Mark – 

 

The wireless portion falls under 15 Subpart C section 15.247 (I assume its
802.11bgn) and possibly under 15 E if it supports 802.11an.  

 

It also falls under the rule parts for a digital device.  If its a device for
home use that can connect to a PC (which seems likely) then it is considered a
Class B PC peripheral and, as such, subject to either certification or
Declaration of Conformity.  You know have the choice to either cover the
digital device certification at the same time you get the wireless portion
certified as a composite device or you certify the wireless device and use the
Declaration of Conformity procedures for the digital device.

 

I know it seems odd that you would treat the complete product as two separate
devices. Perhaps it is better to say that you evaluate the product under two
separate rule parts.  All emissions you can identify as being from the
wireless circuitry need to comply with the wireless rules and everything else
needs to comply with the digital device rules.

 

Mark (Briggs)

 

 

________________________________

From: [email protected] [mailto:[email protected]] On Behalf Of Mark Gandler
Sent: Wednesday, November 25, 2009 9:22 PM
To: [email protected]
Subject: Composite device per FCC 15.31

 

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

 

 

 

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