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FCC Part 15

The FCC has mandatory requirements before a product can be used, sold, or even marketed in some cases. Depending on the type of equipment that the product is, manufacturers are required to meet the FCC requirements for Verification, Certification, or Declaration of Conformity (DoC). The most common FCC requirements are FCC Part 15 Subpart A, FCC Part 15 Subpart B, FCC Part 15 Subpart C and FCC Part 18.

A lot of manufacturers do not know or believe their products have to be tested for FCC compliance. This is due to a lack of information or research and the misconception that there is only a requirement if the product uses RF intentionally or is a wireless product, but that is not the case. FCC Part 15 Subpart B is for unintentional radiators that use IC chips, oscillators, clocks, or one of any other numerous active electronic components.

FCC Verification is a process that requires the manufacturer to insure that their product complies with the requirements of the appropriate FCC rules and regulations. FCC Part 15 Subpart B lists the emissions limits and requirements. Testing to the appropriate test methods is typically the only way to prove the requirements are met. F2 Labs is an accredited laboratory with the equipment, experience, and expertise to help ensure your product is compliant with the appropriate regulations. For testing to FCC Part 15 Subpart B, there is no requirement for the test data or information to be submitted to the Commission for approval unless specifically requested. Verification is to be attached to the equipment in the way of the appropriate labeling showing that compliance is met. These labeling requirements are also given in FCC Part 15.

Per the FCC KDB 996369 D01 Module Equip Auth Guide V02:

A host product itself is required to comply with all other applicable FCC equipment authorization regulations, requirements, and equipment functions that are not associated with the transmitter module portion. For example. Compliance must be demonstrated: to regulations for other transmitter components within a host product; to requirements for unintentional radiators (Part 15 Subpart B), such as digital devices, computer peripherals, radio receivers, etc.; and to additional authorization requirements for the no-transmitter functions on the transmitter module (i.e., Verification or Declaration of Conformity) as appropriate (e.g., Bluetooth and Wi-Fi transmitter modules may also contact digital logic functions).

To ensure compliance for all non-transmitter functions, a host product manufacturer is responsible for ensuring compliance with the module(s) installed and fully operational. For example, if a host product was previously authorized as an unintentional radiator under the Declaration of Conformity procedure without containing a certified transmitter module, then a module is added, the host manufacturer is responsible for ensuring that the host continues to be compliance with the Part 15 subpart B unintentional radiator requirements after the module is installed and operational. Because this may depend of the details of how the module is integrated within the host, the module grantee (the party responsible for the module grant) shall provide guidance to the host manufacturer for ensuring compliance with the Part 15 Subpart B requirements.

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FCC Certification is covered under Part 15 Subpart C for intentional radiators. The most common types of intentional radiators are Wi-Fi or Bluetooth devices, remote control devices, intermittent transmitters such as garage door openers and alarm transmitters. Intentional radiators covered under FCC Part 15 Subpart C must have their product tested by an accredited laboratory like F2 Labs, and then submitted for approval by the Commission or an approved Telecommunications Certification Body (TCB). Once the product is approved, a Grant is issued and the manufacturer can start to market and sell their product with the approved labeling.

The FCC Part 15 Subpart C rules for marketing, sales, and use of radio transmitters are fairly clear with regards to the limits and requirements of each test required, but FCC Part 15 Subpart C does not list the procedures for performing the tests. There are other technical standards used for the procedures and test methods. These standards are listed throughout FCC Part 15 rules like FCC Part 15.31. There are also other requirements not listed directly in the FCC Part 15 Subpart C rules. They are known as KDB’s that the Commission releases with additional requirements and sometimes even changes. These can be found on the FCC website under the Knowledge Database (KDB) section, but can be very difficult to navigate and understand if you are not sure what you are looking for. F2 Labs is very familiar with this process and can easily assist you through this process. Contact us for consultation, evaluation and FCC testing Part 15, Part 18 and more.

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