On October 24th 2023, the FCC introduced additional comments regarding Publication 996369 in order to ensure compliance of the certification of RF modules and their integration into host devices.
Key updates are focused on revisions these FCC Modular Approval Guilelines.
A few highlights are related to procedures for Limited Modular Approval (LMA) certification as it has been clarified that devices not having a shielding are treated differently to any other item on 15.212 and must undergo a C2PC (or C3PC if SDR). Other requirements under 15.212 are not mandated to undertake C2PC, the host integrator could simply ensure compliance themselves, such as voltage regulation on the main product PCB.
Furthermore, if a module comes with ‘professional installation’ instruction, it must be filed as LMA now.
The Grantee’s Integration Instructions must provide a test plan (required by rule 47 CFR 15.212(b)) to demonstrate continued compliance when the module is integrated into a host.
In Summary the downsides of LMA have been highlighted and it is important that manufacturers provide the test plan or seek for assistance from the testing provider.
For further information, please contact our GMA team at [email protected]
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