NRF52832 BLE Certification under ETSI EN 300 328

RE: NRF52832 BLE Certification under ETSI EN 300 328

HugoCalliope — Mon, 11 Sep 2023 13:56:38 GMT

Thanks a lot for providing this reference.
I am currently filling the form EN 300 328 2.2.2 for a NRF52833 SMD antenna board with Softdevice 113 and have some questions:

In the section E.2:

- e) the maximum RF Output Power (e.i.r.p.) is listed here as 4dBm, but the Radio Test firmware lets me choose values up to 8dBm. Is 4dBm still correct?

- f) the same as above.

-m) Our meandered inverted F antenna according to https://www.ti.com/lit/an/swra117d/swra117d.pdf. The anntena was matched by Nordic for 50Ohms, do you know which antenna gain I should assume? There are several mentioned relatively to the xy,xz,yz, plane.

I also face difficulties filling up the section E.3. I don't exactly know which combination leads to the highest overall e.i.r.p. value. Can you help?

Thank you a lot in advance,

Hugo

RE: NRF52832 BLE Certification under ETSI EN 300 328

bjorn-spockeli — Mon, 29 Jul 2019 09:32:26 GMT

Hi Andrzej,

A Bluetooth Low Energy device would have to fall under the category non-adaptive frequency hopping equipment as Bluetooth Low Energy does adapt to its radio environment by identifying channels that are being used and excluding them from the list of available channels.

FCC requires minimum 15 channels(adaptive or not) and ETSI requires a minimum of 5 channels for non-adaptive FHSS equipment, see section below

4.3.1.4.3.1 Non-adaptive frequency hopping equipment

"The hopping sequence(s) shall contain at least N hopping frequencies where N is either 5 or the result of 15 MHz divided by the minimum Hopping Frequency Separation in MHz, whichever is the greater. According to clause 4.3.1.5.3.1 the minimum Hopping Frequency Separation for non-adaptive equipment is equal to the Occupied Channel Bandwidth with a minimum of 100 kHz."

We certify all our Bluetooth Low Energy development kits and reference designs as a Digital Modulation System/ Direct Sequence Spread Spectrum devices.

Best regards

Bjørn

RE: NRF52832 BLE Certification under ETSI EN 300 328

Andrzej — Fri, 26 Jul 2019 08:44:57 GMT

Dear Bjorn,

I'm aware of Bluetooth Low Power Regulatory Aspects Whitepaper but it refers to 4.2.1, which in new version 2.1.1 looks like:

4.2.1 Modulation types
The present document defines two categories of Wide Band Data Transmission equipment:
• Equipment using Frequency Hopping Spread Spectrum (FHSS) modulation.
• Equipment using other types of wide band modulation (e.g. DSSS, OFDM, etc.).
The manufacturer can categorize the equipment to any of the above as long as the equipment complies with the
corresponding requirements defined in either clause 4.3.1 or clause 4.3.2. This is part of the product information to be
declared by the manufacturer. See clause 5.4.1.

So there is no requirement for minimum 15 channels for advertising...

RE: NRF52832 BLE Certification under ETSI EN 300 328

bjorn-spockeli — Fri, 26 Jul 2019 08:15:36 GMT

This is stated in the Bluetooth Low Power Regulatory Aspects Whitepaper, found here. BLE does not meet the FHSS requirements due to the limit number of channels used for advertisment, i.e. 3 channels.

5.2.1 FCC

FCC classifies Bluetooth BR/EDR as a FHSS system; however, Bluetooth LE does not fulfill these requirements*. Instead, FCC classifies Bluetooth LE as a system using digital modulation techniques. 15.247(a)(2): Systems using digital modulation techniques may operate in the 902 - 928 MHz, 2400 - 2483.5 MHz, and 5725 - 5850 MHz bands. The minimum 6 dB bandwidth shall be at least 500 kHz.

*)Frequency hopping spread spectrum systems (FHSS) in the 2400-2483.5 MHz are in FCC 15.247(1) (iii) required to a) use at least 15 channels and b) when hopping, the transmission also must comply with a 0.4 second/channel maximum dwell time.

5.2.2 ETSI

ETSI classifies Bluetooth BR/EDR as an FHSS system; however, Bluetooth LE does not fulfill the FHSS requirements in clause 4.2.1. Instead, ETSI classifies Bluetooth LE as a system using DSSS (direct-sequence spread spectrum) modulation.

§ 4.2.2: For the purposes of the present document, other forms of modulation which do not satisfy the constraints of the specification given in clause 4.2.1, shall be considered equivalent to DSSS modulation. Systems using these other forms of modulation shall be considered equivalent to DSSS systems and shall be tested according to the requirements for DSSS modulation.

RE: NRF52832 BLE Certification under ETSI EN 300 328

Andrzej — Fri, 26 Jul 2019 08:00:46 GMT

Dear Bjorn,

As in new ETSI 300 328 v .2.1.1 in 4.2.1 there are defined two categories FHSS and other.

This document no longer defines what FHSS is (there was a definition in last version and BLE didin't meet those requiremnets), what's more BLE Core document in 1.1 says

Like the BR/EDR radio, the LE radio operates in the unlicensed 2.4 GHz ISM
band. The LE system employs a frequency hopping transceiver to combat
interference and fading and provides many FHSS carriers.

Our question is how should we fill the form: ANEX E if we use NRF52840 with SoftDevice 140.

And Can You provide the source for the information that BLE should be qualified as "system using digital modulation techniques"?

RE: NRF52832 BLE Certification under ETSI EN 300 328

haveltec — Sat, 03 Jun 2017 10:45:16 GMT

Hi Bjørn, thanks for the infos!

RE: NRF52832 BLE Certification under ETSI EN 300 328

bjorn-spockeli — Fri, 02 Jun 2017 07:53:42 GMT

No, you should qualify the nRF51822 with the S130 the same way as the nRF52832 and the S132, i.e. non-adaptive equipment without FHSS. This because a BLE device will advertise in sequence on 3 fixed channels in the 2400-2483 MHz band. Therefore, a BLE device should be qualified as a "system using digital modulation techniques". FCC 15.247 (2) and not a Frequency Hopping System, i.e. you do not have to provide the testing facility with frequency dwell times, channel order etc.

This is described in the Bluetooth Low Power Regulatory Aspects Whitepaper, found here.

RE: NRF52832 BLE Certification under ETSI EN 300 328

haveltec — Tue, 30 May 2017 06:36:34 GMT

Hi Bjørn,

we are also struggle with classification according the EN 300 328. We use a NRF51822 with a PCB antenna and SD 130. Is there a similar example form? The example for the NRF52832 marks a non-adaptive equipment without FHSS. The NRF51822 running SD130 is using frequence hopping spread spectrum and is adative or am I wrong? thanks, Christian

RE: NRF52832 BLE Certification under ETSI EN 300 328

simao.pinheiro — Fri, 19 May 2017 08:35:32 GMT

Great. Thank you Bjørn, we really appreciate it.

RE: NRF52832 BLE Certification under ETSI EN 300 328

bjorn-spockeli — Fri, 19 May 2017 07:19:59 GMT

I am afraid that we do not have a datasheet where these parameters are clearly stated due to the fact that many of the parameters will vary depending on the HW design and SW, but some of the parameters, like Occupied Channel Bandwidth are fixed as these cannot be configured by the radio. Thus, its hard to give a general answer. However, the test house will have to test most of the parameters anyway, so it does not matter if the measured values are a bit higher/lower than the values provided in the form, as long as they are within the allowed limits. My advice would be to fill out the form using the form I provided as a template and if the test house has any comments/complaints then contact us either here on DevZone or Mypage and we will help you sort it out.

RE: NRF52832 BLE Certification under ETSI EN 300 328

simao.pinheiro — Thu, 18 May 2017 14:02:01 GMT

Thank you very much Bjørn, this really helped a lot.

If you don't mind I would still like to ask you a question. Is there a document from where the answers to this form were based? Some sort of datasheet where these parameters (maximum Duty Cycle, Occupied Channel Bandwidth, Transmitter unwanted emissions in the OOB domain, etc) are clearly disclosed. Also, are these parameters fixed (immutable regardless of the application where your NRF52832 is inserted into) or are they configurable?

RE: NRF52832 BLE Certification under ETSI EN 300 328

bjorn-spockeli — Thu, 18 May 2017 09:36:56 GMT

Hi Simao,

I've attached a pre-filled ETSI EN 300 328 form that you can use as a reference when filling out yours. Its not the latest version, but it should be pretty similar and answer most of the questions you have. Let me know if you have any additional questions.

Attachment: etsi_en_300_328_annex_e.pdf

Best regards

Bjørn