Dennis, Thank you! Where did you get your information? I got a response to my inquiry into the FCC faster than normal. It seems like they have a fairly generic form they send out for questions concerning modular licensed transmitters. It’s also very similar to what you have outlined, except you provided even more insight regarding changing out antennas. Though, I imagine if we had an actual modularly approved radio device, the user guide or the grant would have notes listed antenna requirements.
Response: General guidance for licensed-service module-like (licensed module) transmitters for use in final products: Modular Approval procedures in FCC Public Notice DA-00-1407 are for Part 15 devices only [see also 47 CFR 15.212 (FCC 07-56)]. The FCC does not have corresponding procedures for modules in licensed radio services. The requirements of 15.203 (unique antenna) and 15.204 (transmitter and antenna marketed as complete system) are not directly applicable for licensed modules. Generic licensed modules without specific antennas may be certified for use only in final products operating in fixed or mobile RF exposure conditions. Maximum antenna gain, to ensure compliance with RF exposure limits and/or categorical exclusions, is listed in the remarks field of the grant certificate. Maximum allowed antenna gain shall account not just for compliance with MPE limits but also with service-rule ERP / EIRP limits, where applicable. A licensed module must have an FCC ID label on the module itself, visible through a window on the final device or when an access cover is easily removed; if not visible, a second label must be placed on the outside of the final product stating: Contains FCC ID: 01234567. The device description or grant remarks fields of the grant certificate must include the words modular transmitter or transmitter module. Other than for RF exposure and radiated power and/or emissions test requirements, when applicable, additional equipment authorizations are not needed when a licensed module is used in a final product (1.1307 fixed or 2.1091 mobile) that meets all the following: a) Final product complies with device use conditions and any grant remarks, conditions, and limitations described in the module FCC ID filing. b) Final antenna configuration(s) and use conditions comply with applicable licensed-service rules. c) Original test data in the module FCC ID filing continues to represent characteristics of the final product containing module-like device. d) Final product has FCC ID label, as described above. Licensed modules with specific antennas may be certified for use in certain final products operating in portable RF exposure conditions for configurations and procedures described in published KDB 447498. Licensed modules intended for end-user installation in notebook and tablet computers or similar devices, with pre-installed antennas which would operate in portable RF exposure conditions, must utilize some type of bidirectional authentication function to ensure that only combinations for which SAR routine evaluation has been performed are used together. 2.1033(c)(3) requires device operating and installation instructions to be submitted during equipment certification, which should include antenna installation info to support FCC RF exposure compliance. The FCC does not issue equipment-authorization certifications for licensed modules intended for use in mobile-phone handsets. Applications for licensed radio cards using a BIOS-lock function, similar to as used for some Part 15 modules, have been allowed for TCBs. Applications using other authentication techniques must contact the FCC. Module-like transmitters are peripheral to a host and are typically plugged into an externally accessible standard bus on such hosts. Examples of such industry defined standard bus interfaces are PCMCIA (PC Card), SDIO or CompactFlash slots on laptop computers or PDAs (FCC 07-56 footnote 18). A module-like intentional radiator or transmitter device without modular approval grant integrated as a component within a specific final product requires new application under 2.1033(b) or 2.1033(c). Best Regards, Adam Rudd Engineer (EMC) NCR Corporation - RHSS Duluth, GA (770) 495-2825 ________________________________ From: dward [mailto:[email protected]] Sent: Friday, September 05, 2008 2:35 PM To: [email protected]; Rudd, Adam; [email protected] Subject: RE: Radio module integration (Part 22/24) The FCC has two different approaches to part 15 and to licensed modules, but many of the same issues apply to both. The FCC for example only has ONE modular approval docket DA001407 and that deals ONLY with part 15 modules. However, the FCC also recognizes that licensed devices may also be of a modular nature and so, while there really is no modular approval docket for licensed devices like there is for unlicensed part 15 devices, modular transmitters are allowed in the licensed world. There are a few issues dealing with modular transmitters in the licensed rule parts. Licensed transmitters may be approved as modules for installation into the final devices provided the following criteria are met: 1 The final device is designed for mobile or fixed operation (Portable is not permitted – this is in reference to rf exposure more than anything) 2 The maximum antenna gain to allow compliance with RF exposure requirements is listed on the Grant of Certification for the modular transmitter 3 The licensed module must have a FCC ID label on the module itself. That FCC ID label must be visible through a window on the final device or it must be visible when an access panel, door or cover is easily removed. If not, a second label must be placed on the outside of the final device that contains the following text: "Contains FCC ID: xxxyyyzzz.” 4 The Grant should include the following words in the device description or grant notes: “modular transmitter” or “transmitter module” You should notice that unlike the unlicensed DA001407 modular approval docket, since this is a licensed device, you do not have to limit the antenna except to the max gain. Any type antenna, any type connector etc can be used. In fact, removable antenna device do not even have to have an antenna connected for any of the testing. Power can be conducted antenna terminal power and radiated spurious emissions, even though erp/eirp done to TIA603C, only have to have the antenna port connected to a ‘dummy load’. The gain of the antenna can be ‘calculated’ to yield the appropriate MPE etc. You should also notice that there is no such thing as a licensed portable modular transmitter. Thanks Dennis Ward Director of Engineering American TCB Certification Resource for the Wireless Industry www.atcb.com <http://www.atcb.com> 703-847-4700 fax 703-847-6888 direct - 703-880-4841 From: [email protected] [mailto:[email protected]] On Behalf Of Bill Owsley Sent: Friday, September 05, 2008 10:34 AM To: 'Rudd, Adam'; [email protected]; [email protected] Subject: RE: Radio module integration (Part 22/24) In looking at the reference example, the transmitter appears to fit into the PCI port of a laptop, much the same as wireless network card fits into one. So does "modular" have more to do with being unlicensed, or would it have more to do with how it is used? - Bill You can say what you want about the South, but you never hear of anyone retiring and moving North!!! --- On Fri, 9/5/08, dward <[email protected]> wrote: From: dward <[email protected]> Subject: RE: Radio module integration (Part 22/24) To: "'Rudd, Adam'" <[email protected]>, [email protected] Date: Friday, September 5, 2008, 11:42 AM Hi Adam While the FCC does have a policy statement about licensed modular transmitters using “"Contains FCC ID: xxxyyyzzz” on the outside of a host device, it does not have a policy about full transmitters (i.e. non-modular). If the licensed transmitter is not a modular transmitter but has an FCC ID then the FCC has no requirements about placing the ID number on the system and it is sufficient that the FCC ID is on the outside of the licensed transmitter. Thanks Dennis Ward Director of Engineering American TCB Certification Resource for the Wireless Industry www.atcb.com <http://www.atcb.com/> 703-847-4700 fax 703-847-6888 direct - 703-880-4841 From: [email protected] [mailto:[email protected]] On Behalf Of Rudd, Adam Sent: Friday, September 05, 2008 6:11 AM To: [email protected] Subject: Radio module integration (Part 22/24) Gentlemen, Does the FCC have any regulations or guidance for integrating a radio device into a larger system, specifically for a part 22/24 radio where the device will be concealed from view? Per 15.212, there is a lot of criteria involving the device having a Grant with Modular Approval and then if the integrator conceals the radio module’s FCC ID from view we must put a label on the outside that says “Contains FCC ID:xxxxxx”. I’m quite familiar with these requirements for 802.11 and RFID radio devices. But that code section is strictly for unlicensed part 15 transmitters. What about licensed Part 22 and 24 transmitters such as cellular radio devices such as: FCC ID N7NAC875 https://fjallfoss.fcc.gov/oetcf/eas/rep rts/ViewExhibitReport.cfm?mode=Exhibits RequestTimeout=500&calledFromFrame=N&ap lication_id=184431&fcc_id=%27N7NAC875%27 <https://fjallfoss.fcc.gov/oetcf/eas/re orts/ViewExhibitReport.cfm?mode=Exhibit &RequestTimeout=500&calledFromFrame=N&a plication_id=184431&fcc_id=%27N7NAC875%27> Note: Does not have “modular approval”, but that was a requirement under part 15.212… which may or may not be applicable here. I have submitted an inquiry with the FCC OET. But that usually take a couple weeks to get a responce. I am hoping someone here might be able to point me toward the rule section of Part 22 and 24 that would provide guidance. Thank you! Adam Rudd - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. 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Website: http://www.ieee-pses.org/ To post a message to the list, send your e-mail to [email protected] 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] All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. Website: http://www.ieee-pses.org/ To post a message to the list, send your e-mail to [email protected] 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] All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc
