Test Reports and Test Data Acceptance for Certification

Certification Evaluation Overview

1. This document provides an overview of ACB’s certification process in order to determine if test reports and test data, as submitted by applicants/customers, can be accepted for the purpose of certification for the following Recognizing or Regulatory Authority certification schemes:
   • FCC certification
   • ISED (Innovation, Science and Economic Development) Canada certification
   • The issue of an EU-type examination certificate from the NB for the EU Radio Equipment Directive 2014/53/EU
   • The issue of an EU-type examination certificate by the Notified Body for the EMC Directive 2014/30/EU
   • The issue of an EU-type examination certificate by the Approved Body for the UK Radio Equipment Regulations 2017 (S.I. 2017/1206)
   • The issue of an EU-type examination certificate by the Approved Body for the UK Electromagnetic Compatibility Regulations 2016 (S.I. 2016/1091
   • Certification by the RCB in accordance with the Radio Law (Japan).
   • Certification to certain Hong Kong OFCA HKCA 1XXX standards. (Limited to HKCA 1XXX Specified on ACB’s currently accredited scope).
2. ACB provides equipment Certification or Conformity Assessment. ACB accepts applications for Certification or Conformity Assessment from ISO/IEC 17025-accredited testing laboratories, appropriately-listed laboratories, and other approved sources. Submittors must file electronic copies of applications to ACB for review and, if eligible, approval.
3. Under the regulatory schemes listed above, ACB reviews and provides equipment Certification or Conformity Assessment for approved applications submitted to ACB. The technical expertise provided by the reviewers and technical staff ensures that test reports and applications submitted will comply with the necessary technical and administrative requirements under the Applicable Recognizing or Regulatory Authority regulation scheme.
4. Personnel assigned to the Review and Certification Body process are qualified to perform the tasks for the specific evaluation.  Personnel will not be assigned if they have been involved in, or been employed by a body involved in, the design, manufacture, supply, installation, purchasing, owning, use or maintenance of such products in a manner and within a 6-month time period that could conflict with impartiality, confidentiality or objectivity. Personnel assigned applications they should not review will immediately inform managements for reassignment.
5. Submissions to ACB are reviewed according to approved parties Administrative and Technical Review Procedures. The Review and Certification Body processes are used to ensure that submitted applications meet the required acceptance criteria for Certification or Conformity Assessment under Applicable regulations.
6. Applications can be withdrawn under the following situations: customer requests cancellation by submitting in writing; Recognizing or Regulatory Authority (RRA) sends notification to ACB that the approval has been withdrawn, due to apparent inconsistencies with applicable standards.
7. ACB will close applications after 60 days if additional required files are not received for the certification effort, Request for Technical information (RT’s) or surveillance audits.  No refunds will be given if ACB has begun the work.  All applicable documentation is stored within the application on ACB’s website.
8. ACB’s Quality Assurance and the Information Technology staff are responsible for maintaining ACB’s website database.
9. ACB maintains a complete up to date list of procedures used to determine eligibility for Certification or Conformity Assessment.
10. The ACB Certification Body and/or CAB Authority are composed of an individual(s) authorized and approved by the Board of Directors of ACB.
11. The ACB Certification Body and/or CAB Authority will be responsible for decisions relating to the granting, maintaining, extending, reducing, suspending and withdrawing of certification or conformity assessment, where applicable.
12. The Certification Body and/or CAB Authority will be responsible for performance of testing, inspection, evaluation, and certification as defined in ISO/IEC Guides 17065 and 17025, including matters relating to subcontracting of testing and reviewing processes.
13. In the absence of a harmonized standard and other nominative document/directive, ACB senior engineers will confer and develop a review procedure based on their review and certification experience of similar technology that may apply to the product for review of which, there are no harmonized standards.
14. All applications will be filed in electronic format to ACB. A flowchart of the Certification process is shown below.
    • Submitter sends application to ACB through the website e-file system. Internally, an e-mail is sent from the e-file system to ACB staff indicating new application is available.
    • ACB Invoices Client and funds are deposited in ACB account. Clients prepay all application fees. Exceptions exist based on individual agreements. Special Payment Terms are arranged by Director of Finance or his/her designee.
    • Application is assigned by authorized person to Reviewing Body and Certification Body
    • Reviewing body performs administrative review. Request for information is sent to client, if necessary. Time to respond is 60 days or application may be dismissed.
    • Reviewing body performs technical review. Request for information is sent to client, if necessary. Time to respond is 60 days or application may be dismissed.
    • Request for sample is conveyed, if warranted. Sample testing is performed based on standards and procedures of Recognizing or Regulatory Authority.
    • If necessary, requests for additional information (technical or administrative) are made of the Submitter and the Applicant. 60 Day time limit for reply. The application is dismissed if information is not provided in a timely fashion, or if information does not support technical basis for Certification.
    • When all information is satisfactory, the application is referred to the Certification Body with the recommendation for Certification.
    • Certification Body (CB) reviews Application and if satisfactory, grants Certification. If Application is found to be faulty by the Certification Body, Application is returned to Reviewer.
    • ACB issues Grant or Certificate to client and Uploads Required Documentation to Recognizing or Regulatory Authority.  When the client requests that a Grant or Certificate be held until they request release, the reviewer will re-review the device prior to release for compliance to any recent RRA changes to certification rules and regulations.
15. Note: CB Function are not performed by same person who evaluates application. ACB certification process consists of a senior staff member assigning the application to a Reviewing body and a Certification body.  During the assignment of the application the Application Review is performed, as defined in ISO/IEC 17065 Section 7.3.  The Reviewing body performs the function of Evaluation, as defined in ISO/IEC 17065 Section 7.4.  The Certification body performs the functions of Review and Certification Decision, as defined in ISO/IEC 17065 Sections 7.5 and 7.6, respectively.  The same process is followed for each scheme for which ACB is accredited. Upon request, the Applicant or submitter will be provided with a checklist and necessary forms to submit the application to ACB. These are found on the ACB Website. Test reports and test data acceptance for specific RRA’s are noted below.

Test Report Acceptance

After July 12, 2017, all devices applying for FCC certification must be tested at measurement facilities that have been recognized by the FCC as being accredited to ISO/IEC 17025 and the appropriate FCC requirements and that have the proper scope for the equipment for which certification is requested. This is reviewed via the test firm section of the FCC OET Laboratory Division Equipment Authorization System (EAS) website.

1. Test reports and test data acceptance for obtaining FCC certification

1. • After July 12, 2017, all devices applying for FCC certification must be tested at measurement facilities that have been recognized by the FCC as being accredited to ISO/IEC 17025 and the appropriate FCC requirements and that have the proper scope for the equipment for which certification is requested. This is reviewed via the test firm section of the FCC OET Laboratory Division Equipment Authorization System (EAS) website.
   • Regarding 17025: Note that accreditation to 17025 in and of itself is not sufficient as the test lab must also be recognized by the FCC as well as listed on the FCC site. All testing, including testing by external resources and subcontracted testing, must be performed at an accredited test facility that is recognized by the FCC. It is not permitted for a TCB to accept test reports for which an FCC recognized accredited testing laboratory did not perform the testing, but instead only reviewed testing completed at a non-recognized site, without full re-test. When filing an application for certification, the TCB is required to enter the name of the test site from the list of recognized test sites, as shown in the Equipment Authorization System. If a product was tested at more than one site, the test report(s) should specify what tests were performed at which locations.
   • Regarding Locations/Addresses: While the above is regarding acceptability of the test lab in general, the location and/or address must also be covered by the FCC site. If the lab has multiple locations, the location used should somehow be reflected on the FCC site itself to be considered acceptable. Some labs have had to update the FCC site to cover their specific instances.
   • Regarding Scopes of Lab: In addition to 17025 and location requirements mentioned above, the acceptability of the test data must then be determined by reviewing the approved scopes of the laboratory, as listed on the FCC website, against the application and what was tested. If the scopes listed on the FCC website do not cover the equipment tested, the lab would need to expand their listed scopes to do so before we could finally accept the data.
2. Test reports and test data acceptance for obtaining ISED (Innovation, Science and Economic Development) Canada certification
   • After March 15, 2019, all devices applying for ISED certification are required to be tested at measurement facilities that have been recognized by the ISED as being accredited to ISO/IEC 17025 and also have the appropriate ISED scope for the equipment for which certification is requested. This is reviewed via the “Wireless Test Site” section of the ISED Equipment Certification and Registration Services webpage.
   • Regarding 17025: Note that accreditation to 17025 in and of itself is not sufficient as the test lab must also be recognized by ISED as well as listed on their site. All testing, including testing by external resources and subcontracted testing, must be performed at an accredited test facility that is recognized by ISED. It is not permitted for a TCB to accept test reports for which an ISED recognized accredited testing laboratory did not perform the testing, but instead only reviewed testing completed at a non-recognized site, without full re-test. When filing an application for certification, the TCB is required to enter the lab number associated with the test site and validate the name pulled from ISED’s database. If a product was tested at more than one site, the test reports should specify what tests were performed at which locations.
   • Regarding Scopes of Lab: In addition to 17025 and location requirements mentioned above, the acceptability of the test data must then be determined by reviewing the approved scopes of the laboratory, as listed on ISED’s website, against the application and what was tested. If the scopes listed on ISED’s website do not cover the equipment tested, the lab would need to expand their listed scopes to do so before ACB could finally accept the data.
   • Test reports for the purpose of certification which contain Specific Absorption Rate (SAR) test data can only be accepted by ACB where the test firm which performed the SAR measurements and issued the SAR test report is properly registered on the ISED Canada website in the Spectrum Management System section as a registered SAR test firm.
   • SAR test firms are encouraged to contact ISED Canada in order to make sure that they are properly registered in the Spectrum Management System section of the ISED Canada website prior to submitting applications which contain SAR test report(s) to ACB for the purpose of ISED Canada certification and where the SAR test firm has never attempted to register their SAR test facilities at the Spectrum Management System section of the ISED Canada website.
3. Test reports and test data acceptance for obtaining an EU-type examination certificate from the NB for the EU Radio Equipment Directive 2014/53/EU
   
   • ACB accepts test reports for the purpose of certification which have been issued by test firms which may, or may not, be accredited by a member of ILAC (http://www.ilac.org). However, in those cases where the test firm is not accredited by a member of ILAC, or in those cases where the scope of the accreditation does not appear to cover all test data, ACB reserves the right to make inquiries about test procedures used, test equipment used, calibration status of test equipment and facilities, etc. where ACB deems such inquiries necessary in order to assess the validity of reported test results.
4. Test reports and test data acceptance for obtaining an EU-type examination certificate from the NB for the EU EMC Directive 2014/30/EU
   • ACB accepts test reports for the purpose of certification which have been issued by test firms which may, or may not, be accredited by a member of ILAC (http://www.ilac.org). However, in those cases where the test firm is not accredited by a member of ILAC, or in those cases where the scope of the accreditation does not appear to cover all test data, ACB reserves the right to make inquiries about test procedures used, test equipment used, calibration status of test equipment and facilities, etc. where ACB deems such inquiries necessary in order to assess the validity of reported test results.
5. Test reports and test data acceptance for obtaining a type examination certificate from the AB for the UK Radio Equipment Regulations 2017 (S.I. 2017/1206)
   • ACB accepts test reports for the purpose of certification which have been issued by test firms which may, or may not, be accredited by a member of ILAC (http://www.ilac.org). However, in those cases where the test firm is not accredited by a member of ILAC, or in those cases where the scope of the accreditation does not appear to cover all test data, ACB reserves the right to make inquiries about test procedures used, test equipment used, calibration status of test equipment and facilities, etc. where ACB deems such inquiries necessary in order to assess the validity of reported test results.
6. Test reports and test data acceptance for obtaining a obtaining a type examination certificate from the AB for the UK Electromagnetic Compatibility Regulations 2016 (S.I. 2016/1091)
   • ACB accepts test reports for the purpose of certification which have been issued by test firms which may, or may not, be accredited by a member of ILAC (http://www.ilac.org). However, in those cases where the test firm is not accredited by a member of ILAC, or in those cases where the scope of the accreditation does not appear to cover all test data, ACB reserves the right to make inquiries about test procedures used, test equipment used, calibration status of test equipment and facilities, etc. where ACB deems such inquiries necessary in order to assess the validity of reported test results.
7. Test reports and test data acceptance for obtaining Radio Law (Japan) certification from the RCB
   • ACB accepts test reports for the purpose of certification which have been issued by test firms which may, or may not, be accredited by a member of ILAC (http://www.ilac.org). However, in those cases where the test firm is not accredited by a member of ILAC, or in those cases where the scope of the accreditation does not appear to cover all test data, ACB reserves the right to make inquiries about test procedures used, test equipment used, calibration status of test equipment and facilities, etc. where ACB deems such inquiries necessary in order to assess the validity of reported test results.Pursuant to Article 38-3 (1) i) of the “Radio Law” ACB reserves the right to make inquiries about the competency of personnel of the test firm where ACB deems such inquiries necessary in order to assess the validity of reported test results: 
   • As stipulated in the “Radio Law”, Article 24-2 (4) and Article 38-3 (1) ii), calibration of test equipment must be traceable and the calibration interval should not exceed the period of 1 year.
   • Article 24-2 (4): 
   • Article 38-3 (1) ii): 
   • Information about the calibration of test equipment and which address the two cited articles above must be included in the test report.

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