The new EU Regulation (EU) 2019/320 (also known as Regulation E112) is mandatory from March 17, 2022. EU Regulation 2019/320 establishes Article 3(3)(g) of the Radio Equipment Directive (RED, 2014/53/EU), which requires smart phone manufacturers to demonstrate that their products comply with the positioning requirements of Galileo satellites, AML and Wi-Fi. BACL, which is the Notified Body for CE certification in the EU (Notified Body: 1313), and also has established branches in Europe, has a wide range of testing capabilities and comprehensive accreditation scope, and can provide one-stop testing and certification services for smart phones, helping manufacturers enter the EU market smoothly!

Reference test standards:

• ETSI TS 103 246-3 V1.3.1 (2020-10)

• ETSI TS 103 246-5 V1.3.1 (2020-10)

• ETSI EN 303 413 V1.2.1 (2021-04)

• ETSI TS 103 625 V1.1.1 (2019-12)

• 3GPP TS 36.509 V16.0.0

•  ISO/IEC 18305:2016

Test items:

1. NMEA output

2. Time to first fix (TTFF)

3. Positioning accuracy

4. Galileo Open Service Navigation Message Authentication (Galileo OSNMA)

5. Exposure of additional Galileo observations

6. Emergency communication-related tests

7. Wi-Fi positioning-related tests

Among them, test items 1-5 need to be tested by radiation method, and the test system is shown in the figure below:

As the original description of the regulation is relatively simple, there are questions on the interpretation of the regulation from all sides of the industry. BACL has compiled the following FAQs for you based on the recent EU discussions and some expert interpretations.

Q1: How to define the time point of March 17, 2022 given in the E112 regulation? Which time point shall prevail?

A: The time point when the product enters the EU market (customs) shall prevail, which is for each individual product rather than the model. If the old model continues to be shipped after this date, it still needs to comply with the new regulations. Hence it may need additional test per the new E112 regulation and its CE certificate should be updated accordingly. Products that have entered the EU market before this date do not need to be updated.

Q2: What products are covered in the E112 regulation? How does the regulation define smart phones? Can feature phones be exempted?

A: 1. The requirements of the regulation apply to smart phones.

2. Per the definition in the regulation, smart phones are cell phones with data processing functions similar to a computer, which are generally considered to be equipped with a smart operating system that can install APP and support cellular data.

3. If the phone does not support GNSS and Wi-Fi, it is considered a non-smart phone, and can be exempted.

Q3: Is it necessary to apply for NB certificate for the content of the new regulation?

A: Yes, as there is no harmonized standard for E112 testing, it is required to apply for NB certificate according to RED directive.

Q4: Do non-cellular products, such as those supporting voice calls, need to meet E112 regulations? For example, tablet PCs, smart watches, etc.

A: E112 regulations do not apply to non-cellular products.

Q5: Is it necessary to test in authorized laboratories or locally in Europe?

A: There is no authorized laboratory requirement for RED certification, and no need for local testing in Europe. BACL has the testing capability and test site to meet the relevant requirements, and can provide you with one-stop service.

Q6: Is it possible to exempt E112 and obtain NB certificate for cell phones sold to non-EU regions? It is used for local transfer certificate.

A: BACL can currently issue NB certificates for smart phones sold to non-EU regions.

Q7: Are cell phones sold to the EU with some functions not supported exempted from the corresponding test items to meet the regulatory requirements?

A: Smart phones sold to the EU must meet the full requirements of the regulations and pass all tests.

Q8: Does the phone have to support OSNMA? Can I obtain the certificate by declaration if it does not support it?

A: The official guideline clearly requires that the phone only needs to support OSNMA authentication readiness at this stage, but it is not mandatory to support authentication usage/ processing, so you cannot obtain the certificate by declaration.

Q9: If the phone only supports Galileo single-band E1, does it meet the regulatory requirements? Does it have to support Galileo dual-band? Is it possible to support Galileo only?

A: It is not mandatory to support Galileo dual-band, and supporting Galileo single-band can meet the requirements. However, in order to meet the positioning accuracy requirements, you need to cooperate with other satellite positioning systems for mixed positioning, such as GPS, Glonass, Beidou, so you must support at least two kinds of satellite positioning systems.

Q10: Does AML test need to support both SMS and https transmission?

A: Both SMS and https transmission should be supported.

Q11: Does UKCA need to be tested?

A: No, it is not required. UKCA is building its own satellite positioning system and will not use Galileo system in the future.

About BACL

Bay Area Compliance Labs Corp (BACL for short), founded in 1996, is a comprehensive third-party testing and certification organization integrating testing, certification, inspection, equipment manufacturing, metrological calibration, laboratory information consulting, software development and technical training. At present, BACL has more than 2000 employees, more than 10 comprehensive laboratories and more than 40 branches around the world. It has set up local service institutions in Asia, South America, Africa, the Middle East and other regions, which can provide customers with one-stop testing and certification services such as electromagnetic compatibility, radio frequency, safety, energy efficiency, physics and chemistry, reliability, factory inspection and international certification.