EN 300 328 V2.2.2: Reminder of new mandatory compliance requirement in effect 6 August 2021

With billions of devices entering the market every year, it’s a wonder that our devices are able to connect and communicate so effectively while sharing the same spectrum. As the Internet of Things continues to grow, so does the potential for signal interference amongst products utilizing a 2.4 GHz radio frequency. Regulatory compliance testing continuously works to reduce the risk of any potential safety issues as well as increase the product’s performance abilities.

In order to comply with these market requirements for electrical and electronic products with radio transmitters and receivers, manufacturers, importers, and distributors are required to strictly adhere to the EU Radio Equipment Directive 2014/53/EU and UK Radio Equipment Regulation 2017, including compliance with the related harmonized standards and designated standards lists. And one key standard whose deadline for establishing compliance is quickly approaching is EN 300 328 V2.2.2.

Compliance with EN 300 328 V2.2.2 will become mandatory for radio products within its scope from 6 August 2021 onward. This new version replaces EN 300 328 V2.1.1 which was originally published 13 January 2017 for transmission systems operating in the license free 2.4 GHz band.

The 2.4 GHz band is used for technologies such as 2.4 GHz WLAN, Bluetooth, ZigBee, and more. Products that have not established compliance with EN 300 328 V2.2.2 after 5 August 2021 cannot continue to be placed on the market.

What changes have been made in EN 300 328 V2.2.2?

Since the earlier EN 300 328 V2.1.1 version, there have been changes made to the standard, including:

  • Clarification on definitions and requirements from the previous version
  • Changes to test methods and reporting requirements outlined
  • Changes made to the Receiver Blocking test method, including a retest
  • Relaxed rules in the Transmitted Unwanted Emissions requirements

Here are important changes to note in EN 300 328 V2.2.2:


Assessment type / section Important changes to note:
Antenna Types
(Section 4.2.4)
New addition from previous version. Specifies that dedicated antennas must be assessed in combination with equipment to meet requirements.

Accumulated Transmit Time, Frequency Occupation and Hopping Sequence Conducted Measurements
(Section 5.4.4.2.1)

Test methods have been revised in the sixth step in order to indicate the use of a peak detector rather than Root Mean Square (RMS). Additionally, the number of sweep points is defined as ~400/Occupied Channel Bandwidth (MHz). This number may be increased in situations where there are overlapping channels.

RF Output Power — Conducted Measurements
(Section 5.4.2.2.1.2)

The test method for Radio Frequency (RF) Output Power requires a fast power sensor with minimum sensitivity of -40 dBm is included in the new version.

Power Spectral Density Conducted Measurements (Section 5.4.3.2.1)

There are two options for power density test methods. Option 1, equipment with continuous and non-continuous transmissions, is now required to use maximum TX-sequence time in place of channel occupancy time within the formula for determining sweep time for non-adaptive, non-continuous transmission equipment

Option 2, equipment with continuous transmission capabilities, is revised from 2x the nominal bandwidth for determining frequency spans to at least 2x the Occupied Channel Bandwidth.

Presentation of Equipment (Sections 2.2 and 5.3.4)

These sections reference ETSI EG 203 367 Guide for the application of harmonized standards that cover 3.1b and 3.2 Directive 2014/53/EU for multi-radio and combined radio and non-radio equipment. The existing content has been removed where it was addressed by the previous standard.

Received Category
(Section 4.2.3)

This section redefines receiver categories in order to address all combinations of equipment types and power levels.

Received Blocking Limits (Sections 4.3.1.12.4 and 4.3.2.11.4)

Receiver blocking parameters are redefined across all receiver categories. The blocking signal power has increased, however the wanted signal power from companion devices has also been revised. These changes may not result in more stringent requirements than the first version, but conformance must been evaluated.

Receiver Blocking Performance Data
(Sections 4.3.1.12.3 and 4.3.2.11.3)

A new reference to Frame Error Rate (FER) is made. The option for the manufacturer to declare alternative performance criteria has been removed. However, for equipment that does not support a PER or FER test, the minimum performance criteria must be that there is no loss of the wireless transmission functions that are necessary for the intended use of the equipment.

Receiver Blocking Test Method (Section 5.4.11.2)

This section has been revised in correlation to the changes made in the receiver blocking limits and parameters. There are additional measurement methods available, including extended steps to address any non-compliance issues.

Transmitter Unwanted Emissions in the Out-of-Band Domain
(Section 5.4.8.2.1)

The test method has been revised to specify the measurement mode as Time Domain Power, as well as a revision regarding sweep mode from continuous to single. The maximum number of sweep points has increased to 30,000.

Transmitted Unwanted Emissions in the Spurious Domain — Limits
(Sections 4.3.1.10.3 and 4.3.2.9.3)

The limits of frequency range from 694-862 MHz have been revised to -36 dBm. These less stringent limits align with CEPT ERC Recommendation 74-01, which is based on the transition from analog to digital and the resulting spectrum allocation.


Who will be affected by this change?

Manufacturers of products that are supporting technologies such as Bluetooth, Wi-Fi, ZigBee, and other wideband and frequency-hopping (FHSS) data transmission equipment that is capable of operating in the band 2400 — 2483.5 MHz frequency band will be affected. This is not only applicable to those implementing chipset solutions but also those incorporating modules provided by third parties.

This will affect products being placed on the market in the European Union, as well as the United Kingdom

How will manufacturers demonstrate compliance?

In order to demonstrate compliance with the updated standard, manufacturers must conduct a review of existing test reports in order to evaluate the changes as they relate to specific products. Limited testing must be performed to demonstrate compliance with the latest requirements, with all proper documentation made in a test report that is held in the manufacturer’s technical construction file.

If an EU Notified Body Type Examination Certification or UK Approved Body Type Examination Certification was previously obtained or currently desired, the manufacturer must complete an application for Modification Certification. The Declaration of Conformity must be updated to reflect compliance with EN 300 328 V2.2.2.

It’s also important to note that any manufacturer who incorporates a third-party module and uses third party Declaration of Conformity documentation and test reports in the technical file must request to be issued the latest documentation from their provider.

Any noncompliant products placed on the market on or after 6 August, 2021 may result in a variety of enforcement actions and penalties against the manufacturer to enforce compliance with EN 300 328 V2.2.2, including withdrawal of products from the market, sanctions, and other fines.

How can Nemko help with the transition process?

Nemko’s network of global wireless laboratories perform radio testing according to EN 300 328 V2.2.2. Nemko can provide EU Notified Body Type Examination Certification and UK Approved Body Type Examination Certification for all radio products within scope. For manufacturers who self-declare, Nemko also can provide a high-level review of all technical construction files (DoC and radio test reports) for products in consideration to determine any gaps in compliance and can provide a letter containing the findings of the review, which helps to ensure the product’s compliance with the EU Radio Equipment Directive and UK Radio Equipment Regulation.

Send us an email at info@nemko.com if you have any questions or need further information.

 

Written by Vina Kerai
Vina is located in Nemko’s US office and she is responsible for Nemko’s Telecommunications Certification Body programs. Vina has a proven track record of successfully implementing and managing certification programs with over 18 years of experience from R&D/engineering, compliance testing and certification to management. Vina is skilled at working with wireless technologies and guiding engineering technical leads across multiple IoT Verticals for key regulatory markets including the US, Canada, Europe, Japan, Korea, Taiwan and Hong Kong.

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