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AN4804 Application note

How to get your Bluetooth design FCC and BT certified

Sergio Rossi

Introduction In order to sell Bluetooth low energy products in the North American market and the European Union, the equipment must comply with regulatory requirements of the FCC (Federal Communications Commission), the IC (Industry Canada) and the European R&TTE (Radio and Telecommunication Terminal Equipment directive). For Bluetooth devices, Bluetooth compliance and certification is also required.

The Bluetooth Compatibility Certification aims to deliver a seamless user experience through the vast number of Bluetooth mobile devices that are available on the market. This application note presents the fundamentals of the process to release a Bluetooth smart product.

Figure 1: BT product market release requirements

Contents AN4804

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Contents

1 Bluetooth qualification process ..................................................... 3

2 Bluetooth certification process (FCC regulatory domain)............ 6

3 Conclusions ................................................................................... 11

4 Support material and helpful links ............................................... 12

5 Glossary ......................................................................................... 14

6 Revision history ............................................................................ 15

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1 Bluetooth qualification process

In order to release a Bluetooth product to the market, the solution needs to be qualified, which means that conformance must be verified, an IP license must be granted, and logo and word mark usage rights need to be received along with verified interoperability. Effective February 1st, 2014, Bluetooth SIG (special interest group) introduced a streamlined qualification and listing process and revised the fee structure for all new product listings (see link below for details).

https://www.bluetooth.org/en-us/test-qualification/qualification-overview/listing-process-updates

Figure 2: Bluetooth product qualification and certification process

If ST reference designs (e.g. STEVAL-IDB002V1: Bluetooth® SMART board based on the BlueNRG low energy network processor) are strictly followed and the profiles are not changed, customers need not go through the complete qualification process. End product listing (EPL) on the SIG website can be posted free of charge.

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If customers are unsure whether their design “strictly conforms” to requirements, it is recommended to contact a Bluetooth qualification expert (BQE) for advice. The BQE is normally from an authorized testing house, such as 7layers, AT4 Wireless, etc.

The qualification process consists mainly of the following three steps:

Radio qualification

Verify the radio’s conformance to the Bluetooth specification. Radio testing should be performed at a Bluetooth-qualified testing facility (7layers, AT4 Wireless, SGS, UL, etc), and QDID (Qualified Design Identification) obtained. Component or subsystem listing.

Software qualification

Verify the Bluetooth stack’s conformance to the Bluetooth specification. Perform protocol testing at a Bluetooth qualified test facility (or Profile tuning suite, PTS), such as RFCOMM, L2CAP, ATT, etc. Perform profile testing at a Bluetooth qualified test facility (or PTS), such as SPP, A2DP, Proximity, etc. Obtain QDID (qualified Design Identification) from Bluetooth SIG. Component or subsystem listing.

End product listing

The Bluetooth SIG requires that every commercially available product implementing Bluetooth technology be listed in the Bluetooth SIG end product listing (EPL). Creating a product listing on the EPL can be done on the Bluetooth SIG web site. The EPL benefits members by providing a free marketing tool using the bluetooth.com and bluetooth.org websites. The EPL will become the authoritative place for consumers and manufactures to find all qualified Bluetooth-enabled products.

Each member will be required to declare each of their products and the portions of the Bluetooth specification to which they are compliant. Members will then be issued a declaration ID and pay a listing fee. Products using identical or unchanged Bluetooth-compliant portions may appear under the same listing or declaration ID at no additional cost.

After February 1st, 2014, the Bluetooth EPL was no longer free-of-charge, but costs $8000 (adopter members) or $4000 (associate and promoter members) for each listed product. For the latest information, click on the following link:

https://www.bluetooth.org/en-us/test-qualification/qualification-overview/listing-process-updates

Figure 3 shows the STMicroelectronics qualification/declarations & end product listing, available on the SIG web site:

https://www.bluetooth.org/tpg/listings.cfm

For a more detailed explanation of the product type definitions, see Section 3: "Conclusions".

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Figure 3: STMicroelectronics qualified product listing on the SIG website

Bluetooth certification process (FCC regulatory domain)

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2 Bluetooth certification process (FCC regulatory domain)

The FCC is the organization responsible in the USA for implementing rules limiting the potential for interference of licensed operation of low power, non-licensed transmitters. These rules are documented in Part 15 of Title 47 of the FCC. For operation in the 2400 - 2483.5 MHz band (ISM band), a low power, non-licensed device must meet one of the following sub-parts of the regulation:

Part 15.247: devices that operate under the provisions of this section are limited to frequency hopping and digitally modulated schemes

Part 15.249: this sub-part does not impose restrictions on either the modulation scheme or the end application

The FCC classifies Bluetooth BR/EDR as an FHSS system. However, Bluetooth LE (low energy) does not fulfill these requirements. Instead, the FCC classifies Bluetooth LE as a system using digital modulation techniques, documented in Part 15 of Title 47 of the FCC. So this allows the BlueNRG to operate without needing to use a pseudo-random hopping sequence generator.

There are two ways of obtaining FCC certification, either directly from the FCC or through a TCB (Telecommunications Certification Body). For almost all devices, one can chose either to use a TCB or the FCC for certification. The exception is when the equipment uses new technology or when the test methods are undefined or unclear. In this case the FCC is the only party that can provide certification.

The compliance testing process is typically split into three separate categories:

RF

EMC

Safety

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Figure 4: Bluetooth certification process

An end product using a modular certified radio will not need radio certification provided that the restrictions mentioned in the modules grant are met. In other words, customers that will use, for example, one ST module that is already FCC certified (e.g. the X-NUCLEO-IDB04A1) will not need to proceed with the FCC process unless the customer application introduces changes that increase emissions (e.g. different type of an antenna, colocation, RF layout change).

There are several permissive changes (PC)/modifications that can be made to an RF device without the need to file for a new equipment authorization. However, changes to the basic frequency determination and stabilizing circuitry (including clock and data rate), frequency multiplication stages, basic modulator circuit or maximum power or field strength will always require a new FCC ID and new equipment authorization from the FCC. There are three classes of permissive changes:

Class 1: changes that do not degrade the performance reported to the FCC and do not require a modification of the grant – no filing required.

Class 2: changes that degrade the performance reported to the FCC but are still in compliance with the limits and changes to the grant – filing required.

Class 3: changes to software for a software-defined/cognitive radio – filing required

Class 1: changes could be on digital traces. Please note that if there is no filing required, there is still a requirement to document the changes. If uncertain whether the change is a Class1 or Class 2 permissive change, please consult with subject-matter experts prior to requesting guidance from the certification test house/TCB.

Class 2: changes could be chip replacement on portions of the transmitter that perform sub-functions, such as an amplifier chip or an oscillator chip. A class 2 change requires a description of the changes made, a re-test to show that the devices are still in compliance and a test report showing compliance with the rules that need to be provided to the FCC. While a class 2 change requires filing with the FCC, the FCC ID will not be changed.

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The following information must be submitted for FCC certification:

Cover letter

Test report from lab

User manual

Schematics with parts list

Block diagram

Photo of the test setup

Internal/external photos

FCC ID label and placement on the device

Operational description

The following provides a more detailed explanation of the information to be submitted:

Test report from lab

The lab report extract shown below provides a list of the tests necessary to obtain FCC certification for a BLE product.

Figure 5: Lab test item list for FCC certification

In application note AN4378 (available on www.st.com), some of the above tests were completed on ST's STEVAL-IDB002V1 BlueNRG evaluation kit.

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FCC ID label and placement on device

The FCC ID is a 4 to 17-character unique identifier for the equipment and consists of two elements: the Grantee Code and the equipment Product Code. The Grantee Code is a three-character alphanumeric string representing the grantee/applicant. The Grantee Code always begins with an alphabetic character and does not contain the numbers one and/or zero. The Grantee Code is assigned by the commission permanently to a company for authorization of all radio frequency equipment. The Product Code is the non-grantee code portion of the FCC ID that begins after the first three characters. The product code may include hyphens and/or dashes (-). The product code shall consist of a minimum of 1 and a maximum of 14 characters. For example: FCC ID: S9NIDB04A1.

The FFC ID must be permanently marked either directly on the transmitter or on a tag that is permanently affixed to it. The FCC ID label must be readily visible to the purchaser at the time of purchase.

Requirements for ID labels

Requirements for ID labels vary between products and modules. The size of the product may also affect labeling requirements. Two main components are always required for products and modules: each label should contain the FCC ID number and the model number.

Requirements for agency and confidentiality letters

The FCC requires an agency letter signed by the authorized signatory for each company. The letter simply states that the manufacturer acknowledges the appointment of individuals at the test lab to act as its agents in submitting the filing paperwork.

The FCC also requires the applicant to designate any information deemed to be confidential. When filings are complete, confidentiality letters are uploaded as public record and are therefore viewable online.

The FCC offers two types of confidentiality arrangements: permanent and short-term.

Short-term confidentiality is available for all items related to product certification. However, short-term confidentiality is limited to 180 days after the grant of authorization is issued. This essentially allows customers to maintain temporary control over sensitive information prior to the product launch or press release.

Permanent confidentiality is reserved for items or exhibits that are sensitive in nature, such as trade secrets or proprietary information. Some items do not qualify for permanent confidentiality, including test setup photos, external photos and test reports. User manuals and internal photos may receive permanent confidentiality with expanded justification.

It is important that the FCC confidentiality letters match in terms of what is listed as confidential.

Additional technical documents

Additional documentation required for the filing includes the theory of operation, block diagram, schematics and antenna datasheets.

The theory of operation differs from the product description. The theory of operation should provide an overview of how the product or module functions. It should highlight the specifications of the radio, including output power, channels and modulation type.

The block diagram is fairly self-explanatory. This diagram should highlight key components of the product, particularly the radio communication aspect. One important element that must be highlighted includes the crystal frequencies and locations.

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For schematics, the latest revision should be submitted. It is important to include schematics for the entire product in addition to radio-specific portions. Schematics are generally compared against internal photos.

For external antennas, it is also necessary to supply appropriate datasheets.

User manual required

For both product and modular certification, a user manual is required. There are slight differences in requirements for each type of certification. However, key components in each are the FCC warning statements regarding labeling, modifications and RF exposure.

Ancillary information

A few ancillary documents and calculations required for the filing process include the emission designator, external photos, internal photos, test setup photos and MPE/SAR evaluation. Typically this information will be provided by the test laboratory, as it can be determined from test results or taken from test samples.

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3 Conclusions

Bluetooth qualification and certification (FCC) is quite complex. The purpose of this document is to provide an overview of the steps necessary to release a Bluetooth low energy product to the market. As previously stated, it is recommended to consult organizations that specialize in Bluetooth qualification services, such as 7layers and AT4 Wireless.

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4 Support material and helpful links

Product type definitions

Bluetooth end product - An implementation of Bluetooth wireless technology, which implements, at a minimum, all mandatory requirements in radio, baseband, link manager, logical link control and adaptation protocol, service discovery protocol and generic access profile parts of the specification.

Bluetooth subsystem product - An implementation of Bluetooth wireless technology that implements only a portion of the specification in compliance with such portion of the specification and in accordance with the mandatory requirements as defined herein. Bluetooth subsystem products can be qualified solely for distribution and the use of Bluetooth wireless technology in Bluetooth subsystem products require such Bluetooth subsystem products to be combined with a complementary Bluetooth end product or one or more complementary Bluetooth subsystem products such that the resulting combination satisfies the requirements of a Bluetooth end product.

There are three types of Bluetooth subsystem products as defined below:

Bluetooth host subsystem product – A Bluetooth subsystem product containing, at a minimum, all the mandatory requirements defined in the host controller interface, logical link control and adaptation protocol, service discovery protocol and generic access profile parts of this specification, but none of the protocols below host controller interface (HCI). In addition, a Bluetooth host subsystem product may contain, at a minimum, all the mandatory requirements defined in one or more of the protocols and profiles above HCI.

Bluetooth controller subsystem product – A Bluetooth subsystem product containing, at a minimum, all the mandatory requirements defined in the Bluetooth radio, baseband, link manager and HCI parts of this specification, but none of the protocols and profiles above HCI.

Bluetooth profile subsystem product – A Bluetooth subsystem product containing, at a minimum, all the mandatory requirements defined in one or more of the profile specifications.

Bluetooth component product - An implementation of Bluetooth wireless technology that does not meet the requirements of a Bluetooth end product, but implements, at a minimum, all the mandatory requirements of one or more of the protocol and profile parts of the specification in compliance with such portion of the specification. Bluetooth component products can be qualified solely for distribution, and the use of the Bluetooth wireless technology in Bluetooth component products requires such Bluetooth component products to be incorporated into Bluetooth end products or Bluetooth subsystem products. Components are qualified as a “partial" product type to enable end product qualification.

Bluetooth qualification helpful hyperlinks

Introduction to membership:

https://www.bluetooth.org/Membership/benefits.htm

New to the Bluetooth SIG

https://www.bluetooth.org/en-us/members/new-to-the-sig

Getting started with the Bluetooth SIG

https://www.bluetooth.org/en-us/members/getting-started-with-sig

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Become a member

https://www.bluetooth.org/login/register/

Bluetooth qualification and declaration processes

https://www.bluetooth.org/en-us/test-qualification/qualification-overview

EPL – end product list

https://www.bluetooth.org/tpg/listings.cfm

https://www.bluetooth.org/Technical/Qualification/eploverview.htm

CPL – component product list

http://www.bluetooth.com/Bluetooth/technology/Building/Component/

Listing fees

http://www.bluetooth.org/Technical/qualification/fees.htm

QDID – Purchase one

http://www.bluetooth.org/tpg/QLI_obtainQDID.cfm

Qualification FAQs

https://www.bluetooth.org/ticketing/faq.cfm

Specifications

https://www.bluetooth.org/Technical/Specifications/adopted.htm

FCC Certification helpful hyperlinks

FCC parts

http://www.scc-ares-races.org/FCCpartstitles.html

AN4378 Application note: Using the BlueNRG transceiver under FCC title 47 part 15 in the 2400 – 2483.5 MHz band

http://www.st.com/st-web-ui/static/active/cn/resource/technical/document/application_note/DM00098029.pdf

Glossary AN4804

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5 Glossary

BQE: Bluetooth qualification expert

EPL: End product list - the listing database required for all products listed as compliant to PRD 2.X.

PTS: Profile Tuning Suite - software test reference which controls a Bluetooth endpoint to carry out Bluetooth profile tests. The PTS provides members with a means to perform interoperability testing against a tool designed to ensure that interoperability testing requirements are met.

FCC: Federal Communications Commission

MPE: Maximum permissible exposure

QDID: Qualified design ID - an alpha-numeric number provided to the member once the listing fee is received by the SIG

SIG: Abbreviation for Bluetooth SIG. SIG stands for special interest group

TCB: Telecommunications certification body

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6 Revision history Table 1: Document revision history

Date Revision Changes

25-Jan-2017 1 Initial release.

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