AN4804

Application note
How to get your Bluetooth design FCC and BT certified

Sergio Rossi

Introduction
In order to sell Bluetooth low energy products in the North American market and the European Union,
the equipment must comply with regulatory requirements of the FCC (Federal Communications
Commission), the IC (Industry Canada) and the European R&TTE (Radio and Telecommunication
Terminal Equipment directive). For Bluetooth devices, Bluetooth compliance and certification is also
required.
The Bluetooth Compatibility Certification aims to deliver a seamless user experience through the vast
number of Bluetooth mobile devices that are available on the market. This application note presents the
fundamentals of the process to release a Bluetooth smart product.
Figure 1: BT product market release requirements

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www.st.com
Contents AN4804
Contents
1 Bluetooth qualification process ..................................................... 3
2 Bluetooth certification process (FCC regulatory domain)............ 6
3 Conclusions ................................................................................... 11
4 Support material and helpful links ............................................... 12
5 Glossary ......................................................................................... 14
6 Revision history ............................................................................ 15

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AN4804 Bluetooth qualification process

1 Bluetooth qualification process

In order to release a Bluetooth product to the market, the solution needs to be qualified,
which means that conformance must be verified, an IP license must be granted, and logo
and word mark usage rights need to be received along with verified interoperability.
Effective February 1st, 2014, Bluetooth SIG (special interest group) introduced a
streamlined qualification and listing process and revised the fee structure for all new
product listings (see link below for details).
https://www.bluetooth.org/en-us/test-qualification/qualification-overview/listing-process-
updates
Figure 2: Bluetooth product qualification and certification process

If ST reference designs (e.g. STEVAL-IDB002V1: Bluetooth SMART board based on the

BlueNRG low energy network processor) are strictly followed and the profiles are not
changed, customers need not go through the complete qualification process. End product
listing (EPL) on the SIG website can be posted free of charge.

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Bluetooth qualification process AN4804
If customers are unsure whether their design strictly conforms to requirements, it is
recommended to contact a Bluetooth qualification expert (BQE) for advice. The BQE is
normally from an authorized testing house, such as 7layers, AT4 Wireless, etc.
The qualification process consists mainly of the following three steps:
Radio qualification
Verify the radios conformance to the Bluetooth specification. Radio testing should be
performed at a Bluetooth-qualified testing facility (7layers, AT4 Wireless, SGS, UL, etc),
and QDID (Qualified Design Identification) obtained. Component or subsystem listing.
Software qualification
Verify the Bluetooth stacks conformance to the Bluetooth specification. Perform protocol
testing at a Bluetooth qualified test facility (or Profile tuning suite, PTS), such as RFCOMM,
L2CAP, ATT, etc. Perform profile testing at a Bluetooth qualified test facility (or PTS), such
as SPP, A2DP, Proximity, etc. Obtain QDID (qualified Design Identification) from Bluetooth
SIG. Component or subsystem listing.
End product listing
The Bluetooth SIG requires that every commercially available product implementing
Bluetooth technology be listed in the Bluetooth SIG end product listing (EPL). Creating a
product listing on the EPL can be done on the Bluetooth SIG web site. The EPL benefits
members by providing a free marketing tool using the bluetooth.com and bluetooth.org
websites. The EPL will become the authoritative place for consumers and manufactures to
find all qualified Bluetooth-enabled products.
Each member will be required to declare each of their products and the portions of the
Bluetooth specification to which they are compliant. Members will then be issued a
declaration ID and pay a listing fee. Products using identical or unchanged Bluetooth-
compliant portions may appear under the same listing or declaration ID at no additional
cost.
After February 1st, 2014, the Bluetooth EPL was no longer free-of-charge, but costs $8000
(adopter members) or $4000 (associate and promoter members) for each listed product.
For the latest information, click on the following link:
https://www.bluetooth.org/en-us/test-qualification/qualification-overview/listing-process-
updates
Figure 3 shows the STMicroelectronics qualification/declarations & end product listing,
available on the SIG web site:
https://www.bluetooth.org/tpg/listings.cfm
For a more detailed explanation of the product type definitions, see Section 3:
"Conclusions".

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AN4804 Bluetooth qualification process
Figure 3: STMicroelectronics qualified product listing on the SIG website

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Bluetooth certification process (FCC regulatory AN4804
domain)

2 Bluetooth certification process (FCC regulatory

domain)
The FCC is the organization responsible in the USA for implementing rules limiting the
potential for interference of licensed operation of low power, non-licensed transmitters.
These rules are documented in Part 15 of Title 47 of the FCC. For operation in the 2400 -
2483.5 MHz band (ISM band), a low power, non-licensed device must meet one of the
following sub-parts of the regulation:
Part 15.247: devices that operate under the provisions of this section are limited to
frequency hopping and digitally modulated schemes
Part 15.249: this sub-part does not impose restrictions on either the modulation
scheme or the end application
The FCC classifies Bluetooth BR/EDR as an FHSS system. However, Bluetooth LE (low
energy) does not fulfill these requirements. Instead, the FCC classifies Bluetooth LE as a
system using digital modulation techniques, documented in Part 15 of Title 47 of the FCC.
So this allows the BlueNRG to operate without needing to use a pseudo-random hopping
sequence generator.
There are two ways of obtaining FCC certification, either directly from the FCC or through a
TCB (Telecommunications Certification Body). For almost all devices, one can chose either
to use a TCB or the FCC for certification. The exception is when the equipment uses new
technology or when the test methods are undefined or unclear. In this case the FCC is the
only party that can provide certification.
The compliance testing process is typically split into three separate categories:
RF
EMC
Safety

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AN4804 Bluetooth certification process (FCC regulatory
domain)
Figure 4: Bluetooth certification process

An end product using a modular certified radio will not need radio certification provided that
the restrictions mentioned in the modules grant are met. In other words, customers that will
use, for example, one ST module that is already FCC certified (e.g. the X-NUCLEO-
IDB04A1) will not need to proceed with the FCC process unless the customer application
introduces changes that increase emissions (e.g. different type of an antenna, colocation,
RF layout change).
There are several permissive changes (PC)/modifications that can be made to an RF
device without the need to file for a new equipment authorization. However, changes to the
basic frequency determination and stabilizing circuitry (including clock and data rate),
frequency multiplication stages, basic modulator circuit or maximum power or field strength
will always require a new FCC ID and new equipment authorization from the FCC. There
are three classes of permissive changes:
Class 1: changes that do not degrade the performance reported to the FCC and do
not require a modification of the grant no filing required.
Class 2: changes that degrade the performance reported to the FCC but are still in
compliance with the limits and changes to the grant filing required.
Class 3: changes to software for a software-defined/cognitive radio filing required
Class 1: changes could be on digital traces. Please note that if there is no filing
required, there is still a requirement to document the changes. If uncertain whether the
change is a Class1 or Class 2 permissive change, please consult with subject-matter
experts prior to requesting guidance from the certification test house/TCB.
Class 2: changes could be chip replacement on portions of the transmitter that
perform sub-functions, such as an amplifier chip or an oscillator chip. A class 2
change requires a description of the changes made, a re-test to show that the devices
are still in compliance and a test report showing compliance with the rules that need to
be provided to the FCC. While a class 2 change requires filing with the FCC, the FCC
ID will not be changed.

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Bluetooth certification process (FCC regulatory AN4804
domain)
The following information must be submitted for FCC certification:
Cover letter
Test report from lab
User manual
Schematics with parts list
Block diagram
Photo of the test setup
Internal/external photos
FCC ID label and placement on the device
Operational description
The following provides a more detailed explanation of the information to be submitted:
Test report from lab
The lab report extract shown below provides a list of the tests necessary to obtain FCC
certification for a BLE product.
Figure 5: Lab test item list for FCC certification

In application note AN4378 (available on www.st.com), some of the above tests were
completed on ST's STEVAL-IDB002V1 BlueNRG evaluation kit.

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AN4804 Bluetooth certification process (FCC regulatory
domain)
FCC ID label and placement on device
The FCC ID is a 4 to 17-character unique identifier for the equipment and consists of two
elements: the Grantee Code and the equipment Product Code. The Grantee Code is a
three-character alphanumeric string representing the grantee/applicant. The Grantee Code
always begins with an alphabetic character and does not contain the numbers one and/or
zero. The Grantee Code is assigned by the commission permanently to a company for
authorization of all radio frequency equipment. The Product Code is the non-grantee code
portion of the FCC ID that begins after the first three characters. The product code may
include hyphens and/or dashes (-). The product code shall consist of a minimum of 1 and a
maximum of 14 characters. For example: FCC ID: S9NIDB04A1.
The FFC ID must be permanently marked either directly on the transmitter or on a tag that
is permanently affixed to it. The FCC ID label must be readily visible to the purchaser at the
time of purchase.
Requirements for ID labels
Requirements for ID labels vary between products and modules. The size of the product
may also affect labeling requirements. Two main components are always required for
products and modules: each label should contain the FCC ID number and the model
number.
Requirements for agency and confidentiality letters
The FCC requires an agency letter signed by the authorized signatory for each company.
The letter simply states that the manufacturer acknowledges the appointment of individuals
at the test lab to act as its agents in submitting the filing paperwork.
The FCC also requires the applicant to designate any information deemed to be
confidential. When filings are complete, confidentiality letters are uploaded as public record
and are therefore viewable online.
The FCC offers two types of confidentiality arrangements: permanent and short-term.
Short-term confidentiality is available for all items related to product certification. However,
short-term confidentiality is limited to 180 days after the grant of authorization is issued.
This essentially allows customers to maintain temporary control over sensitive information
prior to the product launch or press release.
Permanent confidentiality is reserved for items or exhibits that are sensitive in nature, such
as trade secrets or proprietary information. Some items do not qualify for permanent
confidentiality, including test setup photos, external photos and test reports. User manuals
and internal photos may receive permanent confidentiality with expanded justification.
It is important that the FCC confidentiality letters match in terms of what is listed as
confidential.
Additional technical documents
Additional documentation required for the filing includes the theory of operation, block
diagram, schematics and antenna datasheets.
The theory of operation differs from the product description. The theory of operation should
provide an overview of how the product or module functions. It should highlight the
specifications of the radio, including output power, channels and modulation type.
The block diagram is fairly self-explanatory. This diagram should highlight key components
of the product, particularly the radio communication aspect. One important element that
must be highlighted includes the crystal frequencies and locations.

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Bluetooth certification process (FCC regulatory AN4804
domain)
For schematics, the latest revision should be submitted. It is important to include
schematics for the entire product in addition to radio-specific portions. Schematics are
generally compared against internal photos.
For external antennas, it is also necessary to supply appropriate datasheets.
User manual required
For both product and modular certification, a user manual is required. There are slight
differences in requirements for each type of certification. However, key components in each
are the FCC warning statements regarding labeling, modifications and RF exposure.
Ancillary information
A few ancillary documents and calculations required for the filing process include the
emission designator, external photos, internal photos, test setup photos and MPE/SAR
evaluation. Typically this information will be provided by the test laboratory, as it can be
determined from test results or taken from test samples.

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AN4804 Conclusions

3 Conclusions
Bluetooth qualification and certification (FCC) is quite complex. The purpose of this
document is to provide an overview of the steps necessary to release a Bluetooth low
energy product to the market. As previously stated, it is recommended to consult
organizations that specialize in Bluetooth qualification services, such as 7layers and AT4
Wireless.

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Support material and helpful links AN4804

4 Support material and helpful links

Product type definitions
Bluetooth end product - An implementation of Bluetooth wireless technology, which
implements, at a minimum, all mandatory requirements in radio, baseband, link manager,
logical link control and adaptation protocol, service discovery protocol and generic access
profile parts of the specification.
Bluetooth subsystem product - An implementation of Bluetooth wireless technology that
implements only a portion of the specification in compliance with such portion of the
specification and in accordance with the mandatory requirements as defined herein.
Bluetooth subsystem products can be qualified solely for distribution and the use of
Bluetooth wireless technology in Bluetooth subsystem products require such Bluetooth
subsystem products to be combined with a complementary Bluetooth end product or one or
more complementary Bluetooth subsystem products such that the resulting combination
satisfies the requirements of a Bluetooth end product.
There are three types of Bluetooth subsystem products as defined below:
Bluetooth host subsystem product A Bluetooth subsystem product containing, at
a minimum, all the mandatory requirements defined in the host controller interface,
logical link control and adaptation protocol, service discovery protocol and generic
access profile parts of this specification, but none of the protocols below host
controller interface (HCI). In addition, a Bluetooth host subsystem product may
contain, at a minimum, all the mandatory requirements defined in one or more of the
protocols and profiles above HCI.
Bluetooth controller subsystem product A Bluetooth subsystem product
containing, at a minimum, all the mandatory requirements defined in the Bluetooth
radio, baseband, link manager and HCI parts of this specification, but none of the
protocols and profiles above HCI.
Bluetooth profile subsystem product A Bluetooth subsystem product containing,
at a minimum, all the mandatory requirements defined in one or more of the profile
specifications.
Bluetooth component product - An implementation of Bluetooth wireless technology that
does not meet the requirements of a Bluetooth end product, but implements, at a minimum,
all the mandatory requirements of one or more of the protocol and profile parts of the
specification in compliance with such portion of the specification. Bluetooth component
products can be qualified solely for distribution, and the use of the Bluetooth wireless
technology in Bluetooth component products requires such Bluetooth component products
to be incorporated into Bluetooth end products or Bluetooth subsystem products.
Components are qualified as a partial" product type to enable end product qualification.

Bluetooth qualification helpful hyperlinks

Introduction to membership:
https://www.bluetooth.org/Membership/benefits.htm
New to the Bluetooth SIG
https://www.bluetooth.org/en-us/members/new-to-the-sig
Getting started with the Bluetooth SIG
https://www.bluetooth.org/en-us/members/getting-started-with-sig

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AN4804 Support material and helpful links
Become a member
https://www.bluetooth.org/login/register/
Bluetooth qualification and declaration processes
https://www.bluetooth.org/en-us/test-qualification/qualification-overview
EPL end product list
https://www.bluetooth.org/tpg/listings.cfm
https://www.bluetooth.org/Technical/Qualification/eploverview.htm
CPL component product list
http://www.bluetooth.com/Bluetooth/technology/Building/Component/
Listing fees
http://www.bluetooth.org/Technical/qualification/fees.htm
QDID Purchase one
http://www.bluetooth.org/tpg/QLI_obtainQDID.cfm
Qualification FAQs
https://www.bluetooth.org/ticketing/faq.cfm
Specifications
https://www.bluetooth.org/Technical/Specifications/adopted.htm

FCC Certification helpful hyperlinks

FCC parts
http://www.scc-ares-races.org/FCCpartstitles.html
AN4378 Application note: Using the BlueNRG transceiver under FCC title 47 part 15
in the 2400 2483.5 MHz band
http://www.st.com/st-web-
ui/static/active/cn/resource/technical/document/application_note/DM00098029.pdf

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Glossary AN4804

5 Glossary
BQE: Bluetooth qualification expert
EPL: End product list - the listing database required for all products listed as compliant
to PRD 2.X.
PTS: Profile Tuning Suite - software test reference which controls a Bluetooth
endpoint to carry out Bluetooth profile tests. The PTS provides members with a means
to perform interoperability testing against a tool designed to ensure that
interoperability testing requirements are met.
FCC: Federal Communications Commission
MPE: Maximum permissible exposure
QDID: Qualified design ID - an alpha-numeric number provided to the member once
the listing fee is received by the SIG
SIG: Abbreviation for Bluetooth SIG. SIG stands for special interest group
TCB: Telecommunications certification body

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AN4804 Revision history

6 Revision history
Table 1: Document revision history
Date Revision Changes
25-Jan-2017 1 Initial release.

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 AN4804

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