FCC ID: UY6-FHLSM Module with communication function for sending and receiving data to and from compatible wireless devices

Integration guide TOHNICHI RF MODULE MODEL: FHLSM Board Board+FHLSM Applicable FCC Rules The following FCC rules are applicable to the radio module:

CFR 47, Part 15.247 The radio module is only tested to the above FCC rules, therefore further testing is required for unintentional emissions to FCC Part 15, Subpart B after the radio module is integrated into the host. Limited module procedures This radio module is approved for integration into host model T-FHLSM-Sub Board. Integration into hosts that are different in construction require a Class II Permissive Change filing on the limited modular certification to allow use in other hosts. RF exposure considerations The antenna used for this transmitter must be installed to provide a separation distance of at least 20 cm from all persons and must not be co-located or operating in conjunction with any other antenna or transmitter. Antennas The module must only be used with the antennas provided. Label and Compliance information The following information must be provided to the user in the host user manual:

CAUTION Changes or modifications not expressly approved by the party responsible for compliance could void the users authority to operate the equipment. This device complies with Part 15 of the FCC Rules. Operation is subject to the following two conditions: (1) this device may not cause harmful interference, and

(2) this device must accept any interference received, including interference that may cause undesired operation. The host which is equipped with FHLSM must be labeled with:

Contains FCC ID: UY6-FHLSM Contains IC: 6561B-FHLSM

User Manual TOHNICHI RF MODULE MODEL: FHLSM The purpose of this manual is to explain correct way how to integrate module FHLSM to the end product. It includes procedures that shall assist you to avoid unforeseen problems. This manual presents information that shows how module and end product, where module integrated, complies with regulations in certain regions. Any modifications, not expressly approved by the manufacturer could void the authority to operate in these regions. The TOHNICHI RF MODULE, model FHLSM is installed in a portable device or in a fixed device. The usage is only for data transmission. And the FHLSM RF MODULE has to be installed and used in accordance with the technical description/installation instructions provided by the manufacturer. The system may only be implemented in the configuration that was authorized. Note that any changes or modifications to this equipment not expressly approved by the manufacturer could void the users authority to operate this equipment. Regulatory Information USA-Federal Communications Commission (FCC) This device complies with Part 15 of the FCC Rules. Operation is subject to the following two conditions:

(1) This device may not cause harmful interference, and

(2) This device must accept any interference received, including interference that may cause undesired operation. Any changes or modifications not expressly approved by the party responsible for compliance could void the users authority to operate the equipment. Labeling TOHNICHI RF MODULE FHLSM is labeled as below. FCC ID: UY6-FHLSM The proposed with FCC ID label format is to be placed on the module. If FCC ID is not visible when the module is installed into the system, Contains FCC ID: UY6-FHLSM shall be placed on the outside of final host system. Caution: Exposure to Radio Frequency Radiation. To comply with RF exposure compliance requirements, this device must not be co-located or operating in conjunction with any other antenna or transmitter. Operating by itself, the output power from this device is below the threshold where SAR measurements are required. Canada-Industry Canada (IC) This device complies with Industry Canada licence-exempt RSS standard(s). Operation is subject to the following two conditions:

(1) This device may not cause interference, and

(2) This device must accept any interference, including interference that may cause undesired operation of this device. Le prsent appareil est conforme aux CNR d'Industrie Canada applicables aux appareils radio exempts de licence. L'exploitation est autorise aux deux conditions suivantes :

(1) il ne doit pas produire de brouillage et

(2) l utilisateur du dispositif doit tre prt accepter tout brouillage radiolectrique reu, mme si ce brouillage est susceptible de compromettre le fomctionnement du dispositif. Labeling TOHNICHI RF MODULE FHLSM is labeled as below. IC: 6561B-FHLSM The proposed with IC ID label format is to be placed on the module. If IC ID is not visible when the module is installed into the system, Contains IC: 6561B-FHLSM shall be placed on the outside of final host system. Caution: Exposure to Radio Frequency Radiation. To comply with RF exposure compliance requirements, this device must not be co-located or operating in conjunction with any other antenna or transmitter. Operating by itself, the output power from this device is below the threshold where SAR measurements are required. Attention: Exposition aux radiations de frquences radio. Pour se conformer aux exigences de conformit d'exposition aux RF, cet appareil ne doit pas tre colocalis ni fonctionner en conjonction avec une autre antenne ou transmetteur. D'exploitation par elle-mme, la puissance de sortie de cet appareil est en dessous du seuil o les mesures SAR sont ncessaires. Instructions to OEM Integrators A User manual provided to the end user must indicate the operating requirements and conditions that must be observed to ensure compliance with the above-mentioned FCC /IC RF Exposure guideline.

Product Name: RF MODULE |

Model No:FHLSM FCC ID :UY6-FHLSM IC :6561B-FHLSM R 001-X RK Brny S/N eee TOHNICHT MFG.CO.,LTD. 16 Product Name: RF MODULE Model No:FHLSM FCC ID :UY6-FHLSM IC :6561B-FHLSM TR 001-X ae Bry S/N veeseetok TOHNICHI MFG. CO.,LTD. eS RF TRANSCEIVER lodel No: T-FHPM Contains FCC ID: UY6-FHLSM |

Contains IC :6561B-FHLSM |

IN: TORINIGH MFG. CO, LID, 39.3 Product Name: RF TRANSCEIVER Model No: T-FHLSM Contains FOC ID: UY6-FHLSM Contains IC: 6618-FHLSM SIN: TORINIGH MFG. Co. Li. Marking position juct Name: RF TRANSCEIVER jodel No: T-FHPM Contains FCC ID: UY6-FHLSM |

Contains IC :6561B-FHLSM |

Ni _- TOHINIGHLVIFG, CO. LTD, 39.3 10 im Product Name: RF TRANSCEIVER Model No: T-FHPM Contains FCC ID: UY6-FHLSM Contains IC :6961B-FHLSM S/N: TOHINIGH MFG. Ly. Marking position Product Name : RF TRANSCEIVER Please do Not use for SOR O ER (clk Model No : T-TOFHM screw loosening operation. ULBWUEES UW. Contains FCC ID : UY6-FHLSM | E Plese do Not Bsr (CH RLAWe Contains IG : 6861B-FHLSM disassemble in any case. Feu SIN: TOKNICH MFG. CO. LT, owe Product Name : RF TRANSCEIVER Model No : T-TOFHIA Contains FOC ID : UY6-FHLSM Gontaing IG : 68618-FHLSM SIN:

Modular Approval Request - FCC RE: Request for modular approval Model: FHLSM FCC ID: UY6-FHLSM To whom it may concern, We formally request modular approval on the above reference device pursuant to the requirements of FCC publication 996369 D01 for modular approval of Part 15 devices. Modular approval requirement Yes No Comment*

(a) The radio elements of the radio frequency circuitry must be shielded. Physical/discrete and tuning capacitors may be located external to the shield, but must be on the module assembly.

(b) The module shall have buffered modulation/data input(s) (if such inputs are provided) to ensure that the module will comply with the requirements set out in the applicable FCC rule part under conditions of excessive data rates or over-modulation.

(c) The module shall have its own power supply regulation on the module. This is to ensure that the module will comply with the requirements set out in the applicable standard regardless of the design of the power supplying circuitry in the host device which houses the module.

(d) The module must certified with specific antennas and these antennas must be contain a permanently attached antenna, or contain a unique antenna connector, and be marketed and operated only with specific antenna(s).

(e) The module shall be tested for compliance with the applicable standard in a stand-alone configuration, i.e. the module must not be inside another device during testing.

(f) The module must be labelled with its permanently affixed FCC ID label, or use an electronic display.

(g) The module shall comply with all specific rules applicable to the transmitter including all the conditions provided in the integration instructions provided by the grantee.

(h) The module must comply with RF exposure requirements

* Please provide a detailed explanation for each item 1 | P a g e Comment The FHLSM module is not for use with other manufacturers products. Based on the above information this request is for:

LIMITED SINGLE modular approval. Sincerely, Satoshi Takaku 1/26/2021 Company name and address: TOHNICHI MFG. CO., LTD. 2-12, Omori-kita 2-Chome, Ota-ku Tokyo 143-0016 Japan 2 | P a g e Instructions:

Signature:

Definitions:

Please complete this form and copy to company letterhead. The request should be signed by the person who is listed as the contact person on the FCC Grantee database. Single modular approval If all of the answers in the checklist are YES then the product may be approved as a single modular approval. In this case the module may be placed in any host product and may be sold to third parties for integration into host products. Limited modular approval If one or more of the single modular requirements in the checklist cannot be met, the product may be eligible for limited modular approval. In this case the approval is host specific and the product may only be integrated into host configurations for which it has been certified. A Class II Permissive Change may be filed to add host configurations. 3 | P a g e

Tohnichi Mfg. Co., Ltd. 2-12, Omori-Kita 2-Chome, Ota-Ku, Tokyo, Japan Date: January 26, 2021 Equipment Authorization Division Federal Communications Commission 7435 Oakland Mills Road Columbia, MD 21046 Authority to Act as Agent FCC On our behalf, I appoint Cosmos Corporation, 718-1 Katsurase-Cho, Matsusaka-Shi, Mie-Ken 515-1104, Japan, to act as our agent in the preparation of this application for equipment certification. I certify that submitted documents properly describe the device or system for which equipment certification is sought. I also certify that each unit manufactured, imported or marketed, as defined in FCC regulations will have affixed to it a label identical to that submitted for approval with this application. In signing this letter, Applicant certifies that neither the applicant nor any party to the application is not subject to a denial of Federal benefits, that include FCC benefits, pursuant to Section 5301 of the Anti-Drug Abuse Act of 1988, 21 U.S.C. 862 because of a conviction for possession or distribution of a controlled substance. See 47 CFR 1.2002(b) for the definition of a "party" for these purposes. For instances where our authorized agent signs the application for certification on our behalf, I acknowledge that all responsibility for complying with the terms and conditions for certification, as specified by Nemko North America Inc., still resides TOHNICHI MFG. CO., LTD., 2-12, Omori-

kita 2-Chome, Ota-ku Tokyo 143-0016 Japan. Dated this 26 Agency agreement expiration date: Usually Give 3 Months January 20 21 Day of Signature Satoshi Takaku Printed Title: Deputy General Manager On behalf of : TOHNICHI MFG. CO., LTD. Telephone: +81-3-3762-7859 By:

DCN:QAF1839 Issued:19/02/28 Revised:--/--/--

Requirement Compliance list for INTEGRATION INSTRUCTIONS Sections 2.2 through 2.10 of 996369 D03 OEM. Page No. Page 1 of Integration guide Yes No Comment X 2.2 List of applicable FCC rules List the FCC rules that are applicable to the modular transmitter. These are the rules that specifically establish the bands of operation, the power, spurious emissions, and operating fundamental frequencies. DO NOT list compliance to unintentional-radiator rules (Part 15 Subpart B) since that is not a condition of a module grant that is extended to a host manufacturer. See also Section 2.10 below concerning the need to notify host manufacturers that further testing is required.3 2.3 Summarize the specific operational use conditions Describe use conditions that are applicable to the modular transmitter, including for example any limits on antennas, etc. For example, if point-to-

point antennas are used that require reduction in power or compensation for cable loss, then this information must be in the instructions. If the use condition limitations extend to professional users, then instructions must state that this information also extends to the host manufacturers instruction manual. In addition, certain information may also be needed, such as peak gain per frequency band and minimum gain, specifically for master devices in 5 GHz DFS bands. 2.4 Limited module procedures If a modular transmitter is approved as a limited module, then the module manufacturer is responsible for approving the host environment that the limited module is used with. The manufacturer of a limited module must describe, both in the filing and in the installation instructions, the alternative means that the limited module manufacturer uses to verify that the host meets the necessary requirements to satisfy the module limiting conditions. A limited module manufacturer has the flexibility to define its alternative method to address the conditions that limit the initial approval, such as:

shielding, minimum signaling amplitude, buffered modulation/data inputs, or power supply regulation. The alternative method could include that the limited module manufacturer reviews X Page 1 of User Manual X Page 1 of Integration guide

Not applicable detailed test data or host designs prior to giving the host manufacturer approval. This limited module procedure is also applicable for RF exposure evaluation when it is necessary to demonstrate compliance in a specific host. The module manufacturer must state how control of the product into which the modular transmitter will be installed will be maintained such that full compliance of the product is always ensured. For additional hosts other than the specific host originally granted with a limited module, a Class II permissive change is required on the module grant to register the additional host as a specific host also approved with the module. 2.5 Trace antenna designs For a modular transmitter with trace antenna designs, see the guidance in Question 11 of KDB Publication 996369 D02 FAQ Modules for Micro-Strip Antennas and traces. The integration information shall include for the TCB review the integration instructions for the following aspects:

layout of trace design, parts list (BOM), antenna, connectors, and isolation requirements.4 a) Information that includes permitted variances

(e.g., trace boundary limits, thickness, length, width, shape(s), dielectric constant, and impedance as applicable for each type of antenna);

b) Each design shall be considered a different type

(e.g., antenna length in multiple(s) of frequency, the wavelength, and antenna shape (traces in phase) can affect antenna gain and must be considered);

c) The parameters shall be provided in a manner permitting host manufacturers to design the printed circuit (PC) board layout;

d) Appropriate parts by manufacturer and specifications;

e) Test procedures for design verification; and f) Production test procedures for ensuring compliance. The module grantee shall provide a notice that any deviation(s) from the defined parameters of the antenna trace, as described by the instructions, require that the host product manufacturer must notify the module grantee that they wish to change the antenna trace design. In this case, a Class II permissive change application is required to be filed by the grantee, or the host manufacturer can take responsibility through the change in FCC ID (new application) procedure followed by a Class II permissive change application. 2.6 RF exposure considerations It is essential for module grantees to clearly and explicitly state the RF exposure conditions that permit a host product manufacturer to use the module. Two types of instructions are required for RF exposure information: (1) to the host product manufacturer, to define the application conditions (mobile, portable xx cm from a persons body); and (2) additional text needed for the host product manufacturer to provide to end users in their end-product manuals. If RF exposure statements and use conditions are not provided, then the host product manufacturer is required to take responsibility of the module through a change in FCC ID (new application). 2.7 Antennas A list of antennas included in the application for certification must be provided in the instructions. For modular transmitters approved as limited modules, all applicable professional installer instructions must be included as part of the information to the host product manufacturer. The antenna list shall also identify the antenna types

(monopole, PIFA, dipole, etc. (note that for example an omni-directional antenna is not considered to be a specific antenna type)). For situations where the host product manufacturer is responsible for an external connector, for example with an RF pin and antenna trace design, the integration instructions shall inform the installer that unique antenna connector must be used on the Part 15 authorized transmitters used in the host product. The module manufacturers shall provide a list of acceptable unique connectors. 2.8 Label and compliance information Grantees are responsible for the continued compliance of their modules to the FCC rules. This includes advising host product manufacturers that they need to provide a X Page 2 of Integration guide X Page 2 of Integration guide X Page 2 of Integration guide

Not applicable. The module is only integrated into the manufacturers own host products and the manufacturer controls and has access to the test modes required for testing of the transmitter. X Page 1 of Integration guide physical or e-label stating Contains FCC ID with their finished product. See Guidelines for Labeling and User Information for RF Devices KDB Publication 784748. 2.9 Information on test modes and additional testing requirements5 Additional guidance for testing host products is given in KDB Publication 996369 D04 Module Integration Guide. Test modes should take into consideration different operational conditions for a stand-alone modular transmitter in a host, as well as for multiple simultaneously transmitting modules or other transmitters in a host product. The grantee should provide information on how to configure test modes for host product evaluation for different operational conditions for a stand-

alone modular transmitter in a host, versus with multiple, simultaneously transmitting modules or other transmitters in a host. Grantees can increase the utility of their modular transmitters by providing special means, modes, or instructions that simulates or characterizes a connection by enabling a transmitter. This can greatly simplify a host manufacturers determination that a module as installed in a host complies with FCC requirements. 2.10 Additional testing, Part 15 Subpart B disclaimer The grantee should include a statement that the modular transmitter is only FCC authorized for the specific rule parts (i.e., FCC transmitter rules) listed on the grant, and that the host product manufacturer is responsible for compliance to any other FCC rules that apply to the host not covered by the modular transmitter grant of certification. If the grantee markets their product as being Part 15 Subpart B compliant (when it also contains unintentional-radiator digital circuity), then the grantee shall provide a notice stating that the final host product still requires Part 15 Subpart B compliance testing with the modular transmitter installed.6

Tohnichi Mfg. Co., Ltd. 2-12, Omori-Kita 2-Chome, Ota-Ku, Tokyo, Japan Date: January 26, 2021 Equipment Authorization Division Federal Communications Commission 7435 Oakland Mills Road Columbia, MD 21046 FCC ID: UY6-FHLSM Product Name: FHLSM Request for Confidentiality Pursuant to Sections 0.457 and 0.459 of the commissions rules, we hereby request that the following documents be held confidential:

Block diagram Schematics Parts list Operational Description These materials contain trade secrets and proprietary information and are not customarily released to the public. The public disclosure of this information might be harmful to the company and provide unjustified benefits to our competitors. Dated this 26 Day of January, By:

20 21 Signature Satoshi Takaku Printed Title: Deputy General Manager On behalf of : TOHNICHI MFG. CO., LTD. Telephone: +81-3-3762-7859 DCN:QAF1840 Issued:19/02/28 Revised:--/--/--