This application note provides a brief summary of general radio
certifications, focusing on the 2.4 GHz frequency band and covering the wireless modules of Silicon Labs.
Silicon Labs RF modules are certified to meet the requirements of the Federal Communications Commission (FCC), Innovation, Science, and Economic Development (ISED),
European Conformity (CE), and other regulatory bodies. When using Silicon Labs precertified modules, customers can refer to these certifications and related test reports to
achieve regulatory compliance.
This document also provides answers to frequently-asked questions and general guidance for radio certification.
Certification requirements depend on regions and modules. This document highlights
the main differences between the different modules, module types, and certification requirements between different countries. It also describes a list of requirements that the
pre-certified module must meet in order to get a full modular certification as well as differences between the FCC and CE and other countries.
KEY POINTS
• Brief review of Silicon Labs radio module
certifications
• Regulatory overview of various countries
• Radio certification flow
• RF Exposure considerations
• Accredited test house examples
• Silicon Labs certification-related
documentation for customers
• Wireless Module Certification FAQ
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AN1048: Regulatory RF Module Certifications
Introduction
1. Introduction
Certification requirements depend on regions and modules. This document highlights the main differences between the different modules, module types, and certification requirements of different countries. It also describes a list of requirements that the pre-certified
module must meet in order to get a full modular certification as well as differences between the FCC and CE and other countries.
The FCC has two main categories: full modular approval and limited modular approval. A module that does not meet all conditions listed in FCC part 15.212 is certified to the Limited Modular Approval category. Both for full and limited modular approval, the end product
will be labeled with the module's FCC ID. For instance, the BGM12x SiP module shields the passive components in the substrate,
which acts as an intrinsic shield but does not include metallic shielding on top due to its highly optimized size and performance. However, the module fully meets radiated testing requirements of FCC and other standards without the metallic shield. The current state of
FCC rules requires metallic shielding. For this reason, module customers need to perform verification testing with Class 1 Permissive
Change for FCC and, additionally, apply for a Class 2 Permissive Change for ISED. As an additional example, the BGM13S SiP module (or PCB modules as BGM111) includes metallic shielding on the package with the FCC ID label, so it has a full FCC modular approval.
CE is not a certification, and there are no modular certifications in Europe or in countries following RED directives, as opposed to FCC.
CE requires a declaration from the manufacturer that the product meets the requirements of the R&TTE or RED directive. For example,
the BGM12x SiP module certification for CE does not differ from traditional PCB modules like the Blue Gecko BGM111.
The SoC/IC level wireless components cannot be pre-certified because they lack a fixed RF path and antenna. Customers must perform RF measurements to validate and certify design compliance with the regulatory rules.
Table 1.1. Silicon Labs Modules Main Regulatory Certifications Summary
MIC (Japan)Full Modular CertificationFull Modular Certification
KCC (South Korea)Full Modular CertificationFull Modular Certification
Note:
1. SiP modules are typically certified for limited modular certification due to the lack of metallic shielding and/or space for an FCC ID
label, but, in some cases, it has full modular certification. Related information can be found in the data sheet of the particular SiP
part.
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AN1048: Regulatory RF Module Certifications
Introduction
1.1 Certification Terminology / Acronyms
• FMA (or MA) = Full Modular Approval – meets criteria set for full modular certification.
• LMA = Limited Modular Approval – does not meet criteria set for full modular certification.
• C1PC = Class 1 Permissive Change – applies to modular approval (LMA, FMA) and relates to changes not increasing emissions.
• C2PC = Class 2 Permissive Change – applies to modular approval (LMA, FMA) and relates to changes increasing emissions or
changes to remove particular grant restrictions (antenna type, RF layout change, radio co-location).
• CB = Certification Body – a person authorized by the specific authority to review applications and admit certificates.
• TCB = Telecommunication Certification Body – issues grants for equipment subject to certifications.
• NB = Notified Body – an organization designated by an EU country to assess the conformity of certain products before being placed
on the market.
• DoC = Declaration of Conformity – mandatory self-declaration written under full responsibility by the manufacturer stating product
compliance.
• RED = Radio Equipment Directive – EU directive 2014/53/EU for compliance of radio equipment.
• TCF = Technical Construction File – technical documentation for a product providing evidence of compliance (test reports, declarations) and conformity to a relevant regulation; also includes technical design material.
• EU-TEC = EU Type Examination Certificate - optional document confirming directive conformity and compliance by testing against
harmonized standards (also known as the NB Opinion); provides statement by NB that TCF is appropriate for DoC.
• GMA = Global Market Access – service offered by test houses to help manufacturers cover global certification needs; applying reuse of certification in countries for which not certified.
• OEM = Original Equipment Manufacturer – in the context of certifications, this is an end-product producer as opposed to a component vendor. Also referred to as Module Integrator.
• OPN = Orderable Part Number – the part number used when customers place component orders.
• DUT/EUT = Device Under Test / Equipment Under Test – the device/equipment being tested.
• SAR = Specific Absorption Rate.
1.2 Customer Selection of Silicon Labs Solution
The solution selected by the customer determines design complexity, certification requirements, costs, etc., as listed below.
• Chip down / SoC
• 100% of customers of Silicon Labs. RF design experience is required. Lowest device cost but high certification cost.
• Example: EFR32MG21 SoC customer design.
• Uncertified module
• High certification cost. RF design experience is not required.
• Five standard certifications are marked on the part: FCC, ISED, CE, Japan, and Korea.
• Reel/Delivery package markings are not needed since they are on the part.
• Data sheet includes required wording from FCC, ISED, CE, Japan, and Korea.
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AN1048: Regulatory RF Module Certifications
Introduction
1.3.2 SiP Modules
SiP modules can have FMA, LMA with C1PC needed, and LMA with C2PC needed, while LMA with C1PC is the most common due to
the space limitation for marking on the parts. Furthermore, SiP modules with the lack of metallic shielding do require verification testing
with C1PC for FCC, and, additionally, C2PC for ISED. Data sheet includes required wording from FCC, ISED, CE, Japan, and Korea.
However, in some cases, FCC approves SiP modules without a certification label on the part as FMA if the OPN is clearly visible on it
and the related data sheet contains certification details (for instance, WFM200).
• Limited only in the sense that the mark (certification label) is missing.
• In some cases, it is approved as FMA when only the label is missing due to space constraints.
• Due to limited space, part markings only include Part Number (OPN) and Trace Code.
• Markings included on the delivery package:
• Required if not on part: ISED, FCC, CE, Japan, and Korea.
• Recommended if not on part: Taiwan.
• BGM13S22 example: Limited certifications listed due to space constraints.
• WFM200 example:
• Marking has three lines – Model name / OPN / trace code that are clearly visible on the part’s package.
• Packaging label requires CE logo and markings.
• FMA even without the FCC/ISED label, but data sheet contains required certification information.
• SiP module regulatory markings will not be added due to limited space and cannot fit more than 2-3 IDs.
• FMA is even possible and approved by FCC.
• Older designs, such as BGM13S, may have FMA, which is stated in the relevant part’s data sheet.
1.4 Customer Process for LMA SiP Module Certification
• When a product design including a SiP module with LMA is finalized, the customer shall contact the company providing certification
services for their product's general FCC, CE, and other country regulatory certifications and perform compliance testing on the final
product.
• The company providing the certification services will use Silicon Labs certification test reports and finalize the certification for the
customer.
• Documents can be downloaded at public certification databases.
• Documents can be downloaded from silabs.com.
• www.silabs.com/support serves customers and certification houses and can answer any questions.
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AN1048: Regulatory RF Module Certifications
Certifications/DoC Basics and Certification Flows
2. Certifications/DoC Basics and Certification Flows
2.1 Market and Application-Specific Certification Examples
• Europe: CE
• USA: FCC
• Canada: ISED (Former IC)
• South-Korea: KCC
• Japan : MIC (commonly known as Telec)
• Australia : RCM
• Typically split into three separate categories: RF, EMC and Safety
• Application-specific requirements: Medical, Automotive and Aviation
2.2 Certification versus DoC Basic Difference
2.2.1 Certification
• Testing takes place in an accredited test lab.
• The manufacturer, or an agent authorized by the manufacturer, submits an application to a CB.
• CB approves the application; admits the certificate to the manufacturer, and uploads the certification listing to the specific database.
• Typical countries Silicon Labs considers when applying for radio approvals include the USA, Canada, Japan, and Korea.
• Taiwan and Brazil are not typically certified by Silicon Labs but are occasionally included based on priority determination/customerbase demand.
2.2.2 DoC
• The EUT is tested according to any applicable standards, typically (but not necessarily) in an accredited test lab.
• The manufacturer will file the test evidence together with any technical information to an internal compliance folder.
• The manufacturer signs a DoC, which states the applicable standards according to which the product was found to be compliant.
• NB involvement required if testing occurs against non-harmonized standards.
• Countries: EU countries, Australia, New Zealand.
2.3 Process Flow in Certifications
2.3.1 FCC, ISED, MIC
1. Prepare samples and book a test slot from an accredited test lab.
2. Test lab will test according to the test instructions given by the module manufacturer.
3. Test lab provides the test reports.
4. Module manufacturer submits test reports and a certification application to a CB.
5. The CB reviews the application and admits the certificate to the manufacturer.
6. The CB uploads the certification listing to the specific database.
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AN1048: Regulatory RF Module Certifications
Certifications/DoC Basics and Certification Flows
2.3.2 CE
1. Prepare samples and book a test slot from an accredited test lab.
2. Test lab will test according to the test instructions given by the module manufacturer.
3. Test lab provides the test reports.
4. If all testing was done according to harmonized standards:
• Manufacture files the test evidence and all technical material to TCF.
• Manufacturer will sign a DoC in which the manufacturer states all the standards with which the product is found to be compliant.
5. If all testing was not done according to harmonized standards:
• Manufacturer submits an NB application to an NB.
• The NB will review the test reports and all technical material and user manuals.
• If the NB approves, they will provide the manufacturer with a letter in which they state that they have found the product to be
compliant with all applicable standards.
• Manufacture files the NB letter, test evidence, and all technical material to TCF.
• Manufacturer will sign a DoC in which the manufacturer states all the standards with which the product is found to be compliant.
2.4 Classical versus Self Declaration versus Restrictive
2.4.1 Classical
• Globally, the most common, including USA, Canada, Japan, Korea.
• Less flexible than self-declaration.
• Authority or CB must assess the test reports, design material, and hardware integration instructions and issue a certificate.
• End products can inherit approval from a module under some conditions.
• OEM is required to test their product, even if they are using a module with full approval.
• Repeating full testing is not required; sufficiently frequent spot-checking is suggested.
2.4.2 Self-Declaration
• EU, Australia, New Zealand.
• Extremely flexible. OEM simply creates a DoC for their product. They do not have to contact any CB. However, the customer may
want or have to be in contact with an NB.
• OEM has the full legal responsibility for the product they put on the market. Therefore, Silicon Labs strongly recommends that customers test the end-product to prove compliance and not just assume that the module’s own compliance evidences can be reused
as-is for the end-product.
• Silicon Labs also provides its own DoC and test reports for the modules to show compliance.
2.4.3 Restrictive Markets
• China, Russia, etc.
Note: In these markets there are difficulties in access which make them restrictive.
2.5 Silicon Labs Documentation for Customers
2.5.1 Data Sheet
• Minimal regulatory information except that which is required by regulatory bodies.
• Highlights the modular approval type.
2.5.2 Test Reports and Certificates
• Zip packages for region or authority containing various PDF reports and certificates for customer reference.
• Find these in Technical Resource Search: https://www.silabs.com/support/resources.ct-module-certifications.
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AN1048: Regulatory RF Module Certifications
Certifications/DoC Basics and Certification Flows
2.5.3 Installation Guide
• Detailed layout guidelines, including dimensions.
• Possibly includes FCC “test list” help.
• Possibly includes other general regulatory advice.
2.5.4 Layout Template
• File that is importable into a CAD design on a non-printable layer that shows outlines and dimensions that would help OEMs.
2.5.5 Design Files for Modules
• Module design files are Silicon Labs IP, so they cannot generally be shared with customers. If it is required for certification purposes,
Silicon Labs can share design files with the certification test house under NDA.
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AN1048: Regulatory RF Module Certifications
Certifications/DoC Basics and Certification Flows
2.6 Customer Certification: Engineering Flow
The flowchart below is designed to enable a customer's design to pass emissions requirements for whatever region they are interested
in. There are no legal assumptions required or built-in. It is an engineering flow customers can follow to achieve a passable design. All
customers will need to design their system and test it.
Customers are expected to visit a test house, even when using a fully certified module. This is especially valid for regions following the
DoC approach, but also, for example, for FCC, where testing of the end-product has always been officially strongly recommended but
not explicitly highlighted until very recently through the KDB publication 996369 D04, and has not always been enforced.
Silicon Labs role:
• Customers are not required to have deep knowledge of RF circuits or other technical details, although that may speed up the process, while Silicon Labs experts are available to provide guidance and provide hints on a suitable design meeting regulatory requirements. Using a certified module clearly offers benefits validating the above.
• Silicon Labs requires customers to understand their legal responsibilities. They may not be engineers, but they are business people.
• Silicon Labs might point customers to TCBs when they need to notify or work with a regulatory body regarding permissive changes.
Figure 2.1. Certification Engineering Flow
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AN1048: Regulatory RF Module Certifications
Certifications/DoC Basics and Certification Flows
2.7 Customer Certification: Paperwork Flow
The flow chart below is only provided as a guideline, not a legal contract. All customers should work with a TCB to answer questions
specific to their situation.
Figure 2.2. Certification Paperwork Flow
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Certifications/DoC Basics and Certification Flows
Table 2.1. Summary of Certifications Paperwork Flow
AN1048: Regulatory RF Module Certifications
CaseFCCISEDRED (DoC Based)Korea
FCC ID owner: Silicon Labs
A
No notification needed.
Same as
FCC
(~1000 USD for spot checking compli-
Similar to FCC but
no spot check re-
quired
ance)
FCC ID owner: Silicon Labs
We authorize C2PC against original
B
grant.
(~500 USD for C2PC, ~2000 USD for
testing if applies)
FCC ID owner: Silicon Labs
2
Same as
FCC
Customer DoC
Customer tests
EMC, safety, some
emissions.
Request for change
assumed
Customer can adjust
2
levels as desired.
Customers assess
We authorize C2PC against original
C
grant.
Same as
FCC
(~500 USD for C2PC, ~2000 USD for
their own risk.
(~5000 USD for test-
ing)
Request for change
assumed
testing if applies)
New certification needed. FCC ID
markings must be covered or removed.
D
3
Same as
FCC
Apply for end prod-
uct certification
(Cost depends on changes and tests)
1
Japan
Similar to FCC but
no spot check re-
quired
Request for change
assumed
Request for change
assumed
Apply for end prod-
uct certification
Note:
1. Japan requires only conducted testing of the module. Antennas are added based on antenna specification only.
2. As for xGM SiP Modules, they all are FMA except BGM12x, which is LMA due to lack of shielding. This is an additional example
where some extra effort with permissive changes is needed. WFM200 could be approved with a FMA despite the lack of label; so,
in this case, there is no need for any permissive change.
3. A new certification is more work for a customer, but their test house will be allowed to reuse applicable materials from Silicon
Labs, such as block diagrams, schematics, and test reports.
2.8 Customer Certification: Expected Process Timeline
An example of Silicon Labs' typical module certification timeline is shown below.
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AN1048: Regulatory RF Module Certifications
Certifications/DoC Basics and Certification Flows
2.8.2 Customer Modular Approval
Assume a few days of required spot-testing, after agreement with the test house. C2PC requires about 1 week to prepare material and
have it reviewed by TCB.
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Brazil (Anatel)http://www.anatel.gov.br/institucional/
Japan (MIC)http://www.soumu.go.jp/english/
Korea (KCC)http://eng.kcc.go.kr/user/ehpMain.do
3.2 Test House Examples
The table below lists accredited test houses that Silicon Labs has recently used for module certification efforts. Test houses primarily
make available their labs and engineers for the testing of modules against relevant regulatory standards in order to verify and report
their compliance. They also might offer their own NB or TCB services or propose to use NBs and TCBs that they partner with. In many
cases, Silicon Labs has been using the services of a third-party TCB of our choice, namely American Certification Body (ACB, https://
acbcert.com).
SGS (Standard Global Services)https://www.sgs.com/en/office-directory
https://www.canada.ca/en/innovation-
science-economic-development.html
Table 3.2. Test House Examples
Test HouseURL for Worldwide Locations
Australia (ACMA)https://www.acma.gov.au/
http://ec.europa.eu/growth/sectors/electrical-
engineering/red-directive_fi
Bureau Veritashttp://www.us.bureauveritas.com/home/worldwide-locations/locations
Dekrahttps://www.dekra.com/en/dekra-worldwide/
Elementhttps://www.element.com/locations
TUV-SUDhttps://www.tuvsud.com/en-us/locations#/
NCC Certificações do Brasilwww.ncc.com.br | www.ncc.org.br
• CE requires a declaration from the manufacturer that the product meets the requirements of the R&TTE or RED directive.
• CE is a “self-declaration” and not a certification.
• Since there is no certification, there is no modular approval / certification either.
• A module manufacturer is responsible for their module's compliance, and the end product manufacturer is responsible for their
end product's compliance.
• Test reports of Silicon Labs modules are available and show compliance, but any end product needs its own evidence.
• The manufacturer of the end product (OEM) is responsible for the product being compliant.
• Silicon Labs strongly recommends that the OEM perform radiated testing on the end product.
• Conducted test results can be inherited from Silicon Labs module test reports.
• Typically, test evidence (reports) must be presented.
• Optionally, an NB opinion can be requested as a formal “certificate”.
• RED Guide can be found here: https://ec.europa.eu/docsroom/documents/23321/attachments/1/translations/en/renditions/native
• A product is tested according to harmonized standards.
• Harmonized standards: A harmonized standard is a European standard developed by a recognized European Standards Organization, such as CEN, CENELEC, or ETSI. It is created following a request from the European Commission to one of these organizations. Manufacturers, other economic operators, or conformity assessment bodies can use harmonized standards to demonstrate that products, services, or processes comply with relevant EU legislation.
• Relevant standards for radio products:
• RF: ETSI EN300328 (radio emissions): https://ec.europa.eu/growth/single-market/european-standards/harmonised-standards/
red_en
• EMC: ETSI EN301489 (other emissions and immunity): https://ec.europa.eu/growth/single-market/european-standards/harmon-
ised-standards/electromagnetic-compatibility_en
• Safety: ETSI EN60950 (safety): https://ec.europa.eu/growth/single-market/european-standards/harmonised-standards/general-
product-safety_en
• All harmonized standards with status information: https://portal.etsi.org/webapp/WorkProgram/Frame_WorkItemList.asp?qSORT=DI-
• If harmonized standards are not followed, it is mandatory to use Notified Body.
• Manufacturer can also use Notified Body, just to gain more confidence in the compliance. Manufacturer maintains TCF.
• Test reports
• Description of the device (schematic, layout, BOM, photos, etc.)
• DoC
• NB opinion letter (if applied)
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AN1048: Regulatory RF Module Certifications
Regulatory Overview
3.4.1 Limitations
• CE is not a certification, so there is no modular certification. Each end product will require its own test evidence of compliance. Typically, conducted test results can be inherited from the module test reports. The radiated tests and immunity tests must be performed
with the end product assembly.
• If transmit power is higher than +13 dBm (20 mW), RF exposure must be evaluated.
• Typically requires SAR testing.
• Dependent on end product and use case, such as proximity to human body.
• If the product’s TX power exceeds 13 dBm, RF exposure evaluation should be evaluated by a suitable test laboratory.
• Multiple radios used in a single end product.
• If co-located radios are transmitting simultaneously, RF exposure must be re-evaluated.
• If co-located radios are not transmitting simultaneously, RF exposure is evaluated for each radio independently.
• For non-adaptive transmitters, the maximum EIRP is +10 dBm. For non-hopping transmitters, the maximum PSD (Power Spectral
Density) is 10 mW/MHz. In practice, these requirements limit the maximum nominal transmit power of 802.15.4-based protocols to
+12 dBm and BLE (Bluetooth Low-Energy) to +10 dBm with antenna gain of 0 dBi. If the antenna gain is higher, the transmit power
must be reduced accordingly.
3.4.2 Modules Tested for CE: What Does the Customer Need to Do?
• DoC (RE-D Declaration of Conformity) and test reports are available.
• For the end product, all conducted test cases of EN300328 can be inherited from the module test report.
• Any radiated test cases or ESD under EN300328 and EN301489 must be tested with the end product.
• RF exposure evaluation depends on the application and the transmit power of the module.
3.4.3 Countries Following the CE Standard
EU countries, ETFA countries: Iceland, Norway, Switzerland (and Liechtenstein), French DOMs, Guadeloupe, Martinique, French Guiana, Reunion, Afghanistan, Andorra, Georgia, Gibraltar, Maldives, Monaco, San Marino, Sao Tome and Principe, Seychelles, Vatican
City, Faroe Islands, Greenland, Svalbard, Azores, Madeira, Canary Islands, Guernsey, Jersey, Isle of Man, Montserrat, and Pit-cairn
Islands.
3.4.4 Australia (ACMA) and New Zealand (RSM)
• Similar to CE with few difference.
• Local representative or local office register to ACMA.
• Local representative or local office is responsible for maintenance of TCF and DoC.
• ACMA accepts FCC and CE test reports.
• Submit questions to ACMA officers: comply.label@acma.gov.au .
• Under the Trans-Tasman Mutual Recognition Agreement (TTMRA) between Australia and New Zealand, all devices compliant with
Australia's electromagnetic compatibility (EMC) compliance and labeling regime can be supplied in New Zealand, and all devices
compliant with New Zealand’s EMC compliance and labeling regime can be supplied in Australia.
3.5 FCC
• Types of authorization: Certification (radio), DoC (computer peripheral) or Verification (other electronic devices).
• Relevant standards for a product implementing a radio: Intentional radiators 47 CFR FCC Part 15C and Unintentional radiators 47
CFR FCC Part 15B.
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AN1048: Regulatory RF Module Certifications
Regulatory Overview
3.5.1 Single or Full Modular Approval
• Definition: a completely self-contained RF transmitter that is missing only an input signal and power source to make it functional.
• A module to be used in any host. Typically, compliance is ensured independent of the host board.
• A module that meets all eight module criteria listed below.
1. Transmitter/RF portion must have its own metallic shield.
2. Buffered data input.
3. Own power supply regulation.
4. Embedded antenna or unique antenna coupler (RF pin is a unique antenna coupler).
5. Module tested in a standalone configuration.
6. FCC ID label.
7. Must comply with all applicable rules applicable to the transmitter.
8. Must comply with any applicable RF exposure requirements.
• FMA is tested in standalone configuration.
• Module integrator must follow module’s grant limitations, e.g., distance and co-location for RF exposure.
• Module integrator can use the module without additional testing or permissive changes provided that the restrictions listed in the
FCC grant (e.g., co-location or RF exposure) are not a problem with the new host. However, FCC strongly recommends that spot
testing for additional emissions be performed with the new host. KDB 996369 gives comprehensive instructions for the module integrators. The KDB can be found here: https://apps.fcc.gov/oetcf/kdb/forms/AdvancedExternalSearch.cfm.
• Installation guide is required.
• The installation guide is, in practice, a HW layout guide. This is provided by Silicon Labs for each FMA modules.
• Compliance must not rely on instruction regarding SW configurations. For instance, some modules may have TXP limitations
across the full frequency band or on a few (higher) channels for FCC band-edge compliance.
3.5.1.1 How Do Customers use FMA?
• No separate certification with the end product; just label the product and get instant access to the markets.
• The host must be labelled that it includes a certified module.
• An end product using a radio with full modular approval will not need radio certification testing if the restrictions mentioned in the
module grant are met.
• The host must follow the module grant limitations.
• Distance and co-location for RF exposure.
• If the host does not follow the module grant restrictions (RF exposure, antenna types / antenna gain), a permissive change is
needed to remove the restrictions in that particular assembly.
• The host must still comply with its own requirements, such as part 15B verification (unintentional radiators).
• RF exposure limits:
• The minimum separation distance to a human body for the SAR measurement exemption is stated in the user manual.
• With modules, it is possible to measure the worst-case SAR to allow smaller separation from a human body.
• Depending on the nature of the end-product, head SAR must always be tested.
3.5.2 Limited Modular Approval
• A module that does not meet all eight criteria set above for a module.
• A module to be used in a known host or a known environment.
• For a licensed limited single module, the manufacturer must state how control of the end product into which the module will be installed is to be maintained, such that full compliance of the end product is always assured.
• LMA is not tested as standalone but is instead tested inside a specific host.
• The certification is valid only for the specific host and the module integrator or the module manufacturer must take actions, such as
performing testing or calculations, in order to approve the new host. In practice, the required actions depend on how the certification
is limited.
• If the host or end environment is known, Limited Modular Approval may be possible.
• Limited to application
• Limited to host
• Limited to installer (typically the Grantee or partner)
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