SONY
Sony Group Corporation
1-7-1 Konan Minato-Ku Tokyo, 108-0075 Japan
Request for Modular/Limited Modular Approval
Date: July 30, 2021
Subject: Manufacturer‟s Declaration for ☐ - Modular Approval
Confidentiality Request for: ______ AK8-WE8853S ______
☒ - Limited Modular Approval ☐ - Limited Split Modular Approval
☐ - Split Modular Approval
8 Basic Requirements – FCC Part 15.212(a)(1)
For Items Marked “NO(*)”, the Limited Module Description Must be Filled Out on the Following Pages
Modular Approval Requirement
Requirement Met
1. The modular transmitter must have its own RF shielding. This is intended to ensure that the module
does not have to rely upon the shielding provided by the device into which it is installed in order for all
modular transmitter emissions to comply with FCC limits. It is also intended to prevent coupling
between the RF circuitry of the module and any wires or circuits in the device into which the module is
installed. Such coupling may result in non-compliant operation. The physical crystal and tuning
capacitors may be located external to the shielded radio elements. 15.212(a)(1)(i)
Details: <example – The module contains a metal shield which covers all RF components and circuitry. The shield is located on
the top of the board next to antenna connector>
☒ - YES ☐ - NO(*)
2. The modular transmitter must have buffered modulation/data inputs (if such inputs are provided) to
ensure that the module will comply with FCC requirements under conditions of excessive data rates or
over-modulation. 15.212(a)(1)(ii)
Details: <example – Data to the modulation circuit is buffered as described in the operational description provided with the
application>
☒ - YES ☐ - NO(*)
3. The modular transmitter must have its own power supply regulation on the module. This is intended to
ensure that the module will comply with FCC requirements regardless of the design of the power
supplying circuitry in the device into which the module is installed. 15.212(a)(1)(iii)
Details: <example – The module contains its own power supply regulation. Please refer to schematic filed with this application>
☒ - YES ☐ - NO(*)
4. The modular transmitter must comply with the antenna and transmission system requirements of
§§ 15.203, 15.204(b), 15.204(c), 15.212(a), and 2.929(b). The 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 § 15.203 is not applicable
to modules but can apply to limited modular approvals under paragraph 15.212(b). 15.212(a)(1)(iv)
Details: <example – The module connects to its antenna using an UFL connector which is considered a non-standard
connector. A list of antennas tested and approved with this device may be found in users manual provided with the application>
☒ - YES ☐ - NO(*)
5. The modular transmitter must be tested in a stand-alone configuration, i.e., the module must not be
inside another device during testing. This is intended to demonstrate that the module is capable of
complying with Part 15 emission limits regardless of the device into which it is eventually installed.
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 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 or commercially available (see Section 15.31(i)). 15.212(a)(1)(v)
Details: <example – The module was tested stand-alone as shown in test setup photographs filed with this application>
☐ - YES ☒ - NO(*)
070920-02b
SONY
Sony Group Corporation
1-7-1 Konan Minato-Ku Tokyo, 108-0075 Japan
Modular Approval Requirement
6. The modular transmitter must be labeled with its own FCC ID number, or use an electron display (see
Requirement Met
KDB Publication 784748).
If using a permanently affixed label with its own FCC ID number, if the FCC ID 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.
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. 15.212(a)(1)(vi)
Details: <example – There is a label on the module as shown in the labeling exhibit filed with this application. Host specific
labeling instructions are shown in the installation manual .filed with this application.>
☒ - YES ☐ - NO(*)
7. The modular transmitter must comply with all specific rule or operating requirements applicable to the
transmitter, including all the conditions provided in the integration instructions by the grantee. A copy
of these instructions must be included in the application for equipment authorization. For example,
there are very strict operational and timing requirements that must be met before a transmitter is
authorized for operation under Section 15.231. For instance, data transmission is prohibited, except for
operation under Section 15.231(e), in which case there are separate field strength level and timing
requirements. Compliance with these requirements must be assured. 15.212(a)(1)(vii)
Details: <example – The module complies with FCC Part 15C requirements. Instructions to the OEM installer are provided in
the installation manual filed with this application.>
☒ - YES ☐ - NO(*)
8. The modular transmitter must comply with any applicable RF exposure requirements. For example,
FCC Rules in Sections 2.1091, 2.1093 and specific Sections of Part 15, including 15.319(i), 15.407(f),
15.253(f) and 15.255(g), require that Unlicensed PCS, UNII and millimeter wave devices perform
routine environmental evaluation for RF Exposure to demonstrate compliance. In addition, spread
spectrum transmitters operating under Section 15.247 are required to address RF Exposure compliance
in accordance with Section 15.247(b)(4). Modular transmitters approved under other Sections of Part
15, when necessary, may also need to address certain RF Exposure concerns, typically by providing
specific installation and operating instructions for users, installers and other interested parties to ensure
compliance. 15.212(a)(1)(viii)
Details: <example – The module meets Portable exclusion levels as shown in the RF exposure information filed with this
application.>
☒ - YES ☐ - NO(*)
Limited Module Description – When Applicable
* If a module does NOT meet one or more of the above 8 requirements, the applicant may request Limited Modular Approval (LMA).
This Limited Modular Approval (LMA) is applied with the understanding that the applicant will demonstrate and will retain control over
the final installation of the device, such that compliance of the end product is always assured. The operating condition(s) for the LMA;
the module is only approved for use when installed in devices produced by grantee. A description regarding how control of the end
product, into which the module will be installed, will be maintained by the applicant/manufacturer, such that full compliance of the end
product is always ensured should be provided here.
Details: <example - N/A>
070920-02b
SONY
Sony Group Corporation
1-7-1 Konan Minato-Ku Tokyo, 108-0075 Japan
Software Considerations – KDB 594280 / KDB 442812 (One of the following 2 items must be applied)
Requirement
1. For non-Software Defined Radio transmitter modules where software is used to ensure
compliance of the device, technical description must be provided about how such
control is implemented to ensure prevention of third-party modification; see KDB
Publication 594280.
Details: <example – The firmware of the device can not be modified or adjusted by the end user as described in a separate cover
letter filed with this application. >
☐ - Provided in Separate
Cover Letter
Requirement Met
☒ - N/A
2. For Software Defined Radio (SDR) devices, transmitter module applications must
provide a software security description; see KDB Publication 442812.
☐ - Provided in Separate
Cover Letter
☒ - N/A
Details: <example –N/A>
Split Modular Requirements
Requirement
Provided in Manual
1. For split modular transmitters, specific descriptions for secure communications
between front-end and control sections, including authentication and restrictions on
third-party modifications; also, instructions to third-party integrators on how control is
maintained.
Details: <example – N/A >
☐ - Provided in Separate
Cover Letter
☒ - N/A
OEM Integration Manual Guidance – KDB 996369 D03 Section 2
Clear and Specific Instructions Describing the Conditions, Limitations, and Procedures
for third-parties to use and/or integrate the module into a host device.
Requirement
Is this module intended for
sale to third parties?
☐ - YES
☒ - No,
If No, and LMA applies, the applicant can optionally choose to not
make the following detailed info public. However there still needs
to be basic integration instructions for a users manual and the
information below must still be included in the operational
description. If the applicant wishes to keep this info confidential,
this will require a separate statement cover letter explaining the
module is not for sale to third parties and that integration
instructions are internal confidential documents.
Items required to be in the manual – See KDB 996369 D03, Section 2
As of May 1, 2019, the FCC requires ALL the following information to be in the installation manual. Modular transmitter
applicants should include information in their instructions for all these items indicating clearly when they are not applicable. For
example information on trace antenna design could indicate “Not Applicable”. Also if a module is limited to only a grantees own
products and not intended for sale to third parties, the user instructions may not need to be detailed and the following items can
be placed in the operational description, but this should include a cover letter as cited above.
1. List of applicable FCC rules. KDB 996369 D03, Section 2.2
a. Only list rules related to the transmitter.
2. Summarize the specific operational use conditions. KDB 996369 D03, Section 2.3
a. Conditions such as limits on antennas, cable loss, reduction of power for point to point
3. Limited Module Procedures. KDB 996369 D03, Section 2.4
systems, professional installation info
a. Describe alternative means that the grantee uses to verify the host meets the necessary
limiting conditions
b. When RF exposure evaluation is necessary, state how control will be maintained such
that compliance is ensured, such as Class II for new hosts, etc.
4. Trace antenna designs. KDB 996369 D03, Section 2.5
a. Layout of trace design, parts list, antenna, connectors, isolation requirements, tests for
design verification, and production test procedures for ensuring compliance. If
☒ - All Items shown to
the left are provided in
the Modular Integration
Guide (or UM) for Full
Modular Approval (MA)
or LMA.
☐ - An LMA applies
and is approved ONLY
for use by the grantee in
their own products, and
not intended for sale to
070920-02b
SONY
Sony Group Corporation
1-7-1 Konan Minato-Ku Tokyo, 108-0075 Japan
confidential, the method used to keep confidential must be identified and information
provided in the operational description.
5. RF exposure considerations. KDB 996369 D03, Section 2.6
a. Clearly and explicitly state conditions that allow host manufacturers to use the module.
Two types of instructions are necessary: first to the host manufacturer to define
conditions (mobile, portable – xx cm from body) and second additional text needed to be
provided to the end user in the host product manuals.
3rd parties as provided in
a separate cover letter.
Therefore the
information shown to the
left is found in the
theory of operation.
6. Antennas. KDB 996369 D03, Section 2.7
a. List of antennas included in the application and all applicable professional installer
instructions when applicable. The antenna list shall also identify the antenna types
(monopole, PIFA, dipole, etc – note that “omni-directional” is not considered a type)
7. Label and compliance information. KDB 996369 D03, Section 2.8
a. Advice to host integrators that they need to provide a physical or e-label stating
“Contains FCC ID: “ with their finished product
8. Information on test modes and additional testing requirements. KDB 996369 D03, Section 2.9
a. Test modes that should be taken into consideration by host integrators including
clarifications necessary for stand-alone and simultaneous configurations.
b. Provide information on how to configure test modes for evaluation
9. Additional testing, Part 15 Subpart B disclaimer. KDB 996369 D03, Section 2.10
Sincerely,
By:
__________________________
Takeshi Kobayashi
Product Safety Manager
Product Compliance Section
Quality Assurance Department
Sony Corporation.
Tel: +81-050-3750-6543
Fax: +81-050-3750-6573
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