Question: We want to FCC certify a new line of wireless modules that cannot be tested in a stand-alone configuration. How should we proceed?
Answer: First, please review the unpublished draft FCC KDB 996369 D01 Module Certification Guide DR09-45040 released for comments on April 24, 2023. When the guide content is finalized, it will replace the current module certification guide published in 2015. Needless to say, this 2023 draft provides a lot of new, informative content to guide you through the FCC module certification process.
Since the modules don’t comply with all the conditions of §15.212(a)(1) for single modular transmitters, they may qualify for limited modular approval (LMA) per §15.212(b) by testing in the Host, pending pre-approval guidance from the FCC as described in the unpublished draft and in KDB 388624 D02 Pre-Approval Guidance List v18r03 (PAG List), Section 2.5, category MODLIM:
“Under 47 CFR 15.212(b) requirements, the Grantee of a limited module must file with the certification application a description of the proposed method used to ensure host with the limited module installed are compliant. No specific format or template required for this filing. The Grantee can devise a strategy to be reviewed and approved through a Pre-Approval Guidance (KDB) procedure. Once approved, the same approval can be reused for additional modules by the same Grantee using the same method.”
We recommend you review the other FCC KDB 996369 modular approval documents for a more complete understanding of the requirements. Your TCB can guide you through the process.