John, In my experience, it will be easier to just get a new FCC ID. I used to use modular approvals extensively but gave up due to the complexities of managing someone else’s Grant and disappearing cost savings once integrated into a “portable” device.
1) You’d have to update your module vendor’s grant with a permissive change filing, which is not necessarily a problem but the additional paperwork can grow over time. 2) Changes to your device may require updates to the grant at a later date. I’ve seen this happen more than I’d like to remember. 3) If this plan is used too often, finding your product in the huge list of C2PC filings on the FCC’s website under the module FCC ID can be an inconvenience. Compare this to obtaining a new FCC ID: 1) You can still re-use your supplier’s FCC reports to eliminate the same testing you would eliminate using the modular approach. 2) Changes to your device can be addressed internally – no need to involve the module supplier 3) Finding your device’s FCC Filing is trivial – you have your own FCC ID. None of these items are showstoppers, but they add complexity. In summary, once you enter the realm of portable devices that require SAR, the cost savings that could be gained from using a modular approval disappear quickly. You still get the benefit of test avoidance for some tests that are still isolated to the module, but the number of integrated tests (radiated spurious emissions, SAR, collocated radios (if applicable), etc…) will be applicable whether you use the modular approach or just re-use the module’s RF reports in your filing. My personal convenience quickly became the deciding factor, and I know quite a few of my former coworkers had a similar revelation. Just some food for thought. Best Regards, -Dave Heald From: [email protected] [mailto:[email protected]] On Behalf Of John McAuley Sent: Monday, September 13, 2010 8:26 AM To: [email protected] Subject: SAR Testing and FCC ID Hi Group We have a product that will contain a 2.4 GHz device that has modular approval and an FCC ID. The FCC grant states: “Approval is limited to OEM installation only. The antenna(s) used for this transmitter must be installed to provide a separation distance of at least 20 cm from all persons and must not be co-located or operating in conjunction with any other antenna or transmitter.” This product is now being used in a device which will be body worn and therefore less than 20cm. We are having an appropriate SAR test carried out to ensure that it complies. Is it necessary to get a new FCC grant or can we list the original FCC ID on the outside of the product and not involve a TCB again? Many thanks John McAuley www.cei.ie [email protected] ***************************************************************** DISCLAIMER: The information contained in this e-mail may be confidential and is intended solely for the use of the named addressee. Access, copying or re-use of the e-mail or any information contained therein by any other person is not authorised. If you are not the intended recipient please notify us immediately by returning the e-mail to the originator - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <[email protected]> All emc-pstc postings are archived and searchable on the web at http://www.ieeecommunities.org/emc-pstc <http://www.ieeecommunities.org/emc-pstc> Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <[email protected]> Mike Cantwell <[email protected]> For policy questions, send mail to: Jim Bacher <[email protected]> David Heald <[email protected]> ________________________________ This e-mail and any attachments may contain confidential material for the sole use of the intended recipient. If you are not the intended recipient, please be aware that any disclosure, copying, distribution or use of this e-mail or any attachment is prohibited. If you have received this e-mail in error, please contact the sender and delete all copies. Thank you for your cooperation. - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <[email protected]> All emc-pstc postings are archived and searchable on the web at http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <[email protected]> Mike Cantwell <[email protected]> For policy questions, send mail to: Jim Bacher <[email protected]> David Heald <[email protected]>
