ACMA legislation

[LukeW]

I want to nut out the process to get RCM for some bespoke radio gadgets.

We're talking about LIPD spread spectrum and digital modulation type stuff, low power, about +20 dBm or so, 2.4 GHz e.g. Wi-Fi, Bluetooth and 802.15.4, along with LoRa and Sigfox at 920MHz. Possibly 5.8 GHz WiFi as well. We're talking about fairly standard designs with common RF SoCs for these protocols.

The relevant frequency classes, within LIPD / AS4268:

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915-928 MHz Frequency hopping and Digital Modulation transmitters
1W EIRP. Minimum 20 hopping frequencies.
For digital modulation, radiated peak power spectral density in any 3 kHz is limited to 25 mW per 3 kHz.
The minimum 6 dB bandwidth must be at least 500 kHz.

2400-2483.5 MHz Frequency hopping and Digital Modulation transmitters
4W EIRP. Minimum 75 hopping frequencies.
For digital modulation, radiated peak power spectral density in any 3 kHz is limited to 25 mW per 3 kHz.
The minimum 6 dB bandwidth must be at least 500 kHz.

5150-5250 MHz Indoor RLAN
200mW EIRP averaged over the entire transmission burst.
If the emission bandwidth is 1MHz or greater, the radiated power spectral density in any 1MHz is limited to 10mW per MHz.
If the emission bandwidth is less than 1 MHz, the radiated power spectral density in any 4 kHz is limited to 40 uW per 4 kHz.
All devices shall use Dynamic Frequency Selection and Transmit Power Control.
If TPC is not used then the maximum EIRP is limited to 100mW.

5250-5350 MHz Indoor RLAN
200mW EIRP averaged over the entire transmission burst.
If the emission bandwidth is 1MHz or greater, the radiated power spectral density in any 1MHz is limited to 10mW per MHz.
If the emission bandwidth is less than 1 MHz, the radiated power spectral density in any 4 kHz is limited to 40 uW per 4 kHz.
All devices shall use Dynamic Frequency Selection and Transmit Power Control.
If TPC is not used then the maximum EIRP is limited to 100mW.

5470-5600 and 5650-5725 MHz RLAN
1W EIRP averaged over the entire transmission burst.
If the emission bandwidth is 1MHz or greater, the radiated power spectral density in any 1MHz is limited to 50mW per MHz.
If the emission bandwidth is less than 1 MHz, the radiated power spectral density in any 4 kHz is limited to 200 uW per 4 kHz.
All devices shall use Dynamic Frequency Selection and Transmit Power Control.
If TPC is not used then the maximum EIRP is limited to 500mW.

Short Range Devices (i.e. LIPD class license devices, they're basically synonymous since we're ignoring the part that deals with RC toys) covered under the Radiocommunications (Short Range Devices) Standard 2014 are in Compliance Level 1.

For Level 1 compliance, under the Radiocommunications (Compliance Labelling – Devices) Notice 2014, the supplier of a device must prepare a description of the device and complete and sign a declaration of conformity for the device. Notably, evidence such as test reports is not mandated for Level 1 compliance. Though Compliance level 1 (low-risk device) does not require a supplier to hold a test report, the supplier should be confident that the device complies with the applicable standards.

I want to avoid paying an outside lab except where absolutely necessary. I have an 8 GHz SA, and will verify bandwidth, TX power and frequency, absence of spurs and harmonics and power spectral density.

Now, the Radiocommunications (Short Range Devices) Standard 2014 really just points to AS/NZS 4268.

(Don't even get me started on bloody Australian Standards. The law is not some proprietary IP owned by a private corporation that charges you hundreds of dollars to read it, and if the government can't provide the law for the citizens to freely read, then it surely cannot be considered the law. But I digress.)

Also refer to the LIPD Class License Determination. The operation of short-range spread spectrum and digital modulation devices is authorised under the Radiocommunications (Low Interference Potential Devices) Class Licence 2000. Note that the LIPD Class License Determination and AS/NZS 4268 are essentially identical.

AS/NZS 4268 specifies that the equipment should be designed, constructed and manufactured in accordance with sound engineering practice and with the aim of minimising harmful interference to other equipment and services. Transmitters and receivers may be individual or combination units. OK.

Any adjustment mechanism that could enable the equipment’s performance to be altered so that the requirements of this Standard are not met shall be contained within the housing of the equipment and shall not be externally accessible. Any means of programming the equipment that could enable the equipment’s performance to be altered so that the requirements of this Standard are not met shall be protected from end user access. The equipment shall default to a mode compliant with the requirements of this Standard if a reset occurs.

If testing is performed, AS/NZS 4268 specifies FCC testing protocols - 47 CFR Part 15, Radio Frequency Devices (Intentional Radiators) - as acceptable tests.

The upper and lower frequency limits of the transmitter 99% emission power bandwidth shall at all times remain within the operating frequency limits. OK.

The devices are not designed for on-body portable or handheld use - i.e. not a mobile station under the Radiocommunications (Electromagnetic Radiation — Human Exposure) Standard 2014 and the EMR regulatory standard does not apply.

LIPD compliance with Prescribed Australian Radioastronomy Sites (SKA Pathfinder, Tidbinbilla, Parkes etc) are OK - won't be near them.

Is any device with an ethernet port considered a customer telecommunications equipment or customer cabling regulated under the Telecommunications (Labelling Notice for Customer Equipment and Customer Cabling) Instrument 2015?

The Radiocommunications (Compliance Labelling – Devices) Notice 2014 does not apply to a device that is imported or manufactured otherwise than for supply in Australia. What does such a lack of supply mean? Does this exempt a device imported or manufactured for "personal use", without supply to another person or entity?

With technical compliance demonstrated at the level required, the Declaration of Conformity, supplier registration and product RCM marking are then able to be done.

Does this sound right? Does it tick the right boxes that are required?

[cdev]

"The law is not some proprietary IP owned by a private corporation that charges you hundreds of dollars to read it, and if the government can't provide the law for the citizens to freely read, then it surely cannot be considered the law."

[/b]

Thank you for bringing attention to this problem, which effects many different areas of society today. It really needs to be the law everywhere.

There should never be any cost standing in the way of people getting this kind of information.

[Kerlin]

Never understand that lot.
I know heaps about compliance and have done hundreds of products as required, at great cost.
They impose all this officious, draconian, authoritarian stuff on our local companies and let rubbish from other places pour in by the ship load.
Just useless time and money wasters.
Whish I could be free to tell a story that their own investigation branch confirmed.
I took my technology overseas where the Taiwan government supported me and I came up with a world first.
Now Australia pays to import it.
You will bust yourself trying to do it here, suggest the easiest way is to go over there and complete it.
There are many cheap "friendly and co-operative" test houses there too.