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USFCCRegulation guide

# FCC 5G mmWave Equipment Authorization

5G millimeter wave products operating above 24 GHz require FCC equipment authorization under Part 30 (Upper Microwave Flexible Use Service) and Part 15 rules, with unique testing requirements for beamforming antennas, OTA power measurement, and human exposure (MPE/SAR). The test methodologies differ significantly from sub-6GHz certification and require specialized facilities.

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At a glance

Regulatory framework

FCC Part 30 / Part 15

Authorization route

TCB

Test method

OTA (Over-the-Air)

Key standard

IEC 62209-3, KDB 616217

Typical timeline

6–8 weeks TCB review

## FCC regulatory framework for mmWave 5G

### Part 30 UMFUS Licensed Bands

Upper Microwave Flexible Use Service covers 24.25–24.45 GHz, 27.5–28.35 GHz, 37–38.6 GHz, 38.6–40 GHz, and 47.2–48.2 GHz. Equipment operating in these bands for 5G NR deployments requires FCC equipment authorization under Part 30 rules, which set EIRP limits and out-of-band emission masks specific to each band.

### Part 15 Unlicensed 60 GHz Operation

The 64–71 GHz band is governed by Part 15 Subpart C as an unlicensed band. Products operating here (WiGig, 802.11ad/ay, short-range sensing) do not require a licence but must comply with Part 15 technical requirements and follow OTA measurement procedures defined in KDB publications.

### OET Bulletin 65 MPE Limits at mmWave

FCC Office of Engineering and Technology Bulletin 65 defines maximum permissible exposure limits. Above 6 GHz, the evaluation metric shifts from SAR (W/kg) to power density (mW/cm²). At mmWave frequencies, the spatial peak power density limit is 1 mW/cm² averaged over any 1 cm² area, evaluated at the surface of the human body.

### Equipment Authorization via TCB

5G mmWave equipment authorization is processed through a Telecommunications Certification Body (TCB). TCBs review test reports, check compliance with applicable KDB guidance documents, and issue grants on behalf of the FCC. Direct FCC review is no longer standard for most commercial equipment — selecting an accredited TCB with mmWave experience is critical.

## OTA testing requirements for mmWave

Because mmWave devices use integrated antenna arrays with no accessible RF connector, all measurements must be performed over-the-air. This demands specialized test facilities and methodologies that differ entirely from sub-6 GHz conducted testing.

01

Conducted measurements are not applicable for 5G mmWave products with integrated antenna arrays — all power measurements must be performed over-the-air.

02

OTA EIRP (Equivalent Isotropically Radiated Power) measurements characterise the maximum radiated power in the direction of peak beam, including antenna gain.

03

OTA TRP (Total Radiated Power) measurements integrate radiated power over the full sphere to establish aggregate power for MPE evaluation.

04

Near-field to far-field transformation methods are used when far-field distances are impractical at mmWave frequencies — mathematical transformation from near-field scan data is accepted.

05

Compact Antenna Test Range (CATR) or near-field scanner facilities are required — standard anechoic chambers designed for sub-6 GHz are generally inadequate for above-24 GHz OTA.

06

IEC 62209-3 provides the device-level RF exposure evaluation methodology for equipment with integrated antenna systems above 6 GHz, and is referenced in FCC KDB publications.

## MPE and RF exposure at mmWave

mmWave RF exposure evaluation uses power density metrics rather than SAR. The shallow tissue penetration at these frequencies means exposure is evaluated at the body surface — but the highly directional beams of phased arrays can create intense localised fields that require careful characterisation.

### Power Density Limits Above 6 GHz

The FCC uses a frequency-dependent power density limit: S = f/1500 mW/cm² from 1.5 GHz up to 10 GHz, transitioning to a flat limit of 1 mW/cm² above 10 GHz. For mmWave products operating at 28 GHz or 39 GHz, the applicable limit is 1 mW/cm² averaged over any 1 cm² area at the closest point of public access.

### Spatial Peak Power Density for mmWave

At mmWave frequencies, the FCC evaluates spatial peak power density — the highest power density found at any point within the evaluated area — rather than time-averaged whole-body SAR. The 1 cm² averaging area accounts for the highly localised nature of mmWave energy absorption at tissue surfaces.

### Averaging Area Requirements

FCC rules and OET Bulletin 65 specify that power density averaging at mmWave frequencies uses a 1 cm² spatial averaging area. For beamsteering products, the evaluation must capture the worst-case beam direction and account for the duty cycle of transmission when time-averaging is applied.

### Exclusion Zones for Beamsteering Products

Products with electronically steered beams must define a minimum separation distance (exclusion zone) from the antenna aperture within which the 1 mW/cm² limit could be exceeded. This distance is calculated from the peak EIRP and antenna aperture area, and must be documented in the authorization filing and user manual.

## Certification process and timeline

### TCB Submission Package

A complete TCB submission for mmWave equipment includes FCC Form 731, test reports from an accredited laboratory, attestation statements, operational description, block diagram, schematics, user manual with RF exposure warnings, and KDB-compliant test procedure documentation. Incomplete submissions are a leading cause of delays.

### OTA Test Report Requirements

mmWave OTA test reports must document the test facility configuration (CATR or near-field), measurement uncertainty analysis per ISO/IEC 17025, full spherical or hemispherical scan results, EIRP and TRP calculations, and RF exposure evaluation. TCBs scrutinise measurement uncertainty at mmWave frequencies more closely than for sub-6 GHz submissions.

### KDB Publications for mmWave Procedures

FCC Knowledge Database (KDB) publications are the primary guidance documents for mmWave test procedures. KDB 616217 covers RF exposure for devices with integrated antennas above 6 GHz. KDB 447498 provides OTA measurement guidance. Always check for updated KDB revisions before finalising a test plan — procedures evolve as technology matures.

### SDR and Software-Defined mmWave

Software-defined radio products operating at mmWave frequencies face additional scrutiny because the authorization must cover all software-selectable operating modes. FCC rules require that software cannot enable the device to operate outside its authorized parameters. Security requirements to prevent user modification of operating parameters are mandatory.

## Frequently asked questions

### Can a 5G mmWave module use modular approval to cover end products?

Modular approval is technically possible for mmWave modules but is rarely granted in practice because mmWave performance is highly dependent on the integration environment — antenna orientation, proximity to other components, and enclosure materials all significantly affect radiated performance. Most TCBs require host-device-level OTA testing. Limited modular approval for specific configurations may be possible where the host integration is tightly controlled.

### What is the difference between conducted and OTA testing for mmWave devices?

Conducted testing measures RF output power at a coaxial connector, independent of the antenna. OTA testing measures the actual radiated performance from the antenna system. At mmWave frequencies, virtually all 5G NR devices use integrated antenna arrays with no accessible RF connector — conducted measurement is physically impossible. OTA testing using a CATR or near-field scanner is therefore the only valid measurement approach for mmWave equipment authorization.

### How do beamforming arrays affect FCC certification compared to fixed antennas?

Beamforming arrays add significant complexity to FCC certification. The authorization must cover all beam configurations including the maximum EIRP beam direction. RF exposure evaluation must consider both the peak beam scenario and the time-averaged exposure over normal operation. Exclusion zones must be defined. Test facilities must capture spherical or hemispherical EIRP patterns to find the peak. Fixed-beam products are simpler because the worst-case direction is fixed and fewer beam states need evaluation.

### What is a KDB document and why does it matter for mmWave certification?

FCC Knowledge Database (KDB) publications are official FCC guidance documents that clarify how regulations apply to specific technologies. They do not have the force of law but TCBs treat them as the authoritative interpretation of how to comply with the rules. For mmWave products, KDB publications define acceptable test methodologies, facility requirements, and data formats. Testing without reference to the current applicable KDB documents is a common cause of TCB rejection and test report failure.

**Disclaimer:** This page is an educational resource only and does not constitute legal or regulatory advice. FCC rules, KDB publications, and TCB interpretations change over time. Always consult current FCC rules and engage a qualified telecommunications engineer for product-specific authorization strategy.

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