Electron FCC Certification with regards to antenna

The Archive Product Creation
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Doing my research on FCC certifications, I chanced upon the Particle modules, specifically the Electron 2G (SARA-G350) variety. It looks to be a flexible product and easily integrated into other devices. However, it is unclear to me how the module and antenna certification have been derived.

On the Particle certification page (link here), three links are given. One contains an unintentional radiator test for the Electron module plus antenna and battery. Another contains a Declaration of Conformity, which appears to be based upon the former rapport. Finally, there is a link to several FCC documents, which all seem to refer to the Photon and not the Electron module.

However, it is noted on the certification page that the modules should be listed under a certain FCC number for the intentional radiator/FCC part of the certification. Looking at these FCC numbers, it is clear they are the original U-blox certifications. That makes sense, since these are ‘single-modular transmitter’ certifications and therefore can, and are intended to, be reused. Anyone selling these modules or using them in a product can use the module intentional radiator certification.

However, this is where the part I am unsure of starts. These modules can be used only as long as no changes to the antenna were made. Since these modules do not contain an antenna, I think the rules permit a change to the antenna, as long as it is of a similar type and with equal or lesser gain. I am not sure about that, though, and am not too certain how they apply to a module without antenna either. What I am also unsure of, is how the FCC approved Taoglas antenna came to be. The certification does not seem to list the antenna type used. The gain does appear to be mentioned. Another complication is that the PCB carries the antenna signal, making it part of the antenna structure. Even if the antenna is FCC approved, this causes some concern whether the full product can be considered certified.

In short, my questions are:

  • Is the Electron intentional emitter certification based solely upon the U-blox certification?
  • How was the Taoglas antenna Particle sells derived from the U-blox FCC Certification?
  • Does the Taoglas antenna have separate FCC certification?
  • How is the PCB factored in?

The product seems to fit my needs pretty well, so I am curious to learn the answer to these questions. Thank you!

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Have you looked into the threads touching on the same topic already?

https://community.particle.io/search?q=electron%20fcc

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Yes, in some detail. Some questions were answered in the those threads, but these remain. The inherited module certification is mentioned in relation to the Photon, but nothing is really said about the Electron. The antenna and PCB and their role in certification are not mentioned anywhere, as far as I can tell, yet FCC regulations tell me those are relevant.

Law stuff is always tedious and details matter, though Particle seems to have done the homework. Since the manufacturer (i.e. me) is responsible in the end, it pays to be both explicit and comprehensive. It might help others too.

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Does anyone have any information on this? It seems to me that the Particle staff would be able to answer these questions, since it would have been part of the certification process. I would love to hear their considerations.

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We can ping @will so he could chime in and maybe get the relevant bits added to the docs.

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I think this thread really has all the info you need:

If you want to use the modular certification from ublox, you must use an antenna with gain equal to or less than the antenna that was used for testing (as specified in that thread) in any band. Basically your radiated power should never exceed the original test and you are fine for the intentional radiator testing, as long as you are not building a close-to-the-human-body device.

You still need to do unintentional radiator testing on your final product but that can be done with the cellular radio off.

If you are building a product and want to use the modular certification, I suggest that you contact Particle sales via email and talk directly to them about your needs.

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