New KC Certification vs Report of Change under the RADIO WAVES ACT

As test report is required for KC Certification, it costs a lot to obtain KC Certification.

If some minor changes are made to the KC-certified equipment, the KC applicant can save money by reporting changes instead of new KC Certification under Article 58-2 (5) of the RADIO WAVES ACT (전파법) - When any person who has undergone conformity assessment under paragraphs (2) and (3) intends to revise matters related to such assessment, he/she shall file a report with the Minister of Science and ICT. In such cases, when revisions to matters related to the technical requirements for conformity assessment, among the matters he/she intends to revise, are included, he/she shall undergo conformity assessment under paragraphs (2) and (3), with regard to the relevant matters.

 

Then, what matters are related to the technical requirements for conformity assessment, which requires new KC Certification when any changes are made? The scope is stipulated in Article 15 of the RRA Notification, NOTIFICATION ON CONFORMITY ASSESSMENT OF BROADCASTING AND COMMUNICATIONS EQUIPMENT, ETC. (방송통신기자재등의 적합성평가에 관한 고시), which was amended on April 18, 2023.

 

Amended on April 18, 2023 Article 15 (Scope of revised matters, etc.) (1) Revised matters related to conformity assessment criteria under Article 77-4 of the Enforcement Decree are as follows. In this case, among the conformity assessment criteria under Article 4, only the criteria related to the revised matters may apply.  1. Change of circuit (including printed circuit), change due to replacement or addition of components, change due to removal, replacement, or addition of component elements, or change enabling selective use   2. Change of test items of conformity assessment criteria under Article 4 by implementing or adding new functions, etc. using software without hardware change (However, general-purpose information devices that are manufactured to allow general users to directly install and operate various software, such as computers, smartphones, smart TVs, etc. are excluded from the revised matters.)   3. Change of used frequency or technological method of the equipment that has undergone conformity assessment without hardware change according to frequency allocation under Article 11 and 12 of the Radio Waves Act. (2) Revised matters related to the maintenance and management of the equipment that has undergone conformity assessment, which are not related to the conformity assessment criteria are as follows.   1. Change of derivative model name   2. Change of manufacturer or country of manufacture   3. If a person who received conformity assessment changes his/her name, address, or company name for the following reasons.     a. Inheritance or transfer/merger/division of a corporation (including business division within a corporation)     b. Conversion of an individual entrepreneur to a corporation (if the individual entrepreneur is the same as the representative of the corporation)     c. Transfer/Acquisition to a corporation or an individual entrepreneur     d. Other simple change of name, address, or company name   4. <Deleted>   (3) In spite of paragraph 1, following cases may be regarded as revised matters not related to conformity assessment criteria.     1. Blocking or deleting functions in use using software without hardware change   2. Revised matters related to the common application criteria under Article 4 (1) 1 as follows.     a. Replacing resistors, inductors, and capacitors with component elements of the same kind (However, they can be replaced regardless of the electrical size or capacity of component elements.)     b. Replacing diodes (including light emitting diodes) with diodes of the same kind     c. Reducing power capacity (wattage) while the electrical circuit is the same     d. Removing components from the product that has undergone conformity assessment     e. Replacing computer built-in components [Item 35 of Paragraph I of Section 11 of Annexed Table 1] with components of equivalent function that have undergone conformity assessment     f. Replacing the components of the equipment that falls under Item 2 or 3 of Paragraph P of Section 11 of Annexed Table 1 with components of equivalent function, or adding components that have undergone conformity assessment to the relevant equipment   3. Revised matters related to the application criteria of wireless field under Article 4 (1) 2 as follows:     a. Replacing wireless transmission/reception parts (or finished products with wireless function) with other wireless transmission/reception parts (or finished products with wireless function) of equivalent function that have undergone conformity assessment     b. Removing wireless transmission/reception parts (or finished products with wireless function)

Before Article 15 (Scope of revised matters, etc.) (1) Revised matters related to conformity assessment criteria under Article 77-4 of the Enforcement Decree are as follows. In this case, among the conformity assessment criteria under Article 4, only the application criteria related to the revised matters may apply.     1. Change of circuit (including printed circuit), change due to replacement or addition of components, change due to removal, replacement, or addition of component elements, or change enabling selective use (which shall not affect the type code)   2. Change of test items of conformity assessment criteria under Article 4 by implementing or adding new functions, etc. using software without hardware change (Except for the case where the device code of wireless equipment is added, the type code may be changed. However, general-purpose information devices that are manufactured to allow general users to directly install and operate various software, such as computers, smartphones, smart TVs, etc. are excluded from the revised matters.)   3. Change of used frequency or technological method of the equipment that has undergone conformity assessment without hardware change according to frequency allocation under Article 11 and 12 of the Radio Waves Act.  (2) Revised matters related to the maintenance and management of the equipment that has undergone conformity assessment, which are not related to the conformity assessment criteria are as follows.   1. Change of derivative model name   2. Change of manufacturer or country of manufacture   3. If a person who received conformity assessment changes his/her name, address, or company name for the following reasons.     a. Inheritance or transfer/merger/division of a corporation (including business division within a corporation)     b. Conversion of an individual entrepreneur to a corporation (if the individual entrepreneur is the same as the representative of the corporation)     c. Transfer/Acquisition to a corporation or an individual entrepreneur     d. Other simple change of name, address, or company name   4. <Deleted>  (3) In spite of paragraph 1, following cases may be regarded as revised matters not related to conformity assessment criteria.     1. Blocking or deleting functions in use using software without hardware change   2. Revised matters related to the common application criteria under Article 4 (1) 1 as follows.     a. Replacing resistors, inductors, and capacitors with component elements of the same kind (However, they can be replaced regardless of the electrical size or capacity of component elements.)     b. Replacing diodes (including light emitting diodes) with diodes of the same kind     c. Reducing power capacity (wattage) while the electrical circuit is the same     d. Removing components from the product that has undergone conformity assessment     e. Replacing computer built-in components [Item 35 of Paragraph I of Section 11 of Annexed Table 1] with components of equivalent function that have undergone conformity assessment     f. Replacing the components of the equipment that falls under Item 2 or 3 of Paragraph P of Section 11 of Annexed Table 1 with components of equivalent function, or adding components that have undergone conformity assessment to the relevant equipment   3. Revised matters related to the application criteria of wireless field under Article 4 (1) 2 as follows:     a. Replacing wireless transmission/reception parts (or finished products with wireless function) with other wireless transmission/reception parts (or finished products with wireless function) of equivalent function that have undergone conformity assessment     b. Removing wireless transmission/reception parts (or finished products with wireless function)

To understand the effect of the deletion of underlined provisions, we need to understand what the type code is.

Type code consists of Equipment Code, Frequency, Transmission/Reception Classification, Electric Power, Transmission Format, and Channel. Depending on the type of equipment, some of the code components are omitted in the type code as follows: 

Equipment Group	Equipment Code	Frequency	T/R	Electric Power	Transmission Format	Channel
1. Device of digital selective calling equipment	○
2. Dedicated receiver for digital selective calling	○
3. Device of narrowband direct printing telegraph equipment	○
4. Device of transmitting and receiving equipment among devices of digital selective calling equipment for maritime mobile service	○	○	○	○	○	○
5. Device of transmitting equipment among devices of digital selective calling equipment for maritime mobile service	○	○	○	○	○	○
6. Device of receiving equipment among devices of digital selective calling equipment for maritime mobile service	○	○	○		○	○
7. Device of location information transmitting equipment for search and rescue purposes	○			○
8. Navigational telex receiver	○
9. Device of wireless beacon equipment for satellite emergency location indication	○	○		○
10. Shortwave duplex wireless telephone equipment	○	○	○	○	○	○
11. Ultra-shortwave marine mobile service wireless equipment	○	○	○	○	○	○
12. Wireless equipment of on-board communication stations	○	○	○	○	○	○
13. Device of simplex wireless telephone equipment (Equipment for maritime mobile service)	○	○	○	○	○	○
14. Automatic alarm telephone equipment	○
15. Wireless alarm automatic receiver	○
16. Ship station radar equipment	○	○		○	○
17. Wireless direction measuring equipment	○
18. Equipment of radio buoy	○	○		○	○
19. Device of wireless equipment for automatic identification system	○	○	○	○	○
20. Device of wireless equipment established at mandatory aviation ground stations	○	○		○	○	○
21. Devise of wireless equipment for makeshift radio stations	○	○	○	○	○	○
22. Device of wireless equipment for wireless detection operation	○	○	○	○	○
23. Device of wireless equipment for industrial and public use	○	○	○	○	○	○
24. Device of wireless equipment using simplex wave (Equipment for land mobile service)	○	○	○	○	○	○
25. Wireless equipment for meteorological support	○	○		○	○
26. Device of wireless equipment for wireless calling stations (Commonly apply to equipment of Section 3 and 4 of Annexed Table 1.)	○	○	○	○	○	○
27. Device of wireless equipment for frequency-shared communication (Commonly apply to equipment of Section 3 and 4 of Annexed Table 1.)	○	○	○	○	○
28. Device of wireless equipment for broadcasting production and performance support	○	○	○	○		○
29. Device of wireless equipment for emergency communication assistance	○	○	○	○	○	○
30. Device of wireless equipment for maritime security and safety network	○	○	○	○	○	○
31. Wireless equipment for integrated public network	○	○	○	○	○
32. Wireless equipment for transmitting maritime distress position	○	○	○	○	○
33. Wireless equipment for intelligent transportation systems	○	○	○	○	○	○
34. Device of wireless equipment for MCA mobile communication (Transmission format can be omitted for simple repeater.)	○	○	○	○	○
35. Device of wireless equipment for personal mobile communication (Transmission format can be omitted for simple repeater.)	○	○	○	○	○
36. Device of wireless equipment for IMT mobile communication (Transmission format can be omitted for simple repeater.)	○	○	○	○	○
37. Device of wireless equipment for LTE mobile communication (Transmission format can be omitted for simple repeater.)	○	○	○	○	○
38. Device of narrowband Internet of Things (NB-IoT) wireless equipment	○	○	○	○	○
39. Device of wireless equipment for 5G NR mobile communication (28 ㎓) (Transmission format can be omitted for simple repeater.)	○	○	○	○	○
40. Device of wireless equipment for 5G NR mobile communication (3.5 ㎓) (Transmission format can be omitted for simple repeater.)	○	○	○	○	○
41. Device of wireless equipment for emergency wireless telephones	○	○	○	○	○
42. Device of wireless equipment for satellite mobile communication	○
43. Device of wireless equipment for wireless data communication	○	○	○	○	○
44. Device of wireless equipment for maritime mobile telephones	○	○	○	○	○	○
45. Device of wireless equipment for mobile internet	○	○	○	○	○
46. Device of wireless equipment for location-based services	○	○	○	○	○
47. Device of wireless equipment for subscriber lines	○	○	○	○	○
48. Device of wireless equipment for personal wireless stations	○
49. Wireless device of weak electromagnetic field strength	○
50. Wireless device of magnetic field induction	○
51. Specific low-power wireless device (If field strength is measured, channel and electric power are omitted.)	○
52. Wireless device for RFID (Radio Frequency Identification) (If field strength is measured, electric power is omitted.)	○
53. Wireless Device for USN (Ubiquitous Sensor Network) (If field strength is measured, electric power is omitted.)	○
54. Cordless telephone	○
55. Device using UWB (Ultra-Wideband) technology	○
56. Wireless device for unspecified purposes	○
57. Implantable wireless medical device	○
58. Wireless device for object detection sensors	○
59. Device of wireless equipment for TVWS (TV White Space) data communication	○
60. Wireless device for level measurement radars	○
61. Device of medical equipment using high-frequency current	○	○		○
62. Device of wireless equipment for amateur radio stations	○	○	○	○	○	○
63. Shortwave digital transceiver	○	○	○	○	○	○
64.Device of wireless equipment for 5G mobile communication (when a radio station is built and operated only within a certain area (building, etc.)) (28 ㎓ band) (Transmission format can be omitted for simple repeater.) (※ Commonly apply to equipment of Section 3 and 4 of Annexed Table 1.)	○	○	○	○	○
65.Device of wireless equipment for 5G mobile communication (when a radio station is built and operated only within a certain area (building, etc.)) (4.7 ㎓ band) (Transmission format can be omitted for simple repeater.) (※ Commonly apply to equipment of Section 3 and 4 of Annexed Table 1.)	○	○	○	○	○
66. Autonomous maritime wireless device	○	○	○	○	○

 

A laptop having wireless function belongs to the equipment group of 51. Specific low-power wireless device whose type code consists only of Equipment Code, which prescribed in Annexed Table 1 as follows:

5. Devices of wireless equipment for radio stations that can be established without reporting

Relevant Equipment

Application Criteria of Conformity Assessment

Type of Conformity Assessment

Equipment Code

Other

Electromagnetic Compatibility

Wireless

Wired

Protection against Electromagnetic Radiation

Certification of Conformity

Registration of Conformity

Electromagnetic Radiation Absorption Rate

Electromagnetic Field Strength

Designated Lab Testing

Self-Testing

D. Specific low-power wireless device

1) Wireless control device

○

○

○

LARN1

2) Wireless device for data transmission

○

○

○

LARN2

3) Wireless device for safety system

○

○

○

LARN3

4) Wireless device for transmission of voice and audio signal

○

○

○

LARN4

5) Wireless device for wireless access system, including wireless LAN

a) Frequency band: 5150∼5350㎒, 5470∼5850㎒

○

○

○

○

LARN5

b) Frequency band: 5925∼6425㎒

○

○

○

○

LARN5A

c) Frequency band: 5925∼6425㎒

○

○

○

○

LARN5D

Wireless device used only in subways

d) Frequency band: 5925∼7125㎒

○

○

○

○

LARN5B

Wireless device used only in buildings

e) Frequency band: 17700∼17740㎒, 19260∼19300㎒

○

○

○

LARN5C

6) Wireless repeater device

○

○

○

LARN6

7) Radar wireless device for vehicle collision prevention

○

○

○

LARN7

8) Wireless device for wireless data communication system

○

○

○

○

LARN8

9) Wireless device for identification of moving objects

○

○

○

LARN9

10) Wireless device for small base stations

○

○

○

FTC

11) Wireless device for road information detection radar

○

○

○

RDR

12) Wireless device for intelligent transportation systems

a) Wireless device of 5855∼5875㎒

○

○

○

ITSOL

b) Wireless device of 5895∼5925㎒

○

○

○

ITSOW

13) Wireless device for disaster alert broadcasting

○

○

○

CWB

 

A laptop with Wi-Fi 6 function (Frequency: 5GHz) is subject to certification of conformity and its relevant type code is LARN5 and LARN8.

When Wi-Fi 6e function (Frequency: 6GHz) is added to the laptop, it is still subject to certification of conformity and LARN5B is added to its type code.

Under the previous regulation, the addition of Wi-Fi 6e function requires new KC Certification because it involves the change of type code. However, under the amended regulation, it suffices to report the change.

               

On the other hand, a wireless device for RFID belongs to the equipment group of 52. Wireless device for RFID (Radio Frequency Identification) whose type code consists only of Equipment Code, which prescribed in Annexed Table 1 as follows:

5. Devices of wireless equipment for radio stations that can be established without reporting

Relevant Equipment		Application Criteria of Conformity Assessment					Type of Conformity Assessment			Equipment Code
		Electromagnetic Compatibility	Wireless	Wired	Protection against Electromagnetic Radiation		Certification of Conformity	Registration of Conformity
					Electromagnetic Radiation Absorption Rate	Electromagnetic Field Strength		Designated Lab Testing	Self-Testing
E. Wireless device for RFID (Radio Frequency Identification)	1) Frequency band: 900㎒	○	○		○		○			RFID1
	2) Frequency band: 433㎒	○	○					○		RFID2
	3) Frequency band: 13.56㎒	○	○					○		RFID3

 

A wireless device for RFID with 13.56㎒frequency band is subject to registration of conformity based on designated lab testing and its relevant type code is RFID3.

When the frequency band is extended to 900㎒, not only the type code is changed to RFID1 but also the type of conformity assessment is changed to certification of conformity.

Then, it’s beyond the scope where the revised matter can be covered by reporting of change even under the amended regulation. New KC Certification is required to cover the change.

So, when a new wireless function is added to a KC-Certified equipment, we should confirm whether the change can be covered by reporting of change or new KC Certification is required.