On February 1, 2019, the FCC published final versions of two new guidance documents (KDB’s) which cover issues relating to modular approval of wireless devices. These documents will become effective on May 1, 2019, but are recommended to be followed immediately.
The two documents are:
• KDB 996369 D03 v01: Guidance for Modular Transmitter Instruction Manuals and TCB Certification Application Reviews
• KDB 996369 D04 v01: Modular Transmitter Integration Guide – Guidance for Host Product Manufacturers
The following is Bureau Veritas’ summary of the document – KDB 996369 D04 v01:
1. A common misunderstanding of modular approvals and modularly approved devices is that their PURPOSE is to relieve the host product manufacturer of any responsibilities regarding compliance to “intentional radiator” rules (excepting of course the responsibility to follow any integration and labeling instructions inherent to the modular approval itself). In this new document, FCC is clearly stating that this is NOT the case. The BENEFIT of using a modularly approved device is that the host manufacturer doesn’t have to perform full technical compliance testing and doesn’t have to complete a full subsequent FCC filing process (i.e., Certification). But it is still expected that the host manufacturer VERIFY compliance of the transmitter portion of composite device, since the host manufacturer is ultimately responsible for its operation.
2. Taking account of this newly articulated requirement for verification, the document lays out the following requirements.
a) Consider ALL FCC compliance requirements of the device, including the transmitter module.
b) Follow the integration instruction provided with the module.
c) Pay particular attention to integration instructions regarding RF exposure requirements. (i.e., maintain required distances to ensure that the modular assessment still applies to host)
d) Obtain appropriate device authorizations not covered by the modular approval (e.g., SDoC for unintentional Part 15B operation)
e) Perform some verification testing of the module while installed an operating within the host. This should cover at least the fundamental transmission and spurious emissions while transmitting.
f) Label the product appropriately.
3. The remainder of the guidance document deals with recommended verification tests as well as common operational modes in which to sufficiently exercise the device for purposes of testing.
How Bureau Veritas Can Help
While these guidance documents outline responsibilities that host manufacturers own, it is worth noting that the verification test results are not required for any subsequent FCC filing. These verification test results are to be kept by the manufacturer in a compliance file. Bureau Veritas CAN, upon request, perform this testing for you, the host manufacture, and produce a verification test report for your compliance file that satisfies the intent of this new KDB Guidance document.
The guidance documents are available for download: https://apps.fcc.gov/oetcf/kdb/forms/FTSSearchResultPage.cfm?id=44637&switch=P