Cover Letters_20190220_v1 - Request for Modular Approval_ACJ9TGRI18A

FCC ID: ACJ9TGRI18A

Cover Letter(s)

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FCCID_4195989

                                                            Ben Botros, Project Manager
                                                            Product Safety and Compliance Department




Applicant/Grantee      Panasonic Corporation of North America
FCC ID:                ACJ9TGRI18A
Section 15.212 Modular Transmitters
Request for Modular Approval               Request for Limited Modular Approval
         Requirements                                   EUT Conditions                                 Comply
                                                                                                       (Y/N)
Single Modular Approval Requirements
1       The radio elements of the modular transmitter must         The device does not have Metal      N
        have their own shielding. The physical crystal and         shielding to cover RF section.
        tuning capacitors may be located external to the           Refer to External Photos.
        shielded radio elements.
2       The modular transmitter must have buffered                 All inputs to the device are Y
        modulation/data inputs (if such inputs are provided)       buffered through logic U1 inputs.
        to ensure that the module will comply with Part 15         Refer to Schematic Diagram.
        requirements under conditions of excessive data
        rates or over-modulation.
3       The modular transmitter must have its own power        There is no power supply in the N
        supply regulation.                                     module. 3.3V and 5.0V are fed by
                                                               the final product.
4        The modular transmitter must comply with the The device is equipped with the Y
         antenna and transmission system requirements of unique antenna connector. Refer
         Sections 15.203, 15.204(b) and 15.204(c). The to External photos.
         antenna must either be permanently attached or
         employ a “unique” antenna coupler (at all
         connections between the module and the antenna,
         including the cable). The “professional installation”
         provision of Section 15.203 is not applicable to
         modules but can apply to limited modular
         approvals under paragraph (b) of this section.
5        The modular transmitter must be tested in a stand- The device was installed into the N
         alone configuration, i.e., the module must not be final product for testing. Refer to
         inside another device during testing for compliance setup photos.
         with Part 15 requirements. Unless the transmitter
         module will be battery powered, it must comply
         with the AC line conducted requirements found in
         Section 15.207. AC or DC power lines and data
         input/output lines connected to the module must
         not contain ferrites, unless they will be marketed
         with the module (see Section 15.27(a)). The length
         of these lines shall be the length typical of actual
         use or, if that length is unknown, at least 10
         centimeters to insure that there is no coupling
         between the case of the module and supporting
         equipment. Any accessories, peripherals, or support
         equipment connected to the module during testing
         shall be unmodified and commercially available
         (see Section 15.31(i)).


                                          Panasonic Corporation of North America
                                  Two Riverfront Plaza, 9th Floor, Newark, NJ 07102-5490
                                  Tel/Fax: 201-348-7760 / Ben.Botros@us.panasonic.com


                                                        Ben Botros, Project Manager
                                                        Product Safety and Compliance Department




6   The modular transmitter must be equipped with              The proposed FCC ID label Y
    either a permanently affixed label or must be              format is to be placed on the
    capable of electronically displaying its FCC               module. If FCC ID is not visible
    identification number.                                     when the module is installed into
    (A) If using a permanently affixed label, the              the system, “Contains FCC ID:
    modular transmitter must be labeled with its own           ACJ9TGRI18A” shall be placed
    FCC identification number, and, if the FCC                 on the outside of final host system.
    identification number is not visible when the
    module is installed inside another device, then the
    outside of the device into which the module is
    installed must also display a label referring to the
    enclosed module. This exterior label can use
    wording such as the following: “Contains
    Transmitter Module
    FCC ID: XYZMODEL1” or “Contains FCC ID:
    XYZMODEL1.” Any similar wording
    that expresses the same meaning may be used. The
    Grantee may either provide such a label, an
    example of which must be included in the
    application for equipment
    authorization, or, must provide adequate
    instructions along with the module which explain
    this requirement. In the latter case, a copy of these
    instructions must be included in the application for
    equipment authorization.
    (B) If the modular transmitter uses an electronic
    display of the FCC identification number, the
    information must be readily accessible and visible
    on the modular transmitter or on the device in
    which it is installed. If the module is installed
    inside another device, then the outside of the device
    into which the module is installed must display a
    label referring to the enclosed module. This
    exterior label can use wording such as the
    following:
    “Contains FCC certified transmitter module(s).”
    Any similar wording that expresses the same
    meaning may be used. The user manual must
    include instructions on how to access the electronic
    display. A copy of these instructions must be
    included in the application for equipment
    authorization.
7   The modular transmitter must comply with any               Refer to “User’s Guide” Exhibit     Y
    specific rules or operating requirements that
    ordinarily apply to a complete transmitter and the
    manufacturer must provide adequate instructions
    along with the module to explain any such
    requirements. A copy of these instructions must be
    included in the application for equipment
    authorization.
                                      Panasonic Corporation of North America
                              Two Riverfront Plaza, 9th Floor, Newark, NJ 07102-5490
                              Tel/Fax: 201-348-7760 / Ben.Botros@us.panasonic.com


                                                            Ben Botros, Project Manager
                                                            Product Safety and Compliance Department




8         The modular transmitter must comply with any The device complies with RF Y
          applicable RF exposure requirements in its final exposure compliance requirement
          configuration.
A limited modular approval may be granted for single or split modular transmitters that do not comply with all of
the above requirements, e.g., shielding, minimum signaling amplitude, buffered modulation/data inputs, or power
supply regulation, if the manufacturer can demonstrate by alternative means in the application for equipment
authorization that the modular transmitter meets all the applicable Part 15 requirements under the operating
conditions in which the transmitter will be used. Limited modular approval also may be granted in those instances
where compliance with RF exposure rules is demonstrated only for particular product configurations. The applicant
for certification must state how control of the end product into which the module will be installed will be
maintained such that full compliance of the end product is always ensured.




                                          Panasonic Corporation of North America
                                  Two Riverfront Plaza, 9th Floor, Newark, NJ 07102-5490
                                  Tel/Fax: 201-348-7760 / Ben.Botros@us.panasonic.com



Document Created: 2019-02-12 11:17:10
Document Modified: 2019-02-12 11:17:10

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