We are marking a product with the RCM and have done relevant emissions
testing for the complete product.  The intent from the start has been to
leverage the testing and certifications the supplier obtained to reduce
the amount of testing needed for the end product (a "modular approach" in
a global scale).

An IEEE 802.11 intentional radiator is incorporated into the product.  The
product incorporates a supplier's reference design that has been tested
against relevant ETSI standards for EU deployment.  These ETSI standards
are referenced  by AS 4268.  However, we do not have a test report that
explicitly mentions AS 4268 or a certificate indicating compliance with AS
4268 from the supplier.

In reading the Radiocommunications Labeling Notice, a 2014 revision adds
AS 4268 as a requirement.

I am asking the supplier to obtain at least a certificate showing
compliance with AS 4268, but they are pushing back, indicating they would
need to mark their chipset with the RCM.  This is an inappropriate use of
the RCM, since it apples to complete products.  The supplier has not been
able to identify the marking the claim is needed for their chipset.  The
802.11 intentional radiator is not being used for audio signals.

I am asking for the certificate or an amended report that explicitly
mentions AS 4268 to avoid having to go through unnecessary gyrations
should the compliance status of the intentional radiator come into
question.  My intent is also to no have to explain why the ETSI testing
covers the requirements in AS 4268 to a bureaucrat with limited technical
knowledge and to also satisfy customer requests for evidence of
compliance.

Am I asking too much of the supplier?


Regards,

Peter L. Tarver

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