USA Market Access for Electrical and R&TT Products

July 17, 2019

 

In order to access the market of the USA, products must be approved according to the existing legislation and get the required document of conformity.

 

Electrical and electronic equipment manufacturers planning to sell their products in the United States must ensure that their equipment doesn't interfere electromagnetically with other products or cause harm.

 

The Federal Communications Commission (FCC) is the regulatory body:

 

  • responsible for telecommunications type approvals

  • in charge of the development, enforcement, and implementation of regulations set forth by the Congress in the Communications Act of 1934 and the Telecommunications Act of 1996

  • oversees and enforces requirements for radio devices, per Title 47 of the Code of Federal Regulations (CFR)

 

The Federal Communications Commission regulates interstate and international communications by radio, television, wire, satellite, and cable in all 50 states, the District of Columbia, and U.S. territories. The FCC is also the competent body that sets the rules and technical standards regarding the various types of electronic equipment, including radio frequency, telecommunications terminal, industrial, scientific and medical equipment.

 

The FCC authorization process begins once your product is ready for mass producion and selling to consumers. Your device is tested for possible interference to other equipment, correct radio frequency range, and conformity to other telecommunications requirements. 

 

The FCC has two options for authorization:

 

1. Supplier’s Declaration of Conformity (SDoC)

 

SDoC is a procedure that requires that thу party responsible for compliance ensures that the equipment meets the appropriate technical standards. The responsible party, which must be located in the United States, is not required to file an equipment authorization application with the FCC or a TCB. The equipment authorized under the SDoC procedure is not listed in a FCC database. However, the responsible party or any other party marketing the equipment must provide a test report and other information demonstrating compliance with the rules upon request from the FCC. The testing can be performed at any capable laboratory. It is not necessary to turn to an FCC-accredited laboratory.

 

Under the FCC Rules, equipment that contains digital circuitry and receivers that tune between 30 MHz and 960 MHz, including the receiver portions of transceivers, must comply with the emissions limitations of FCC Part 15B. These limits regulate unintentional emissions from electronic devices, such as microprocessors and digital equipment, opposed to intentional transmitters, like Wi-Fi, Bluetooth, and other radio devices.

 

The SDoC approval process is now used for both Class A and Class B equipment. 

The FCC warning statement must still be on the label or provided with documentation to consumers. The FCC logo is now voluntary.

 

Devices subject to SDoC have the option whether to place FCC ID or not. 

 

2. Certification, also known as FCC ID

 

Certification is the equipment authorization issued by an FCC-recognized Telecommunication Certification Body (TCB) based on the evaluation of the supporting documentation and test data submitted by the responsible party (e.g., the manufacturer or importer) to the TCB. Product testing needs to be carried out in a laboratory accredited by the FCC.

 

The FCC certification covers the following aspects: Radio, EMC, and SAR (Specific Absorption Rate) for “human exposure to electromagnetic fields”. All radio products must be marked with the FCC Identifier (FCC ID), which must be printed on the product.

 

This procedure is required for the equipment that is most likely to interfere with other equipment, signals, and emergency information.

The procedure required for equipment authorization, depends on the FCC Rule Part(s) that apply to the radio frequency functions. In some cases, the device could have different functions and, as a result, would need more than one type of the approval procedure. 

 

 

Telecom approval

 

The Administrative Council for Terminal Attachments (ACTA) is the regulatory body established to:

 

  • adopt technical criteria and act as the clearing-house, publishing technical criteria for terminal equipment developed by ANSI-accredited standards development organizations

  • establish and maintain a registration database of equipment approved as compliant with the technical criteria

 

For ACTA Part 68 Database purposes, terminal equipment that requires formal Approvals testing for “do not harm” requirements including but not limited to: 

 

1. Single-line or Multi-line Telephones

2. Modems (any device that is or contains an analog, digital or Ethernet modem used as an interface to the network)

3. Facsimile Machines

4. xDSL Modems (ex. ADSL, HDSL, VDSL & GDSL)

5. DSL Splitters & Filters

6. Voltage Transient Protective devices

7. Electronically Controlled Line Switches, Indicators and Devices

8. Private Branch Exchanges (PBXs)

9. Key Telephone System (KTS) equipment;

10. Local Area Network (LAN) Gateways to the PSTN

 

Supplier’s Declaration of Conformity (SDoC) and compliance to CFR Part 68 are required. SDoC is a procedure where the responsible party takes steps necessary to ensure that the terminal equipment complies with FCC CFR 47, Part 68 and ACTA-adopted technical criteria. 

 

 

Safety approval

 

The Occupational Safety and Health Administration (OSHA) developed the Safety and Health Information Bulletin (SHIB) to enhance understanding of standards related to OSHA's Nationally Recognized Testing Laboratory (NRTL) Program.

 

A number of OSHA standards contain requirements for "approval" of specific products by the NRTL. The NRTL's approval process generally consists of testing, inspection, and certification of a product by the NRTL.

 

The OSHA standards do not specify the safety requirements that products must meet. These requirements are specified by U.S. standards-developing organizations.

 

Nationally Recognized Testing Laboratories (NRTLs) are third-party organizations recognized by OSHA as having the technical capability to perform safety testing and certification of particular types of products.

 

After certifying a product, the NRTL authorizes the manufacturer to apply the NRTL's registered certification mark on the product.

 

Categories of equipment (products) are required to be approved by a NRTL, per provisions of the General Industry Standards (Part 1910 of Title 29, Code of Federal Regulations) can be found here.

 

 

Energy Efficiency

 

The U.S. Department of Energy (DOE) is the regulatory body authorized to enforce compliance with the energy conservation standards. To ensure the implementation of the current standards for covered appliances and equipment, the DOE published certification, compliance, and enforcement regulations for such products and equipment in the Code of Federal Regulations (CFR) at 10 CFR part 429.

 

The Building Technologies Office of the U.S. DOE develops test procedures and standards and enforces regulations to ensure that manufacturers produce products that are compliant with Federal Regulations through the Appliance and Equipment Standards Program. The program sets minimum energy conservation standards for appliances that are used by consumers each day and currently covers more than 60 different products.

 

In addition, DOE’s test procedures are used for the US Federal Trade Commission’s (FTC) EnergyGuide labeling program and for voluntary ENERGY STAR program. The Appliance and Equipment Standards Program supports the voluntary ENERGY STAR program by working with the Environmental Protection Agency to ensure products that display the label meet Energy Star specifications.

 

Minimum Energy Performance Standards (MEPS) are required for product categories that require mandatory labelling include:

 

  • Ballasts

  • Freezers    

  • Water heaters

  • Heaters

  • Fluorescent lamps

  • Room air conditioners

  • Clothes washers

  • Refrigerators, etc. 

 

Full list of product that are in scope of energy efficiency regulations can be find here.

 

Before distributing any basic model of a covered product or equipment subject to an applicable energy conservation standard, manufacturers must submit a certification report to the DOE conforming that each basic model meets the applicable energy conservation standard(s).

 

Mandatory Energy Guide labelling is required for certain products. The DOE’s test results must be printed on yellow EnergyGuide label, which manufacturers are required to display on many appliances. Manufacturers of major home appliances are required to attach the labels to their products under the FTC’s Appliance Labeling Rule. The labels show the highest and lowest energy consumption or efficiency estimates of similar appliance models. The Rule also requires energy disclosures for certain lighting products and water use labeling for certain plumbing products.

 

The Energy Star Program is a similar labeling program, but it requires more stringent efficiency standards for an appliance to become qualified.However, it is a voluntary program. The Department of Energy (DOE) and the Environmental Protection Agency (EPA) are lead agencies in the development and revision of all test procedures for products in the “ENERGY STAR Program”, including those products that are also subject to DOE's Energy Conservation Standards program. 

 

 

ROHS

 

The European RoHS directive (2011/65/EU) does not directly applicabe in the US. However, several states have enacted legislation, which you need to be aware of in case the product is sold in those states. The following State Directives require that covered electronic devices sold in the specific state must meet the same requirements as those found in European Union’s RoHS legislation:

 

  • California - the Electronic Waste Recycling Act 2003 (CP65)

  • New Jersey’s Electronic Waste Recycling Act (NJAC 13:1E-99.94 et seq.)

  • Illinois Electronic Products Recycling and Reuse Act

  • Indiana code 13-20.5-1-1

  • Minnesota Statute Chapter 115A.13142

  • New York’s Electronic Equipment Recycling And Reuse Law

  • Under Rhode Island’s Electronic Waste Prevention, Reuse and Recycling Act

  • Wisconsin Statute Chapter 287.17

The information has been prepared by the GMA Consult Group team.

 

GMA Consult Group provides a full cycle of international type approval and global market access services for IT, Telecom and industrial electrical products in all countries throughout the world. With proven expertise in worldwide regulations, compliance, certification, and conformity assessment, GMA Consult Group can help your company speed up the access to any market with almost zero efforts from your side.

 

Need your own guide to the world of certification and approvals? Don't hesitate to contact us via info@gma.trade.

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