Hi Anders There are several issues that need to be addressed in your question. The first is that the Part 15 Module is not the same as a license modular transmitter and different issues may need to be addressed for each. At the present time the FCC really does not look at Part 15 Modular approvals under DA001407 the same as they do licensed modular transmitters. What also must be remembered about Part 15 modular approvals is that regardless of the grant notes that may exist, it is implied that all such transmitter have the no collocation condition. The exception is when the grant notes specifically add collocation to another specified transmitter. Obviously then, collocation issues cannot be ignored and they must be addressed.
Please note that there is not such thing as a “Self Declaration” for either of these type devices. Consequently the collocation issues presented on both grants need to be addressed. Perhaps you are confusing the allowance for the statement “Contains FCC ID:xxxx” as ‘self declaration’. Please note that this should not be mistaken as a ‘self declaration’ of compliance. Simply put – there aint no such thing for these type transmitters. For example, at all times and in all hosts compliance of a Part 15 transmitter done under the full Modular approval scheme of DA001407 is the responsibility of the grantee for that module. The exception would be of course if the grant (including grant notes) is violated. In such a case of grant violation the person placing the module inside a device is illegally using the Part 15 Module and is responsible. As to why these restrictions exist: There are again several issues. The most important reason for collocation would deal with SAR or MPE issues. This is typically why the minimum 20cm separation distance for mobile use is placed in the grant notes. A secondary important issue deals with the fact that it is not know how EMC of the two transmitters are affected when the antenna of each is placed in proximity of the other. There are several ways in which you can appropriately address the no collocation requirements. Probably the easiest for you as an OEM putting two approved modular devices into his system would be to have the manufacturer of each separate device do a PC to allow collocation with the other transmitter in your host. Another method would be for you to obtain your own FCC ID number with both transmitters. You could also make sure that the two transmitters do not co-transmit (do not transmit at the same time). In this way, collocation would not be an issue. Lastly, the 20 cm separation requirement used on grants really applies to MPE considerations and not necessarily to EMC considerations. The FCC does appear to accept this distance as a ‘breaking’ point for collocation. This however, might depend on the power involved in the transmitters themselves. That said if you can maintain a minimum of 20cm separation between the two antennae in the system, the collocation issue should not be a problem under most circumstances. This way you could simply place the “Contains FCC ID:xxxxxx” where xxxxx would be the FCC ID of each device in your system. Of course, as indicated above, you should be careful here too as it may depend on the power of the transmitters which would determine any collocation resolution. Generally speaking however, the 20cm separation is sufficient. There are other ways to address this, but the above are the easiest. Thanks Dennis Ward Director of Engineering American TCB Certification Resource for the Wireless Industry www.atcb.com 703-847-4700 fax 703-847-6888 direct - 703-880-4841 NOTICE: This E-Mail message and any attachment may contain privileged or company proprietary information. If you received this message in error, please return to the sender. _____ From: [email protected] [mailto:[email protected]] On Behalf Of Anders Svensson B Sent: 01/08/2008 1:19 AM To: [email protected] Subject: FCC co-location Dear experts, I have found that the FCC grants (FCC part 15) for WLAN modules and GSM modules have a restriction that says that they must not be co-located with other antenna or transmitter. In our coming product we have two modules which is co-located, how do we solve this problem? Our thoughts right now is to use the modules FCC grants and do a FCC Self Declaration for the transmitting part for our units (i.e. no own FCC id for our product). For my understanding: Why do the modules FCC grants have this restrictions? Can the manufacturer update the FCC grants without this restrictions and that are needed for that? Have we any more solutions to solve this? Any inputs is very much appreciated Thanks Regards Anders - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. 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