applicable standards and testing requirements.

4. Testing Requirements

Testing is a cornerstone of FCC compliance. Unintentional radiators need testing for radiated and conducted emissions, intentional radiators need additional testing for spectrum use and RF exposure. This ensures the device operates within the FCC’s limits and doesn’t interfere with other devices.

5. Host-Specific Testing

When a host product integrates various modules or RF devices, additional testing may be necessary to ensure that the combined system meets FCC requirements. Testing verifies the host product meets all necessary requirements when the module is inserted and that it doesn’t create interference issues.

ISED Regulations: Canadian Requirements for Host Products

Canada, through Innovation, Science, and Economic Development Canada (ISED), regulates EMC and radio equipment with similar standards to the US. But there are some differences:

1. ICES and RSS

ISED’s rules are similar to the FCC’s with ICES (Interference-Causing Equipment Standard) for unintentional radiators and RSS (Radio Standards Specification) for intentional radiators. These standards ensure devices don’t cause harmful interference. Knowing these standards is key to being compliant in the Canadian market.

2. Mutual Recognition Agreement (MRA)

Canada and the US have an agreement where test results from a lab in one country can be accepted by the other. This MRA can simplify the testing process for manufacturers targeting both markets.

3. Differences from FCC

Although the Canadian standards are similar to the FCC’s there are some differences such as different frequency ranges for some tests and additional requirements for certain product categories. Manufacturers need to be aware of these subtleties to be fully compliant.

4. Host-Specific Testing

Like the FCC, ISED allows for modular approvals but may require additional testing to ensure the host product, when installed with the module, complies with all Canadian regulations.

EU CE Marking and Directives for Host Products

In the EU, the CE marking means a product complies with a set of directives that ensure health, safety and environmental protection. For host products the key directive is:

1. Radio Equipment Directive (RED) (2014/53/EU)
   Applicable to products using radio frequencies, RED ensures these devices meet essential requirements for health, safety and efficient use of the radio spectrum.

The RED encompasses these directives:

1. EMC Directive (2014/30/EU)
   This directive covers electromagnetic compatibility and ensures devices don’t emit harmful electromagnetic interference and aren’t susceptible to it.
2. Low Voltage Directive (2014/35/EU)
   This directive applies to the electrical safety of products operating between 50-1000V AC or 75-1500V DC, ensuring they can be used safely within these voltage ranges.
3. Harmonized Standards: The EU publishes harmonized standards that provide a presumption of conformity with the relevant directives when followed. Following these standards can simplify the CE marking process.
4. Self-Declaration: Unlike the US and Canada, many products in the EU can be self-declared compliant by the manufacturer without third party testing. This gives manufacturers more flexibility but requires a deep understanding of the applicable standards.
5. Notified Body Involvement: For certain radio equipment or where harmonized standards don’t cover the product, a Notified Body must be involved in the conformity assessment. This independent organization ensures the product meets all the requirements.
6. Technical File: Manufacturers must compile a technical file to demonstrate compliance, including test reports, risk assessments and user documentation. This file must be kept for at least 10 years after the product is placed on the market.

Host-Specific Considerations in the EU

Even with compliant modules the host product must be assessed as a complete system to ensure it meets all relevant EU directives. Some product categories have additional essential requirements under RED Article 3.3 that must be considered during the compliance process for host products.

Host Product Regulations: US vs Canada vs EU

Understanding the similarities and differences across these regions is key to efficiency:

Similarities:

• EMC Testing: All regions require EMC testing for unintentional radiators and have additional requirements for intentional radiators (radio devices).
• Modular Approvals: Accepted to some degree in all regions.

Differences

• Regulatory Bodies: The US uses the FCC, Canada uses ISED and the EU relies on various standards bodies.
• Certification Processes:
  • US and Canada: Formal certification is required for transmitters.
  • EU: Allows self-declaration of conformity.
• Standards and Markings: Each region has its own standards and limits, marking requirements (FCC ID, IC Certification Number, CE mark) and slight variations in frequency bands and power limits.

Region-Specific Documentation:

EU:

• CE DoC: Covers EMC emission/immunity and product safety. Mandatory.
• CE Mark: Mandatory.

US:

• FCC SDoC: Covers EMC emissions only (FCC Title 47 CFR Part 15).
• FCC Label: Voluntary, (FCC SDoC guidelines)

Canada:

• ISED Mark: Mandatory. For more detailed information, you can refer to the General Requirements for Compliance and explore common questions and answers related to the certification process.

5 Common Misconceptions About Host Product Compliance

Understanding these common misconceptions is crucial for ensuring your host product meets all necessary compliance standards across different regions.

1. Modular Approvals Mean Host Product is Compliant

Modular approvals are convenient but they don’t mean the host product is compliant. More testing is often required to ensure the host product as a whole meets all the requirements.

2. EU Self-Declaration Means Less Stringent Requirements

Self-declaration in the EU doesn’t mean less requirements. Manufacturers must still ensure full compliance and keep full documentation to support their declarations..

3. Compliance in One Region Means Global Compliance

Products compliant in one region aren’t compliant in others. Each region’s requirements must be met to be globally compliant.

4. Testing Scope is Uniform Across Products

The scope of testing can vary depending on the product’s classification and intended use which isn’t always clear. It’s important to know the specific testing requirements for each product.

5. Once Compliant, Always Compliant

Regulations change. A compliant product may need to be re-evaluated if the standards change, so it’s important to stay up-to-date with the latest regulations.

Host Product Manufacturers Take Away

• Know your product’s classification and target markets early in the development process.

• Modular approvals are helpful but don’t guarantee host product compliance.

• Pay attention to region-specific requirements especially for certification and labeling.

• Stay up to date with regulatory changes that may impact your product’s compliance status.

• Design to the most stringent requirements when targeting multiple markets.

Don’t Leave Compliance to Chance

CE testing for your host products is not just about legal compliance, it's about protecting your business and your product’s success in multiple markets.

Reach out to Green Mountain Electromagnetics today, and let us help you navigate the complexities of CE certification with our professional, efficient and approachable service.