Product Compliance Challenges for Wireless Radio Devices in Vehicles

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By Steve Hayes, Technical Director – Connected Technologies, Element

ecause the regulations for radio devices in vehicles are different from the normal Federal Communications Commission (FCC) or European Commission (EC) marking requirements, designers and manufacturers of vehicle wireless devices often struggle to understand what requirements apply to their product and how to ensure compliance. This article gives an overview of common regulatory markings for vehicles and how safety and performance requirements differ for radio devices in vehicles, especially regarding electromagnetic compatibility.

Regulatory & Manufacturer Requirements

Most vehicles on the market today display at least one of these four regulatory marks:

E-Mark: This proves that a vehicle or vehicle component complies with safety regulations, laws, and directives in the European Union. All vehicles sold in Europe must bear an E-Mark, but different countries may have different requirements, so the mark also has a number to indicate which national authority issued it.
CCC Mark: This is a product safety mark that is compulsory for a wide variety of products sold or used in China, including vehicles.

CE mark: A European product safety mark that applies to a wide array of products sold on the European market, including vehicles.
FCC Mark or SDOC (suppliers declaration of conformity): This mark indicates that the product complies with the requirements of the Federal Communication Commission of the United States.

All these are examples of regulatory marks, indicating compliance with rules enforced by a government body, but non-government entities also impose requirements on radio devices in vehicles.

The US, notably, does not have a regulatory mark for radio devices used in vehicles. It is the responsibility of vehicle original equipment manufacturers (OEMs) to ensure the safety of every component they use, so OEMs create their own safety standards. Most US OEM standards include the same regulatory tests required by the E-Mark or FCC Mark, plus additional requirements unique to the manufacturer. These additional requirements are partly to protect their brand integrity, so prestigious brands usually have stricter requirements.

Device Compatibility Challenges

Modern vehicles often incorporate dozens of radio devices, from GPS navigation to tire pressure monitors to proximity sensors. These safety and convenience features are in demand, so manufacturers will only continue to add more. However, the more radio devices you have in a small area, the greater the risk that they will interfere with one another. These built-in devices must operate correctly together, but they must also be compatible with devices in or near the vehicle, like phones, and the radios in other, nearby vehicles.

Interference between radio devices is not just annoying, it can be dangerous, especially in a moving vehicle. Some types of device interference may unintentionally amplify radio frequencies to a level that may be harmful to humans, while other types of interference may cause essential vehicle components to malfunction.

Electromagnetic Compatibility and Vehicle Electronics

Many regulations throughout the world address electromagnetic compatibility (EMC), but depending on the context, the term EMC may refer to compatibility in terms of either safety or functionality. Radio devices in a typical usage environment have fewer safety concerns than those in vehicles. If a set of headphones malfunctions due to electromagnetic interference, this does not cause a safety risk for the user. If, however, an object sensor on a vehicle stops working unexpectedly, this could cause a collision. It is helpful to think of electromagnetic testing for safety reasons as separate from electromagnetic compatibility testing.

For this reason, many EMC regulations don’t apply to vehicles or have separate vehicle-specific requirements. In Europe, for example, the EMC Directive applies to most electronics, but not anything used in a vehicle that is “non-immunity related.” The term non-immunity related means that if the product was to malfunction, it doesn’t compromise the safety of the vehicle. The UNECE R10 standard, required for E-Marking in Europe, specifically addresses vehicle electromagnetic safety testing for people inside and outside the vehicle. Table 1 separates the concepts of electromagnetic safety and electromagnetic compatibility, and illustrates how common testing standards apply in each case.

table illustrating the concepts of electromagnetic safety and electromagnetic compatibility and how common testing standards apply in each case

Table 1: Concepts of electromagnetic safety and electromagnetic compatibility and how common testing standards apply in each case.

To make matters more confusing, vehicle OEM standards and vehicle regulations generally base their test requirements on ISO or SAE standards, which focus on electromagnetic safety, while cellular products typically use FCC, ETSI, or IEC test methods, which focus on electromagnetic compatibility. If a manufacturer produces two mechanically identical radio devices but intends that one be built into a vehicle and one be used in a home, they will likely find that the requirements for testing the vehicle-specific device are much more stringent.

In Europe, the standardization body European Telecom Standards Institute (ETSI) offers a guide that is critical to radio equipment manufacturers and vehicle OEMs, explaining what assessments apply based on the device application. In the US, the FCC provides some instructions on their website for how to gain certification through a certification body.

Navigating Requirements as a Radio Device Supplier

Regulatory and contractual responsibilities need to be negotiated and agreed upon between the equipment supplier and the purchaser to clarify which party is responsible for testing and certification. Radio equipment manufacturers designing for an aftermarket product are responsible for providing accurate and sufficient information to the buyer, so the buyer can ensure they aren’t creating a safety risk by integrating the equipment into a vehicle.

The vehicle manufacturer or integrator also has some responsibility to ensure that the final product is compliant. The vehicle manufacturer should understand if the radio equipment is providing an immunity-related function, which dictates what EMC requirements would apply and if the device has the potential to affect the safe operation of the vehicle.

Essentially, both radio equipment suppliers and vehicle manufacturers share responsibility for understanding how regulations apply to radio devices in vehicles. Although radio devices are now a common feature, this remains a complex area of testing with significant safety ramifications, and compliance is essential.

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Steve Hayes is the Technical Director for the Connected Technologies business unit at Element. His decades of experience and unique technical insight help Element stay at the forefront of testing highly complex and evolving products against regulatory, industry, and carrier-specific global requirements. Steve sits on many national and international committees and regulatory forums, where he lends his expertise to the creation of regulatory standards. To see more of Steve’s articles and recorded webinars or to learn more about Element, visit https://element.com.

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