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Summary of Key Topics from the October 2025 TCBC Workshop
The October 2025 TCBC Workshop was held on October 21–22, 2025.
This summary highlights the key discussions and regulatory updates presented during the workshop, focusing primarily on topics not covered in other sections.
Due to the workshop taking place during a U.S. government shutdown, most FCC officials were unable to attend. Participation from the FCC was limited to representatives from the National Security Counsel, who primarily addressed the “Bad Labs” issue through overview presentations and Q&A sessions.
The FCC indicated that a separate webinar dedicated to this topic is planned for a later date.
(U.S) “Bad Labs”
- ■ Currently Published and Enforced Policies
- • Test laboratories are disqualified from FCC recognition if a Prohibited Entity holds 10% or more ownership.
- - To date, the FCC has taken action against 11 laboratories.
- • All TCBs and test laboratories are required to report ownership stakes of 5% or greater, including certification of non-ownership.
- - Implementation is currently pending review by the Office of Management and Budget (OMB).
- • Modular transmitters are explicitly included as Covered Equipment.
- • Test laboratories are disqualified from FCC recognition if a Prohibited Entity holds 10% or more ownership.
- ■ Published but Not Yet Applied Policies
The following policies have been discussed but are not currently enforced:- • Prohibition of testing conducted by laboratories located in Foreign Adversary countries
(e.g., China, Russia, Iran, Cuba, Hong Kong). - • Separation of ownership between TCBs and test laboratories, such that:
- - A TCB may not review applications tested by a laboratory with the same ownership structure.
- • Post-market surveillance testing by a TCB would only be permitted for products originally certified by another TCB.
- • Imposition of FCC laboratory accreditation requirements for SDoC equipment
- - This topic is still under internal FCC review.
- • Prohibition of testing conducted by laboratories located in Foreign Adversary countries
(U.S) “Data Referencing”
Under FCC procedures, data referencing may be permitted when a variant device is derived from a fully tested parent device, provided that unchanged RF paths and circuits can be technically justified.
Recent policy changes and clarifications regarding data referencing were discussed as a dedicated agenda item.
- FCC KDB 484596 D01 v02r01 – Oct 23, 2023
- • Requires an ECR (Equipment Compliance Review) procedure to receive FCC`s confirmation
- • Allowed: Variations due to population, or depopulation or replacement of components
- • Certification: Can be new FCC ID or a variant within the same FCC ID (C2PC)
- • Must all be within the same Grantee code
- FCC KDB 484596 D1 v03 – March 21, 2025
- • Back to stricter times, and not so many changes permitted
- • Reference device must be the most fully populated, Variant can only have transmitter de-population
- • No Data reference under the same FCC ID permitted
- • All tests require a spot-check to confirm the justification in the test plan
- • ECR removed, all decision now made by the TCB
(ISED) RSS-248, “Permanently Integrated Antenna”
Under ISED RSS-248, the following device categories require a permanently integrated antenna:
- Low Power Indoor Access Points
- Very Low Power (VLP) devices
- Indoor subordinate devices
The following antenna configurations are considered acceptable:
- Permanently attached antennas
- Unique proprietary connectors
- Standard connectors incorporating an authentication protocol
Important note:
- Reverse connectors that are commercially available or widely distributed online are not permitted.
ISED emphasized that prior inquiry is required when using unique connectors or authentication-based solutions.
KDB Sharing
Both the FCC and ISED provide official channels through their websites for written inquiries and formal responses.
Several useful KDB cases and interpretations suitable for broader industry sharing were introduced during the TCBC Workshop.
1) FRL Calculation (ISED)
[Question]
May I have your guidance on how to provide the correct information to the Spectra system for FRL [Field Reference Level] when this document is generated by the manufacturer themselves?
[ISED Answer]
Please note that FRL calculations can be completed by the client but they must be verified by an ISED recognized test lab. There is no scope for FRL, therefore, any recognized lab can perform this verification. The CN of the test lab needs to be recorded in the field [GC: in Spectra, when uploading the application]
2) SAR Values Reported in Spectra (ISED)
[Question]
When filling out RSS-102 Annex A, should the SAR values reported in RSS-102 Annex A (and therefore, those listed in spectra) be standalone values or simultaneous transmission values? We’ve seen that not all CBs do this in the same way.
[ISED Answer]
Please note that ISED only requires standalone SAR values to be reported.
3) N.S Testing in a C1PC (ISED)
[Question]
We have been approached by a grantee who obtained IC certification for a proximity reader that operates at both 125 kHz and 13.56 MHz in 2015, prior to the requirement for N.S. testing. They would now like to upgrade the firmware in the device (no changes to the authorized emissions) and give it a new HVIN, hence, a Class I Permissive Change would be required.
My questions are, in this situation, would N.S. Testing now also be required for the 125 kHz emission? And, if so, would it still be considered a c1pc, with the inclusion of N.S. data?
[ISED Answer]
All the current RSS requirements for the product are applicable. Any testing that was not performed and reported to ISED must be performed and reported to ISED according to the latest issue of applicable RSSs
4) Modifications to non-U.S. transmitter (FCC)
[Question]
A device was certified with a WiFi transmitter, and, also included in the EUT is a second 2.4 GHz transmitter that is only authorized for use in the EU - it is disabled at the factory in all units being marketed in the U.S. The applicant has now had to change the non-U.S. transmitter to a similar, but not identical version due to EOL of the original, in other words, it is not pin-for-pin compatible with the original (non-U.S.) transmitter chip. As a result, there has been a pcb re-layout, also accommodating some modified digital circuitry within the EUT (again, not related to the WiFi operation). My question is, may this modification to the non-U.S. approved transmitter portion of the device be accomplished via permissive change (Class 1 or Class 2, depending on test results) to the certified WiFi transmitter? Or must a new FCC ID be obtained for the WiFi transmitter, even though the modifications are to the non-U.S. certified transmitter portion of the device? Just to be clear, there have been no modifications at all to the certified WiFi circuitry and trace antenna. The only modifications are to the non-U.S. certified transmitter and some digital circuitry within the device.
[FCC Answer]
Yes, this modification would be permitted via permissive change.
5) FCC ID number on US Agent for Service of Process Attestations (FCC)
[Question]
We recently received an RT from the FCC in which you stated that the US Agent for Service of Process attestation letter must be revised to also list the FCC ID number of the application with which the attestation was submitted.Is this a new requirement?Until now, the FCC has only required that the FRN and grantee code be included in the letter, allowing an applicant to re-use the same letter for multiple applications.Please clarify if this policy has now changed.
[FCC Answer]
It is a recommended best practice to put the FCCID on the Agent for Service of Process certification but it is not a mandatory requirement. See KDB986446question 20 for information related to this issue.
6) Bandedge compliance of non-straddle channels in NII bands (FCC)
[Question]
Are devices supporting both NII-2C, NII-3, and the straddle frequencies in between required to show compliance to the frequency edge between NII-2C and NII3?
The question is for frequencies in
non-straddle channels in UNII-2C (i.e. CH140, 5700 MHz, 20 MHz BW) if they can follow the band edge requirements at edges 5.85 GHz and no longer at 5.725 GHz (same provision given for the straddle channels per B.2.b)(iii)).
Or are UNII-2C ch 140 5700 MHz signals only eligible for band edge compliance to the 5.725 GHz band edge regardless if straddle channels between 2C/3 exist?.
[FCC Answer]
Regardless if straddle channels exist, 802.11 CH 140 must meet the band edge compliance to the U-NII-2C band.
HAC Waiver and New Test Procedure
Hearing Aid Compatibility (HAC) testing is required for products that support voice calling functions, to ensure compatibility with hearing aids. Due to ongoing issues with the current HAC volume control test methodology, the TCBC Workshop included an overview of the current regulatory status by country and the progress of new standard development efforts aimed at resolving these issues.
- ■ Current Situation
- 1) United States (FCC)
- • FCC DA 25-759 (August 2025) extends the HAC waiver until September 29, 2027, or until a new volume control standard becomes available, whichever comes first.
- 2) Canada (ISED)
- • RSS-HAC Amendment 2 (June 2025)
- • Compliance is required by January 1, 2028
- • No grandfathering is permitted.
- 3) Technical Challenge
- • The current PN-SDNR (Pulsed Noise Signal to Distortion and Noise Ratio) method does not perform well with modern audio technologies, including:
- - Advanced speech codecs
- - AI-based noise cancellation and voice enhancement algorithms
- • The current PN-SDNR (Pulsed Noise Signal to Distortion and Noise Ratio) method does not perform well with modern audio technologies, including:
- 1) United States (FCC)
- ■ Standard Development Progress
Efforts are underway to replace the existing PN-SDNR-based volume control test method with more representative and robust approaches.- 1) Proposed Test Method Updates
- • Distortion-based Volume Control Test Method
- • Transition from PN-SDNR to:
- - Δ-POLQA
- - ETSI-STQ Nonlinearity Measurement (NLM)
- 2) Key Characteristics
- • Δ-POLQA
- - Mathematical MOS (Mean Opinion Score) prediction algorithm
- - Supports full-band evaluation up to 20 kHz
- - Simultaneous assessment of frequency response and distortion
- - Compatible with modern audio codecs and AI-based speech enhancement technologies
- • ETSI-STQ Nonlinearity Measurement (NLM)
- - Based on ETSI TS 104 063
- - Python code provided
- - Quantitative outputs (dB, %)
- - Designed to handle AI-processed audio signals
- • Δ-POLQA
- 3) Development Timeline
- • Test plan development: In progress
- • Round-robin testing: Q4 2025
- • Definition of acceptance criteria: Q1 2026
- • ANSI balloting and approval: Q2 2026
- 1) Proposed Test Method Updates
ANSI C63.10 Transitions
As previously highlighted in HCT Insight, Issue 23, ANSI C63.10—the primary measurement standard for unlicensed wireless devices—is undergoing a phased transition.
- ANSI C63.10-2013
- ✓ No longer acceptable after September 12, 2025
- Applicable Standards Until January 6, 2026
- ✓ ANSI C63.10-2020 + Cor.1-2023
- ✓ ANSI C63.10-2020 + Cor.1-2023 + C63.10a-2024 + Errata to C63.10a-2024
- Applicable Standards After January 6, 2026
- ✓ ANSI C63.10-2020 + Cor.1-2023 + C63.10a-2024 + Errata to C63.10a-2024
Impact:
Products that continue to be sold, distributed, manufactured, or marketed in Canada after the applicable dates must comply with the latest version of the standard.
If compliance cannot be demonstrated, a Permissive Change procedure may be required.
5600-5650 MHz TDWR Band in ISED
With the publication of RSS-247 Issue 4, ISED has officially allowed operation in the 5600–5650 MHz TDWR band.
Key clarifications include:
- DFS Testing Requirement
- - DFS testing must use radar signals defined in EN 301 893 V1.8.1.
-
- Access Points (APs)
- - Use of the 5600–5650 MHz band requires:
- • Additional testing
- • C3PC notification
- - Use of the 5600–5650 MHz band requires:
- Client Devices
- - No additional testing or filing is required unless the certification explicitly includes this frequency band.
Other TCBC Workshop topics—including additional FCC and ISED issues—are covered in detail in other sections of this newsletter.
For a comprehensive overview of the full TCBC Workshop or for further clarification on specific topics, please feel free to contact HCT at any time.