Approval Specialists Forum and Blog

The mandatory human exposure standard in Australia is the Radiocommunications (Electromagnetic Radiation – Human Exposure) Standard 2003 (EMR Standard) with its amendments and applies to most mobile and portable radiocommunications transmitters operating in the 3kHz to 300GHz frequency range.

The EMR Standard differentiates between devices used by an aware user (generally understood to be a device used in a controlled environment by professional or trained users), and a non-aware user (generally understood to be a device that is used in an uncontrolled environment by the general public or untrained users).  Controlled environments could be restricted areas where EMR hazard prone areas are clearly demarcated and/or have warning labels displayed.

Such devices have to comply with their respective Compliance Levels depending on the device Category (either A or B) they fall into (defined in the EMR Standard), as detailed below:

Compliance Level 1 Devices

 This applies to Category A devices only, i.e. a device that is an aware or non-aware user device, and not required to be evaluated under Sections 5.2 and 5.3 of Schedule 5 of the ARPANSA standard (relevant ARPANSA RPS3 extracts are provided below).

 S5.2.2 Equipment with mean power output not exceeding 100 mW (regarding aware user devices).

The evaluation of mobile or portable transmitting equipment for compliance with this Standard is not required where the nominal mean power output delivered to the antenna does not exceed 100mW.

S5.2.3 Equipment with mean power output exceeding 100 mW (regarding aware user devices).

The evaluation of mobile or portable transmitting equipment for compliance with this Standard is not required where:

(a) it operates on a push-to-talk basis;

(b) it is used by an aware user;

(c) it is operated with a transmit duty factor of 50% or less averaged over a six minute period;

(d) it does not exceed the power levels of Table S2 (in ARPANSA RPS3); and

(e) normal operation entails the antenna or other radiating structure being separated from the user’s body by not less than 2.5cm.

 S5.3.2 Equipment with mean output power not exceeding 20 mW (regarding non-aware user devices).

The evaluation of mobile or portable transmitting equipment for compliance with this Standard is not required where the nominal mean power output delivered to the antenna does not exceed 20 mW.

S5.3.3 Equipment with mean output power exceeding 20 mW (regarding non-aware user devices).

The evaluation of mobile or portable transmitting equipment for compliance with this Standard is not required where:

(a) it operates on a push-to-talk basis;

(b) it is operated with a transmit duty factor of 50% or less averaged over a six minute period;

(c) it does not exceed one fifth (20%) of the power levels of Table S2 (in ARPANSA RPS3); and

(d) normal operation entails the antenna or other radiating structure being separated from the user’s body by not less than 2.5cm.

The evaluation of mobile or portable transmitting equipment for compliance with this Standard is not required where the output power delivered to the antenna does not exceed the levels of Table S2 and normal operation entails the antenna or other radiating structure being from the user’s body by not less than 20 cm.

In essence, devices with a mean output power less than 100mW (for aware user devices) / 20mW (for non-aware user devices) are deemed to comply without the need for further testing.  Where devices exceed these power levels, they can still be deemed to comply if they meet the respective criterion of S5.2.3 or S5.3.3 depending on the intended usage environment of the device.  Examples of Compliance Level 1 devices are analogue cordless phones, handheld CB radios used for recreational or domestic purposes, remote garage door openers and the like.

 To comply with compliance level 1, the supplier of a device must:

(a) prepare a description of the device; and

(b) make a declaration of conformity for the device.

 Compliance Level 2 Devices

 This applies to a Category B device (i.e. not a Category A device) for which the normal position of use is more than 20cm from the human body.

 Such device are assessed in accordance with AS 2772.2 standard, which uses a calculated approach, taking into account the transmitter power to the antenna, the antenna gain, and the intended distance of the antenna from the human body.

Typically, examples of such devices or system comprising the transmitter connected to a transmitting antenna would be radio broadcast transmitters, cellular (GSM/UMTS) transmitters, transmission relay stations and the like.

 To comply with compliance level 2, the supplier of a device must:

(a) comply with compliance level 1; and

(b) show conformity with the applicable standard by a report of the results of assessment.

 Compliance Level 3 Devices

 This applies to a Category B device (i.e. not a Category A device) for which the normal position of use is within 20cm from the human body.

 For devices that are used in close proximity to the human ear (e.g. mobile phones), measured SAR levels need to be in accordance with EN 62209-1 method.  Any other SAR measurement method is not acceptable to demonstrate compliance with the Australian Radiocommunications (Electromagnetic Radiation – Human Exposure) Standard 2003.

 For devices not used in close proximity to the human ear, but within 20cm of the human body (e.g. body worn devices that are not Category A devices), the measurement method to be applied is as detailed in Schedule 2 of the Australian Radiocommunications (Electromagnetic Radiation – Human Exposure) Standard 2003.

Examples of such devices are our mobile phones, digital cordless phones and the like.

 To comply with compliance level 3, the supplier of a device must:

(a) comply with compliance level 1; and

(b) show conformity with the applicable standard by a report of the results of assessments by an accredited testing body.

Approval Specialists and Austest Laboratories provide low cost report evaluations to determine if existing test data meets local requirements.

Ultra-Wideband (UWB) devices have the ability to transmit at low output power levels over a broad range of the radiocommunications spectrum and are best suited for short range communications/applications.  As such, they are muted as the next advance in wireless short distance applications such as “wireless USB” and may be considered to have greater application use over many existing uses of Bluetooth(tm). 

Given their broad spectrum of transmission and the future possibility of numerous UWB devices in home applications, there is the potential for interference with existing radiocommunications services or other home devices, once multiple UWB devices are operating in the 1 location.  This is due to multiple devices increasing the ambient “noise floor” within a specific environment.  While 1 UWB device may have transmissions that sneak under the EMC CISPR emission noise floor for a Class B device, there’s no doubt that multiple devices will have an additive effect.

It can be argued that electronic devices in European homes and businesses are well equipped to handle noise via the EMC immunity test requirements of the CE Marking EMC Directive. 

This is not the case in Australia or New Zealand, where the ACMA and NZ MED do not require immunity testing of products.  Previous (dubious) arguments for not invoking EU style EMC Immunity requirements in Australia and New Zealand have included the less densely populated nature of Australian and New Zealand communities compared with those in Europe.   This argument becomes invalid when there are so many products in a home competing for the same limited transmission spectrum (typically from 900MHz to 4GHz).

The use in each home of multiple UWB devices, 802.11a/b/g/n, Zigbee, Bluetooth, 2G, 3G, Femtocells and soon 4G, creates a huge potential for interference issues that remain unaddressed by the ACMA’s current and banal C-Tick regime for general products and LIPDs.      

Contact our Australian lab for EMC emission testing of a wide range of products or LIPD testing to AS/NZS4268 for 802.11x/Bluetooth/RKE/RF devices.

The ACMA have produced a discussion paper on UWB with the closing date for submission on 7 June.  Further information can be found here.

In a clear wake up call to other energy efficiency regulators, the United States Department of Energy have from April 14, changed their requirements for MEPS registration of products under the Energy Star program.  “The EPA has strengthened its approval systems and is no longer relying on an automated approval process.   Companies are now required to submit complete lab reports and results for review and approval by EPA prior to labeling.  All new qualification applications will be reviewed and approved individually by EPA. ”

The certification process will be further strenghtened at the end of the year when only test results from approved, accredited labs will be accepted as evidence of compliance. 

For A2LA (The American Association for Laboratory Accreditation) accredited MEPS testing, contact our Australian lab www.austest.com.au

CeBIT (Sydney Exhibition Centre, 24^th-26^th May, 2010) is Australasia’s leading Business Technology Event and we’re excited to be exhibiting again this year for the 5th time.

For international compliance issues, our Stand G40, Hall 3 (near the rear Café) will have Ms Chun Kim, director of Approval Specialists Inc, who can provide detailed responses to questions on Asia-Pacific and Latin-South American Approvals and in particular, exporters interested in China and South Korea.  

We have a limited number of free passes available, email Austest@austest.com.au.