"Let's Say..." is a monthly blog where LSR's staff provide explanation, expertise, and insight on hypothetical scenarios regarding different product's EMC/EMI regulatory compliance. This month we discuss considerations for a manufacturer who's implemented a WiFi Module, and is concerned about their product's FCC and CE compliance.
The effect of integrating a WiFi module on a product's compliance to the applicable technical standards in the US will greatly depend on the type of product which has been modified, the module selected, and the compliance status of the each prior to the integration.
The FCC Office of Engineering and Technology (OET) Equipment Authorization (EA) procedures include product verification, declaration of conformity (DoC), and/or certification; the type, industry, and implementation of the product will determine which authorization is appropriate and applicable. WiFi modules are intentional radiators requiring certification, and are subject to the requirements of Title 47 CFR Part 15 for unlicensed transmitters.
When considering a WiFi module, there is a tangible cost benefit to implementing a modular design which already has a Grant of Authorization with modular approval from the FCC. The certification costs related to a module are significant; and depending on the antenna design and WLAN protocols utilized, the approval process can exceed 8 to 12 weeks. By integrating one which already has modular approval, the certification for FCC compliance is complete and the product may only need an updated declaration of conformity (DoC) or verification.
Considerations of integrating a this type of module in a product for CE marking differ from those in the US. The European Union (EU) does not consider the modular approval program of the United States and Canada; however, this may not equate to a test program requiring a complete recertification of the specific module, dependent upon the integration of the module itself.
For consideration of compliance for distribution in the countries who participate in the European Union, the product must demonstrate compliance to all applicable directives of the EU's "New Approach" method of harmonisation. Upon integrating a WiFi module into a product, said product is not only required to demonstrate compliance to the EMC directive; but is also now required to demonstrate compliance to the Radio and Telecommunications Terminal Equipment (R&TTE) directive. This being said, there is advantage to sourcing a module that has demonstrated compliance with the R&TTE in it's modular configuration.
Demonstrating compliance to the applicable directives of the EU is a process of self-declaration; requires that evidence of compliance, supported by data obtained from an approved assessment body, clearly demonstrates that the product conforms to all the applicable requirements therein. The product can however, under certain circumstances, leverage the test data of the specific module to demonstrate its compliance to the R&TTE, as long as it can be demonstrated that there is no appreciable difference between the module's performance when integrated into the product and it's performance in a modular configuration.
In conclusion, there are several considerations to evaluate when integrating a WiFi module into a product, not the least of which is how this integration will effect the product's regulatory compliance requirements. Clearly there is cost and conformity advantage in choosing a pre-certified WiFi module, and with special consideration to how the module is integrated, the impact of that integration for demonstrating compliance can be significantly reduced.