To reduce design time, compliance costs and time to market, many manufacturers integrate a pre-certified radio module that adds wireless capability to a larger device. However, it is vital to confirm that the module has valid certifications for all markets where the final product will be sold. If not, additional host product testing may be required. Doing thorough research and due diligence before selecting the module can save considerable time later in the process.
Across the globe, most countries have their own radio regulatory frameworks such as the European Radio Equipment Directive (RED), USA’s Federal Communications Commission (FCC), and Innovation, Science and Economic Development Canada (ISED). Other major markets, including China, Japan, India, Brazil and South Korea, have equivalent national regulations. While some countries accept FCC or RED reports, manufacturers should not assume that this alone will be sufficient for global approval. In many cases, regulators still expect at least limited Radio Frequency (RF) testing at the end-product level.
European Union requirements
European Union requirements
In both the UK and EU, the final product must demonstrate compliance with the RED’s Essential Requirements. This means that it is not just the module that must be tested for radio emissions, but the entire product into which it has been integrated. Integrating a pre-certified wireless module does not exempt the host product from radiated spurious emissions testing, as this remains mandatory to demonstrate continued compliance once the module is installed.
One of these essential requirements is electromagnetic compatibility (EMC). However, there is still a benefit to sourcing a module that has demonstrated compliance with the RED as a stand-alone device, as this can reduce the testing required for the host product. ETSI standards are the core EMC and Radio framework for selling radio equipment in the EU and UK, and they are widely recognised or used as a baseline in other countries. Many regulators outside Europe either directly reference ETSI standards or base their own national requirements on them. This includes Australia, New Zealand and Singapore, as well as the Middle East and CIS regions.
While ETSI EMC standards include both emissions and immunity requirement for EMC, the FCC in the USA and the ISED in Canada primarily focus on emissions. Countries like China and South Korea have their own mandatory standards which, although similar to ETSI in many respects, still require testing or certification to their own national versions.
North America requirements
North America requirements
The ISED rules for modules are broadly similar to those of the FCC and can be difficult to understand. For manufacturers exporting to North America, it is often prudent to seek guidance from an accredited test laboratory or FCC-designated Telecommunications Certification Body (TCB).
A wireless module must meet the relevant FCC rules and specific criteria to gain modular approval. When these requirements are satisfied and the device is certified, the FCC grant will state that the device has modular approval.
A favoured compliance route for FCC and ISED is to use a radio module certified as a “modular approval” transmitter and integrate it into a host device. Although the host device integrating the “modular approval” transmitter does not require certification, the manufacturer must still account for all FCC and ISED requirements for the digital circuitry and transmitter radio requirements. The host device manufacturer is responsible for following the integration guidance issued by the radio module manufacturer. In addition, the host device manufacturer should perform a limited set of transmitter module verification tests to ensure the final product complies with the rules.
Scaling truly global
The EU (RED) and North America (FCC/ISED) provide relatively similar frameworks for modular integration. These define testing requirements that are widely, but not universally, accepted. Manufacturers sometimes get caught out when they start scaling into APAC and LATAM markets and discover that modular approvals are treated very differently.
In many of these markets, regulators require the final host product to be certified as a unique entity. In such cases, the module’s certification serves only as a starting point for mandatory local testing or host-level registration, rather than a substitute for it.
Global complexity
A key reason for non-compliance of final host products containing wireless modules is the assumption that module certification automatically transfers to the complete device. Once the module is integrated, the overall system’s RF and EMC performance can change and affect compliance outcomes.
Best practice advice, when integrating wireless modules into products, includes confirming that the module’s certification and reports are valid in all intended markets, integrating strictly in accordance with the manufacturer’s instructions, performing host-level registration and seeking advice early from an accredited test laboratory or global market access expert.
While the globalisation of markets has created new business opportunities, there are still technical trade barriers and increasingly complex regulatory frameworks to face. TÜV SÜD’s Global Market Access (GMA) experts can help address these challenges, providing guidance on the compliance requirements and the most effective approval strategy for each country.
