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    July 9, 2021

    Meeting Canada’s New Draft Radio Requirements for 6 GHz Technologies

    Regulators in Canada have recently announced plans that will support the continued expansion of license-exempt spectrum needed for electronic devices using Radio Local Area Network (RLAN) technology to provide high data rate wireless access for Canadians in the highly demanded 5925-7125 MHz band.

    In mid-May, the Department of Innovation, Science and Economic Development Canada (ISED) issued its “Decision on the Technical and Policy Framework for License-Exempt Use in the 6 GHz Band.” The decision details a technical and policy framework that will allow for the license-exempt use of the 5925-7125 MHz spectrum frequency band (also known as the 6 GHz band). New spectrum sharing techniques such as dynamic spectrum access are expected to be considered for new services in the 6 GHz band.

    To support the implementation of its 6 GHz framework, ISED also published for public comment a draft of a new radio standard. The standard, RSS-248, Issue 1, “Radio Local Area Network (RLAN) Devices in the 5925-7125 MHz band,” details certification requirements for license-exempt low power RLAN devices operating in the 6 GHz band in indoor environments.

    A summary of the requirements applicable to 6 GHz access points and connected devices under RSS-248 are provided in this article as well as insights on how Nemko can help device manufacturers achieve compliance with Canada’s new regulatory framework for 6 GHz technologies.

    The background behind ISED’s actions on 6 GHz technologies

    Most of us take for granted our reliance on Wi-Fi routers and internet hotspots to access the internet and other applications using our smartphones or computers. But demand for license-exempt spectrum to support all types of wireless communications continues to grow, stretching the use of currently available spectrum to its limits. Further, the introduction of more advance high-speed devices using 5G and 6G technologies requires access to spectrum in higher frequency ranges to fully realize their benefits.

    Recognizing these challenges, ISED launched a public consultation in November 2020 to solicit input on the technical and policy considerations around expanding license-exempt spectrum to include the 6 GHz frequency band, and ISED’s proposed modifications to the current Canadian Table of Frequency Allocations (CTFA) specific to the 6 GHz band that would permit license-exempt RLAN operations.

    ISED also proposed a phased roll-out of new 6 GHz rules, based on the following three device categories:

    • Phase 1: Low-power indoor access points (AP) and connected devices
    • Phase 2: Standard power APs with automated frequency coordination (AFC)
    • Phase 3: Very low-power APs

    During the public consultation period, more than 40 different organizations, including international technology companies, industry groups, and government agencies, provided comments on the changes proposed by ISED. Comments received during the public consultation contributed significantly to the development of the final technical and policy framework presented in ISED Decision published on May 19th.

    A summary of the proposed requirements applicable to 6 GHz indoor access points and connected devices

    Phase 1 of ISED’s release plan regarding the use of low-power indoor access points commenced in early June with the release for public comment of the draft standard RSS-248, Issue 1. The draft standard details technical and operational requirements for RLAN devices, including types of permitted modulation (Clause 4.3), transmitter power limits (Clause 4.6), control of unwanted emissions (Clause 4.7), and the use of a contention-based protocol (Clause 4.8).

    In brief, low-power RLAN devices are subject to the following limitations:

    • RLAN operation is limited to indoor-only access, and cannot be used in motor vehicles, trains, ships, or aircraft. The sole exception is large aircraft operating above 10,000 feet.
    • RLAN devices must use a contention-based protocol (e.g., “listen-before-talk”).
    • The maximum permitted effective isotopically radiated power (EIRP) for an RLAN device is 30 dBm.
    • The maximum permitted power density for an RLAN device is limited to 5 dBm/MHz.
    • The bandwidth used by an RLAN device cannot exceed 320 MHz.

    While these requirements are specific to RLAN operation in indoor environments, the draft standard also makes clear that RLAN devices are expected to comply with the general technical requirements set forth in RSS-Gen, “General Requirements for Compliance of Radio Apparatus.”

    To be legally marketed in Canada, the draft standard classifies RLAN devices as Category 1 equipment, requiring either a technical acceptance certificate (TAC) issued by the Certification and Engineering Bureau (CEB) of ISED or a certificate issued by a recognized certification body (CB). However, the draft standard also affirms that RLAN devices that fall under the scope of the standard are exempt from Canada’s radio licensing requirements.

    The complete text of RSS-248 is available for download at the website of the Radio Advisory Board of Canada at ISED Radio Standards Specifications, RSS-248, issue 1, June 2021 (Draft). Comments on the draft standard can be filed through the standard change request page of Canada’s CEB at Standard Change Request. Comments are due by not later than August 16, 2021.

    Nemko can help you achieve compliance with Canada’s new regulatory framework for 6 GHz technologies

    The implementation of ISED framework to expand access to license-exempt spectrum to include 6 GHz frequencies is expected to triple the spectrum currently available for Wi-Fi, IoT, and other advanced communication technologies, while also increasing throughput rates and lowering latency. In addition to improving wireless device performance, the changes will also open up significant market opportunities for developers of new and innovative wireless communications technologies.

    At the same time, testing and certification of RLAN devices in accordance with the requirements of the draft standard will be required and is expected to apply equally to both new and existing devices. With the anticipated publication of RSS-248 later this year, manufacturers looking to take advantage of this opportunity should seek the assistance of an authorized wireless device testing laboratory and certification body that is recognized by ISED Canada to test and certify their device before placing it on the market.

    Nemko’s extensive network of global wireless laboratories can perform testing to ISED Canada’s published radio standard specifications, including RSS-248.

    Nemko is recognized as an ISED approved wireless device testing laboratory and certification body as well as by the U.S. Federal Communications Commission (FCC) as an accredited testing laboratory and telecommunication certification body (TCB) for the certification of all types of radio products, including RLAN devices.

    For more information about Nemko’s testing and certification services for RLAN devices and other radio products, visit our website at or contact us at

    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...

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