Final FCC certification for product containing an electron "modem"?

I read the previous posts on this, but am not satisfied with the answer. If I design a product containing an electron module, do I need to get the product any further certification in regards to the FCC or any other regulator because it has a radio device that connects to the cell phone network?

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@will @zach
bump
This is important for me, about to move into production in the US.

Does the same or more FCC rules apply to the electron as for the photon/sparkcore:
Is the Cellular certification for the electron complete?

Continuing the discussion from Is it easy to get FCC certification for a device using the Spark Core?:

Or is this page still the latest on what we know about the electron and certification?
https://docs.particle.io/guide/how-to-build-a-product/certification/
The table listing certifications was last updated in February.

@will and @zach,

I would also like to know about this. I also plan to move to production relatively soon.

I’d also like to note that I am a little confused by the links to the FCC docs on the documentation page.

If I follow the links for the XPYSARAU260 or the XPYSARAG350 I get to FCC pages that seem to be about the U260 and G350, respectively. But clicking into the PDF’s on that page, show me information regarding the Photon.

e.g., if you go to the U260 page and click on Declaration of authorization you get the declaration of authorization for the Photon.

Am I missing something on these pages?

Here’s a decent summary (from a good antenna vendor):

Generally, you can take advantage of modular approval from the module vendor (uBlox) if:

  • no other radios apart from cellular in the product
  • not used within 20cm of a human body (so you can skip SAR)
  • lower gain antenna than the one the approvals were done with

…you’ll still have to do FCC 15b for unintentional radiator, but you can do this with the radio part turned off.

Then, there’s PTCRB, which is GSM approvals - ie approval for your device to be connected to a GSM/3GPP spec network:

  • The uBlox module has PTCRB approval, but…
  • If your device has the antenna inside it, or has a cabled antenna which is <20cm from the device, you need to do PTCRB OTA testing. This is kinda expensive - usually $50k+ - as it requires certified labs and a lot of equipment (TRP/TIS etc) and time.
  • It’s sometimes possible for someone who integrates a module (eg Particle) to do some of the required testing. They would have to convince PTCRB the device met the prerequisites and so on. If you have done this, you generally claim it fairly loudly (see: other cellular module integrators).

Finally, there’s carrier approval:

  • This can be somewhat arbitrary. Particle being an MVNO may help here, but they may have to run stuff past their host carrier.
  • Technically it’s approval of the way an app works over the cellular network, as well as minimum performance levels.
  • I’m sure it’s quite different for M2M devices than it was when I was making iPhones (when there were literally hundreds of user interface tests)
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The XPYSARAU260 should refer to this:

(fccid.io is a far, far nicer way to find device reports!)

(edit) Actually, looking more at that, it’s a 2016 device (personal safety device) using the Sara U260 module, and re-using its modular approval… even though it’s within 20cm of the body.

It seems that Particle has started to advertise PTCRB approval here. I wonder if that includes the OTA testing you mentioned for an antenna less than 20cm? Seems like it would be hard to get around that approval with the antenna that has been FCC approved.

So for those of us building M2M products with the Electron, it seems it boils down to:

  • We can use the modular approval for FCC Rule 15 Part A if our product:
    • Doesn’t have a second radio
    • Is not used within 20cm of human body
  • Definitely have to conform to FCC Rule 15 Part B
  • Cross our fingers that Particle has done PTCRB OTA approval with the antenna they sell/recommend with the Electron. Otherwise, we’ll have to
    • Do the PTCRB OTA approval ourselves if we want to use Particle’s recommended antenna
    • OR Find an external antenna that meets the requirement below, lifted from @hfiennes’s fccid.io link

The maximum antenna gain including cable loss for compliance with radiated power limits, RF exposure requirements and the categorical exclusion requirements of 2.1091 is 3.5 dBi for 850 MHz bands and 2.0 dBi for 1900 MHz bands.

  • Then for carrier approval, we use the same tests that were passed for the PTCRB and deviate when required by cellular company.

Sorry if that was long-winded and repetitive, but do you think that is about correct @hfiennes?

Definitely interested in seeing what Particle has to say about this.

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That’d be how I read it, but there are many subtleties and assumptions. As with medical advice, there’s no substitute for talking with an actual doctor - or in this case, a PTCRB accredited lab.

The module is indeed PTCRB certified ( https://www.ptcrb.com/vendor/complete/view_complete_request_guest.cfm?modelid=25785 ), but so is every module as they’d be hard to sell without certification.

This seems to be a good reference too, for those of us in the US: AT&T Approved Modules. Warning, its an XLS.

Seems that both versions of the U260 are on there.

Hey all,

Sorry for the slow reply to this thread. I’ve answered some questions below, but in general, this stuff is extremely case-specific. There might additional certifications (UL for instance) that apply to your end product that have no applicability to our dev kits. In general, we’re willing to lend our experience on this kind of stuff, but having knowledge of your use case, product, and implementation are very important to being able to give good feedback. I’d highly recommend reaching out to sales@particle.io if you’re building a product on the Particle platform for which certification may be necessary.

Here are some comments on the open questions that you all have been asking:

If I design a product containing an electron module, do I need to get the product any further certification in regards to the FCC or any other regulator because it has a radio device that connects to the cell phone network?

Unfortunately, like I mentioned in my previous post, this is a complicated question, and I can’t give any kind of cut and dry answer. In general, though, unless you are using Particle’s dev kit completely unmodified within an enclosure, you’ll likely have to at least self-declare unintentional radiators through FCC’s sub part 15b. If you have made other changes that introduce additional unintentional radiators, introduce co-located radiators, or modify the RF design of the Photon, you’ll likely have to complete FCC subpart 15c. This is all documented on our certifications page.

If I follow the links for the XPYSARAU2602 or the XPYSARAG350 I get to FCC pages that seem to be about the U260 and G350, respectively. But clicking into the PDF’s on that page, show me information regarding the Photon.

Thank you for pointing this out. This is a submission error by the FCC that we will work on correcting with them! We don’t have direct control over this site, so I can’t say exactly how long it will take to make the correction. If there is a certification document you need in the meantime, please let me know over PM and I can send it to you!

Generally, you can take advantage of modular approval from the module vendor (uBlox) if:

  • no other radios apart from cellular in the product
  • not used within 20cm of a human body (so you can skip SAR)
  • lower gain antenna than the one the approvals were done with
    …you’ll still have to do FCC 15b for unintentional radiator, but you can do this with the radio part turned off.

This is true, since the u-blox module carries FCC modular approval. Particle has used this modular approval to do a verification of certification using the u-blox FCC ID, demonstrating that it complies with FCC guidelines after integration of the device onto the Electron.

Then, there’s PTCRB, which is GSM approvals - ie approval for your device to be connected to a GSM/3GPP spec network:

  • The uBlox module has PTCRB approval, but…
  • If your device has the antenna inside it, or has a cabled antenna which is <20cm from the device, you need to do PTCRB OTA testing. This is kinda expensive - usually $50k+ - as it requires certified labs and a lot of equipment (TRP/TIS etc) and time.
  • It’s sometimes possible for someone who integrates a module (eg Particle) to do some of the required testing. They would have to convince PTCRB the device met the prerequisites and so on. If you have done this, you generally claim it fairly loudly (see: other cellular module integrators).

There are three kinds of PTCRB certification:

  1. Module certification
  2. Integrated device certification
  3. End product certification

The u-blox module has the first type, modular certification. Particle is certifying the Electron as an “End Product” which means that, if the Electron is implemented as is, without any hardware or RF changes (including the antenna), there should not be additional PTCRB certification required. However, the requirements here are pretty strict–any introduction of additional radiators would result in the need for an expensive recertification. We’re doing as much as is absolutely possible, though, to avoid this cost for those for whom the Electron is a suitable drop-in wireless element.

Finally, there’s carrier approval:

  • This can be somewhat arbitrary. Particle being an MVNO may help here, but they may have to run stuff past their host carrier.
  • Technically it’s approval of the way an app works over the cellular network, as well as minimum performance levels.
  • I’m sure it’s quite different for M2M devices than it was when I was making iPhones (when there were literally hundreds of user interface tests)

If you use the Electron with the Particle SIM, no additional certification here should be required.

Hi @will,

Can you provide an update on where Particle is with the following?:

Particle is certifying the Electron as an “End Product” which means that, if the Electron is implemented as is, without any hardware or RF changes (including the antenna), there should not be additional PTCRB certification required.

Thanks!

Hey there @hwestbrook – we’ve completed Lab Tests for the U260 and U270 (G350 still in progress), and have passed PTCRB and GCF tests for those two devices. The devices meet all the requirements of an End Product, as defined by the PTCRB. We are in the process of submitting the completed lab reports for approval by PTCRB.

We did additional research, and for an End Product there are no additional integration requirements for product creators from a certification perspective. That being said, there are certainly RF implications for integrating the Electron into an enclosure or in mounting the antenna, so we recommend RF testing of the finished product before any kind of mass deployment to ensure that the RF performance of the integrated device is adequate.

The standard FCC integration requirements will apply to the Electron (antenna of equal or lesser gain, integrated no less than 20cm from the skin, etc.) Those integration instructions are more clearly defined on our certifications page, located here:

https://docs.particle.io/guide/how-to-build-a-product/certification/#fcc-img-class-inline-header-image-src-assets-images-logo-fcc-png-

Did you have any other specific questions?

Just got off the phone with a sales manager for KORE Telematics. I am trying to get pricing for cellular service through them for the Electron, as they appear to specialize in M2M applications and I used them in a prior life.

The guy indicated that he cannot find where the Electron itself is “end unit certified”, only the u-blox module and that both AT&T and T-Mobile require the end unit to be certified.

Any help/guidance on this? I realize this is a bit weird as I’m looking for better pricing than Particle’s Telefonica, but with our data needs, I really do need better pricing.

@will, To maintain the PTCRB and FCC Electron certifications, can another antenna be used such as the one below? I’ve seen that equal of less gain antenna can be used for FCC but I’m not sure about the PTCRB certification.

Also when comparing antenna gain is it the Max Gain that would be compared for a particular frequency range for all or just the ones that will be used?

Also does the antenna types need to be the same? Penta vs Quad etc?

Thanks,

http://www.digikey.com/product-detail/en/pulse-electronics-corporation/W3538B0150/553-2585-ND/2649124

Hey there @ctmorrison – sorry for the delay in the response. I wasn’t notified that a new post had been added to the thread or I would have replied sooner.

The Electron is in the final stages of PTCRB certification for End Product certification and is pending assignment of certification identifiers by the PTCRB committee. AT&T and T-Mobile require end devices to be certified for carrier certifications if the product leverages direct pricing with the network. That certification is not required via Telefonica because the devices are roaming on the network, so a single Telefonica carrier certification is sufficient for support via Particle’s MVNO and SIM.

Have you inquired with our sales team for volume pricing? We are cost competitive with the cheapest options available at volume for product creators, especially given the significant certification costs you save when working with our hardware and MVNO.

Hey @wesner0019 – it all comes down to the gain of the antenna.

The gain cannot exceed the gain of the antenna that was used in certification. For the Electron, that is the PC104.07.165C from Taoglas, here:

It looks like the gains of the antenna you posted are higher than the antenna that was used for certification, so compliance testing would be required.

@will, some what, when comparing the antennas gains it’s difficult to determine what would work, for example the below antenna spec sheet lists it gain at a peak of -2dbi. But the Electron antenna lists gain for all bands, would we be comparing the Electrons highest gain and doesn’t matter what the band its coming from?

Also the Peak gain for the electron antenna is listed as 2.13dbi for the 1900 GSM band, in other data sheets I see negative values listed as the Peak gain. How do you compare a positive dbi to a negative dbi?

Sorry for
all the questions, but just want to make sure I can find a conforming antenna to use.

data sheet:

You would need to ensure your antenna’s peak gain, in every band, is less than or equal to the Taoglas antenna’s peak gain, in every band. This ensures that the combination of module + your antenna will never emit more than the tested antenna did during tests.

-2dBi is 4dB less than +2dBi. Compare as you would any number.

Average gain is the average gain in 360 degrees of both polarizations. Peak is just the best case, which will be highly directional.

dBi is a comparison to a hypothetical perfect antenna with no gain (or loss) uniformly in all directions. These antennas are available at the same place where you can get frictionless slopes and infinitely thin wire.

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btw, that datasheet you link to is kinda useless. It says “GSM” as the frequency band, but that traditionally refers to 900MHz. The antenna itself is definitely dual band (you can see two elements).

The gain is badly specified and not followed up with any test results - the rest of the datasheet is more about RoHS compliance, with only a brief screenshot of return loss.

I’d generally run away from anything that badly specified. There are plenty of antenna vendors who are a bit more generous with their test results.

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@hfiennes, great explanation this helps a lot. Thanks!