INTRODUCTION:
Have you ever manufactured devices that are very similar to one another, and you would like to save time and expenses?
If the answer is yes, then this blog will be extremely useful. In today’s blog we will be explaining another alternative that can be a very useful tool for your international regulatory compliance needs, the Family Type Approval.
CONCEPTS:
Before explaining the family approval concept, in case you haven’t seen our Blog WHAT IS RF MODULAR APPROVAL? Then please let us briefly explain RF or Radio Type Approvals (also referred to as homologation):
The radio type approval is a mandatory procedure (in most countries) in which the designated country authority reviews technical and commercial information such as test reports, user manuals, internal pictures, external pictures, datasheets and more, and confirms that a product complies with the minimum set of regulatory and technical requirements and declares that the device can operate in the country without causing interference or breaching the provisions of its national frequency plan.
Okay now getting down to business, basically, RF Family Type Approval, like its name states, is the process to get one type approval certificate for all products that make up a family or series.
But what can be considered as a family member for regulatory compliance purposes?
Well basically the devices that can enter this VIP group must be electrically and mechanically identical and it is especially important that their radio frequency characteristics are identical.
ADVANTAGES
Less time for the homologation of several devices: instead of making several certifications processes, in the same lead time of one process you can gather a certificate that covers several of your product models.
Lower costs, even though a family type approval may have a slightly higher fee than a regular one model radio type approval process due the regulatory authority’s need of reviewing more documents, compared to the costs that would be incurred by having to separately certify all the equipment that are part of the family, a lot of costs will be saved with the family type approval route.
Efficiency in the creation of technical documentation, this alternative will reduce the amount of product technical documentation because you can issue only one document (one user manual, one datasheet, etc.) that will include several family models. There are some minor format requirements to keep in mind that will be explained in the next point, but in general it is a great alternative for efficiency and to save compliance team efforts.
IMPORTANT POINTS TO KEEP IN MIND
For your family approval to be possible there are some important requirements that must be accomplished:
- The RF functions must be the same, this means that all the devices that will be named on the family certificate must work in the same frequencies, have the same antenna gain, the same output power, etc.
Because we can’t forget that the final purpose of the entities that issue the type approval certificate is to confirm that the device won’t cause interference, harmful frequencies, and will work under the standards stablished by their laws, if the RF functions of the devices in the product family are not the same, under their perspective, they would not be part of the same family, despite the fact that physically, for example, the devices look the same. - All the models must be named in the test report, although this may not be mandatory in all the countries that accept the family approval, it is highly advisable that all the models included in a family certificate are specifically named in your RF test report (and EMC and/or Electrical Safety test report), this is because some countries are not very open to accept family declaration letters.
Another important suggestion is during the issuing the test report you can verify that the values are compliant with the limits established by the different countries and that the report format is compliant with the requirements stablished by each country to avoid future retesting or modification requests to the labs.
We understand that it can be a little complicated to keep all the regulations in the different countries that you would like to comply with in mind, so we also recommend working with third-party consultant with a very deep understanding of the regulations and type approval requirements all over the world, if your internal compliance team does not have this experience. - Documents must be issued naming all the models, this means that for example if you would like to issue one single user manual for all the devices that will be part of the family it is required that the manual mentions the specific models that are part of the family at least in one section.
This would apply for almost all the files that would cover several devices in one, like datasheets, block diagrams, etc.
The only exemption to this would be the pictures. The regulatory authorities usually require separate photos for each model to be included in the family type approval certificate.
LABELLING
As mentioned briefly in the previous point, even though you will be getting one certificate for several devices, it will be very important for you to put the respective model number on the label of the product and that it matches one of the models listed in the certificate exactly.
For example, your certificate mentions the following:
Models: ABC123, DEF456, GHI789, JKL123, MNO456
Your individual product labels would have to show its respective models like in the example below:
Label 1: Model ABC123
Label 2: Model DEF456
Label 3: Model GHI789
Label 4: Model JKL123
Label 5: Model MNO456
It is required that each device has its own label even though they are from the same family, because for importation it wouldn’t be enough for the label to mention “XXXXX Series” or “XXXXX Family”, you can add this for marketing purposes, but it would still be required that you can mention the specific model. This allows for the customs officer to easily confirm the model has prior type approval by comparing the model number listed on the product label to the model number listed on the existing type approval certificate.
MAXIMUM QUANTITY OF DEVICES
There are some countries that allow a maximum number of devices that can be added to a family certificate. For example, Chile allows a maximum of 8 devices when models are identical in terms of RF performance.
The maximum number of devices and some specific country requirements will vary depending on the country and RF Family Type Approval scheme rules.
HOW TO APPLY IT
Ok I know that you might be thinking, all this sounds great and I have several groups of family products, but how can I start?
By following the steps above, you should be well on your way to launching new families or series of similar products into foreign marketplaces and reducing time and resources by following the family type approval scheme.
As mentioned above, we strongly encourage manufacturers to build regulatory compliance teams with international type approval experience. Because this is a very niche industry and experienced employees may be hard to find, third-parties like Approve-IT can act as extensions of your compliance team and support type approval efforts on a global scale. If you do not have in-house experience, then we suggest hiring a third-party to help guide you through the complex type approval landscape.
We encourage feedback and thoughts in the comments section. Thank you!
