(yet another) Photon and FCC question

Hello, I’ve tried reading all of the previous threads on this topic, but I unfortunately remain confused. My “product” (really just meant as a hardware bridge for serial to Particle Cloud) that I plan to ship to users to interface with my app/software is just this (from Particle’s own serial tutorial).

In this case since it’s just a Photon plus an RS232 TTL, is any additional FCC certification required? The end product would be in a plastic enclosure.

Would it be different if it were an Argon? Thank you.

For both the Photon and Argon, assuming you did not change the antenna, you would only need FCC unintentional radiator testing (“FCC 47 CFR Part 15 Subpart B”). This is the least expensive and easiest certification, and just tests that the Photon/Argon, with your components attached, is not unintentionally emitting excessive radio frequencies. You basically have a test lab test it, and sign a SDoC that you conform.

If you modify the antenna to a different type or higher gain, then you need to do intentional radiator testing, which requires testing the RF performance in every Wi-Fi band with special test firmware. This is much more effort.

This may help:

https://apps.fcc.gov/kdb/GetAttachment.html?id=zVUUifMY6Doa%2BO3Sg0Nygw%3D%3D&desc=996369%20D04%20Module%20Integration%20Guide%20V01&tracking_number=44637

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Thank you @rickkas7!

I’m still confused. If I create a simple product, say a PCB with some SSR’s, a tri-color LED, some passive components and plug in an Electron to a set of headers with all of this being placed in a small enclosure and using the provided Electron antenna, am I required to get FCC unintentional radiator testing certification? Alternatively, if I were to utilize a commercial relay “shield” such as one of the 4 relay boards from NCD with an Electron plugged in and with the provided antenna, would I still need to go through the certification? I need to know as this may be a show-stopper for me. Based upon quick research, it appears the cost of the unintentional radiator testing is $2,500 or more. I doubt there would be a demand for more than a couple dozen of such devices.

I guess part of my concern if it I’m creating ad-hoc solutions for customer needs in small volumes, does each device need to have the unintentional radiator certification?

I’d also be interested in whether “rental/lease” and/or making it a “kit” obviates the need for unintentional radiator testing.

Well…I doubt the rental/lease has any bearing on the issue from the FCC perspective. In my case, the number of devices is very low and I simply don’ know if the FCC even cares. If the “unintentional radiator certification” is required for all such devices, then I’ll be contacting my customers and advising them to stop using the devices and I’ll refund lease payments.