Hello Mark – The reason for the lab giving you that advice makes sense if you are using a modular –approved wireless card and the device you are integrating the module into is a DoC device.
Using the modular approval process is useful. In that case what the FCC allows you to do is use the wireless modules certification (without retesting) and then requires final unintentional emissions test on the product. As to the DoC – look in 15.101. The FCC very clearly states what products do or do not need DoC. A wireless router needs to be tested to class B limits for the home (for sure). If the test lab regards the router as a PC peripheral then the system also needs DoC marking. Best Regards Charles Grasso Compliance Engineer Echostar Communications (w) 303-706-5467 (c) 303-204-2974 (t) [email protected] <mailto:[email protected]> (e) [email protected] <mailto:[email protected]> (e2) [email protected] <mailto:[email protected]> ________________________________ From: [email protected] [mailto:[email protected]] On Behalf Of Pettit, Ghery Sent: Thursday, November 26, 2009 10:52 AM To: peter merguerian; [email protected]; Mark Gandler Subject: RE: Composite device per FCC 15.31 And it doesn’t really matter, anyway. Certification is still a legitimate way to authorize a digital device, so you don’t have to issue a DoC. I’d be careful about the TCB and lab. Ghery Pettit From: [email protected] [mailto:[email protected]] On Behalf Of peter merguerian Sent: Thursday, November 26, 2009 8:06 AM To: [email protected]; Mark Gandler Subject: Re: Composite device per FCC 15.31 Mark, My reading of 15.31 (k) is that a composite device is a " system that incorporates different devices contained within a single enclosure or in separate enclosures connected by wire opr cable". As such, your product is not considered a composite device. As you know, you can always get a ruling from the FCC. Best Regards, Peter --- On Wed, 11/25/09, Mark Gandler <[email protected]> wrote: From: Mark Gandler <[email protected]> Subject: Composite device per FCC 15.31 To: [email protected] Date: Wednesday, November 25, 2009, 9:21 PM Hi, In publication 584157 in FCC OET database, FCC states if you have composite device, which consist of devices under Certification and DoC, you must pursue both, including labeling, FCC logo and Warning text/ID. One of our test labs insist (they claim this comes from TCB) what we should treat wireless router/gateway as composite device, meaning Intentional radiator (wireless portion) done through certification and Ethernet/cable ports are treated as PC's peripheral, hence require DoC and logo on the label. In my opinion it does not make sense to treat wireless router/gateway as composite device. It is standalone device which performs multiple functions, but I do not see how can you treat Eth or cable port as separate device. Would be interested to hear some opinions. Happy Thanksgiving, Mark ________________________________ Windows 7: It works the way you want. Learn more. <http://www.microsoft.com/Windows/windo s-7/default.aspx?ocid=PID24727::T:WLMTA L:ON:WL:en-US:WWL_WIN_evergreen:112009v2> - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. 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