Librem 5 FCC Certification

Hardware Librem 5
1

Now that the Librem 5 is shipping in production quantities, what is the status of the certification with the FCC (United States)? If a certification number has been issued, does anyone here know it? Does Purism need to get the Librem 5 certified in every country they ship to?

I buy both Amateur radio radios and part 90 (commercial) radios on Amazon. When it comes to the part 90 radios, I’ve noticed that if the radio isn’t from an American company (particularly if it’s from China), it may be advertised for use in a specific radio service that it is not certified for, and sometimes has no FCC certification at all. Of course that’s not relevant for the part 97 radios. But as an amateur radio operator, I know enough to want to comply with the rules of any radio service I use. It would be interesting to see what psrt of the FCC rules the cell phones are licensed under and to know Purism’s plans for FCC certification of the Librem 5.

3 Likes
2

It has been mentioned in various places that Purism is still in the process of getting the Librem 5 Evergreen FCC certified, since they had to wait for actual devices to be in hand before starting the process. If you are in line to be shipped a phone before the FCC certification is complete, you can request your shipment deferred until after FCC certification is obtained.

Purism will probably have to get certified by whatever governing body oversees radio device certification in the countries they are shipping to, depending on the country. Meaning they will also be getting CE certified for European countries. I’m not sure about approval in other non-US, non-European countries.

3

Isn’t the certification of a modem itself enough?

4

I’m not a lawyer, but Purism has mentioned that since the major radio-emitting components of the phone (wifi + cellular cards) are already certified, it’s a bit of a gray area. I am doubtful that the FCC is going to do anything with such a (relatively) small product launch and the fact that Purism seems to be making a best effort attempt at certification, given the timing.

4 Likes
5

but who certifies the FCC certification ? :upside_down_face:

1 Like
6

modem is already certified, the certification is of the device as a whole.

2 Likes
7

Irrelevant, as the only reason your are getting certification is to operate within the bounds of the law, especially in this case where the only things emitting are already certified.

8

Perhaps the modem certification might be enough. But I am not sure about that. Actually, anything that transmits any kind of radio frequency in the US has to receive a certification from the FCC to be legal. This should include both the modem chip and also the phone itself. Each different radio service has different requirements per applicable statutes that are specific to that radio service. The only radio transmitters that I am aware of that do not require ‘type acceptance’ of the radio in the US are amateur radio transmitters.

The ‘type acceptance’ is achieved by having an independent certified laboratory run required tests and then signing-off that the given radio passed all of those tests. Then the FCC will certify the radio. The tests are both technical and functional. For example, a citizens band radio can comply with all technical specifications for RF emissions and still fail if (for example) the CB radio is capable of being used for a different radio service also, without internal modifications. For example, it is easy to buy a non-certified radio from China (right on Amazon even) that will transmit and receive on many different radio service bands all from the same radio (commercial, amateur, GMRS, MURS, marine, military, police/fire, others). But because it will work on more than one radio service, it can’t be certified for legal use in any radio service. This requirement is for political and not technical reasons because there are no technical reasons to not allow this. Likewise for political reasons, cell phone radios might have politically driven statutory requirements to receive an FCC certification. Sometimes it may not make sense to the average person why some requirement may exist.

I have had some concern about the following. If the modem in the Librem 5 is capable of transmitting outside of legal cell phone frequencies, there could be legal road blocks to getting it FCC certified. In VHF and UHF transceivers, all transmitter and receiver circuits are made to cover the whole (or most of the) VHF or UHF band. The radio can only be certified in most cases, because the software or firmware prohibits out-of-band transmissions. So if a taxi company uses UHF radios to communicate with their fleet, the proprietary (closed source) software or firmware prevents the radio from transmitting on police or fire department frequencies. Under these conditions, the FCC will certify the radio that is sold to the taxi company. If the company that sold the radio to the taxi company were to use open source software, would the FCC still certify that radio? Pretty much any programmer can alter the taxi company radio in that case, to transmit on police frequencies. With the police and fire companies migrating to higher frequencies and trunked systems now, the FCC is loostening-up on enforcement lately. You can even buy a Chinese UHF radio now that is certified by the FCC (under Part 90) for commercial use and that also has a VFO (a big no-no for anything except amateur radios) that can be unlocked. So there are now commercial radios that can be unlocked to dial-in any frequency from a key pad instead of having locked-in channels. That wouldn’t have been allowed thirty years ago when police and fire departments relied on their use of VHF and UHF two-way radio systems.

If a modem in the Librem 5 could be programmed to operate outside of legal cell phone frequencies, there could be a problem. With open-sourced software or firmware, anyone might be able to program the modem to operate lillegally. There are no lock-outs to prevent this. In addition, the cell phone companies might have valid legal grounds to ban the use of these phones on their system if the software or firmware could tune the phone to do things that compromise their cellular phone system. For technical reasons, all radio circuits have to be made to operate outside of the band of their intended use. Like a car engine, if you want it to work well for its intended use, it has to be capable of greatly exceeding that intended use. In this metaphor of the car engine, only a governing device could render the device incapable of illegal use. Such a governing device in a radio transmitter would have to be proprietary locked firmware. To design a radio to fail just outside of its legal operating frequency would be like designing a car engine that runs well up to the speed limit, but that fails for technical reasons at only one mile per hour above the speed limit. No, you need governing firmware to do this in a radio transmitter. Whether or not the FCC will allow that firmware to exist in the public domain in a certified radio is the question. The only other alternative would be to trust the modem manufacturer to have proprietary locked firmware that we have no access to.

3 Likes
9

I understand your concerns and appreciate the thoughtful considerations.

Whether or not the FCC will allow that firmware to exist in the public domain in a certified radio is the question.

I think this is the biggest question and I hope the FCC updates its laws with the technology.

I’ve never done amateur radio, but it seems to me that the increasing popularity/feasibility of SDRs will hopefully really motivate the FCC to rethink its approach… Since presumably SDRs could be configured with open source software/firmware to receive and transmit on a wide range of frequencies.

10

Amateur radio operators are trusted a small amount more, by not requiring them to use certified radios on their alloted frequencies. But with respect to all other radio services, the FCC dis-trusts us all equally. But if an amateur radio operator is found to be in violation on other radio services, the ignorance-as-excuse bar is often much higher. As it is, officially ignorance isn’t an excuse in any case. I read where a non-licensed person used the amateur radio in his brother’s truck to call for emergency help. It saved someone’s life but the guy still had to pay a $30,000.00 fine. Someone assumed that the otherwise illegal operation exemption in emergencies extended to non-licensed users. But the statute limits those kinds of exemptions to only licensed amatures who may (for example) go outside of their assigned frequencies in emergencies. Also, commercial sellers of amateur radios still have compliance requirements on the equipment they sell to amateur operators. This is only relevant to show that speculation and common sense or assumption do not often apply. Only the applicable statutes apply. So someone somewhere should do the applicable research with respect to the statutes that apply to cell phone services. I would hate to see the FCC shut down the shipping of Librem 5 phones after the demand has ramped up in to the millions of phones. It is possible that the governing statutes may still not have matured, leaving some wiggle room. But that too is only a guess or assumption.

Purism may be operating in a gray or unregulated area with respect to these radios. Technically, the WiFi module could face similar issues. Whether or not Purism can share their strategy with us in these areas, I hope they have done their research themselves and have a pro-active plan with respect to the applicable statutes. In the case of most L5 users, traditional strategies may be appropriate. The average L5 customer may not be capable of altering the applicable code on their own radio. But I can hardly wait to see both the code and the modem specifications. There are large blocks of frequencies that licensed amateurs are legally allowed to play-in, spread throughout the GHz bands. If there is one close-by to the L5 of modem frequencies, myself or someone else may attempt to alter the code to go there. Theoretically, amateur radio operators could create their own free exclusive cell phone service for licensed amateurs this way if the hardware permits.

1 Like
11

if the only way to get protection by the LAW is to have a proprietary modem-firmware how would anyone know - in the case of 5G or later(?) modems - what the exact operating frequency picked by the black-box is at any point in time during data/voice use on the cellular network ?

if the firmware of the modem is to be considered hardware (for all intents and purposes), then how can ANY independent scientific-studies be carried out ? simply by measuring the RF radiation emanation ? what is to prevent that black-box modem from emitting on the highest POSSIBLE frequency when it is NOT being TESTED ?

hence my previous question … who certifies the FCC ?

or rather … what is more important ? to comply with the LAW or to be able to GUARANTEE that UNSAFE frequencies aren’t being used by BILLIONS of IOTs around the world during a PLANdemic ? :mask: :upside_down_face:

12

What is the reason that you don’t write “pandemic”?

13

As an aside, a manufacturer can only ship a small number of “prototypes” and “market trials” without an FCC ID.

Is that true? Just seen that on reddit, in this comment.

14

Without getting into a war on the Purism boards, I would suggest you do a google search on the term as written. It communicates a specific mindset and system of beliefs relating to the current situation.

1 Like
15

honestly it would make me VERY happy to be wrong about this “pandemic” but since 'rona-chan symptoms and case-numbers are used loosely at best …

16

Could we all try to keep to the topic, please? Otherwise, discussions like this will end up in low quality innuendo and name-calling, leaving nobody really very happy with the outcome.

10 Likes
17

Something about needing it to import? If modem is already certified does that cover the L5 which is mostly imported?
18

As I understand it (but I’m no expert), anything that can emit radio signals needs to be certified by the FCC that it does not interfere with other things. So the modems and radios in the L5 need to be certified, and they probably already are. The circuitry and antennae in the phone itself also needs to be certified, with the probably-already-certified components installed, so that the phone as a whole device can be certified and compliant. The latter process is in progress but takes some weeks to accomplish, but Purism must (I’d say for good reason) feel confident enough that the phone already conforms to whatever the FCC regulations stipulate or else they wouldn’t start shipping them yet.

So, the way to look at it is this: Purism says their phone is compliant. The FCC hasn’t come back yet to say whether their phone is compliant. If you were to get your shipping email today and if you trust Purism (or otherwise don’t care), you can go ahead and get your phone. If you don’t and want to wait on the FCC’s rubber stamp of approval, Purism gives you the option to wait to receive your phone until the FCC gives their blessing.

Again, my understanding, which may not be super accurate.

3 Likes
19

Yes, these two previous posts seem to be on-track with the legal requirements. The various parts of 47 CFR are thousands of pages of statute/technical issues. It’s very boring but also very relevant. It is somewhat organized, but does require a lot of cross-referencing to fully digest everything that might be relevant. Purism appears to be following the proper legal procedures and I didn’t want to suggest otherwise.

I have purchased a few Chinese two-way radios from Amazon and due to the non-compliance of some sellers there with these rules, I’ve become more sensitive to wanting to go by the book (the relevant 47 CFR sections). Some sellers on Amazon will blatently explain how to use their products in illegal ways as actual selling features of their products. After your interests in Amateur radio mature, the concept of pirate operations become un-appealing and ‘compliance’ becomes more important. The FCC just recently issued a few orders that clarify a few issues that will even change how I can use some of my existing radios. For example, technically, your UV-5R is either an Amateur radio or a Part 90 commercial radio. But it can’t legally be programmed to be both at the same time and can’t be used on commercial frequencies on high power at all because it exceeds the legal 2 Watt limit for part 90 handheld radios, despite its Part 90 certification. A GMRS radio can use Part 90 hardware as long as no non-GMRS frequencies are programmed in to it and that explicitly excludes the use of Part 97 (amateur radio frequencies), if any GMRS frequencies are also programmed in to the radio at the same time. For the average person, the implications of this kind of issue may be un-noticable from a practical perspective. But from what I can tell, I may need to purchase a second L5 if I want to try to use it on any of the amateur radio bands (if that is even possible). Having access to both the software and firmware of a GHz band radio seems intriguing. In most radios once you get that far, the radio will most often be close enough to one Amateur radio band or another, to work there by simply making easy tweaks to the code. At the same time I look and say to myself “how can I experiment this way and not void my legal authority to use the phone as a phone afterward”. That leads to the question of what certifications of the phone itself are even required to begin with, and how the FCC would answer that same question. It might be fun to develop an exclusive ham-radio free (as in free beer) cell phone network. It could be the ultimate repeater/auto-patch replacement. But the FCC probably won’t let us program the same physical phone for both purposes at the same time (a cell phone capable of going outside of the legal cell phone bands even if you do have a personal license that allows doing that), if it can be done. They’ll probably require a separate phone for each different form of license used). This whole discussion has been a moot point until just now, given all of the proprietary code and root access lock-outs in the Apple and Android phones.

1 Like
20

Because he’s stating facts overtly

1 Like