KDB 996369 D03 and D04: New FCC Guidance for Manufacturers Using Radio Modules

Recently, the FCC published a new guidance document for manufacturers using radio modules, FCC KDB 996369 D03 & D04 v01.  This is a must-read document that outlines the steps that manufacturers must now take to ensure they are meeting the FCC’s rules when incorporating radio modules into their equipment.  

The key change, included in section 2.0, highlights that the FCC is now strongly recommending that manufacturers carry out emissions tests on the radio once installed in the host, in addition to following all module guidance and grant notes. This is a step change in how the FCC treat modules, bringing them more in line with the EU approach to modular radios.  The FCC document goes on to clarify that verifying a transmitter by testing for spurious emissions is necessary even if only one module is installed in the host.

What Does This Mean?

By releasing this update, the FCC is handing down clear guidance about manufacturers’ obligations when integrating modules into host products. While this should make the testing and compliance process easier, it also means that some products may need updated instructions or technical documentation. To help you understand this update, our experts break down what has changed in KDB 996369 D03 & D04, and what this means for you. 

Changes to KDB 996369 D03 & D04

Section D03 provides guidance on creating instructions for host manufacturers looking to integrate radio modules in their products, while Section D04 clarifies test standards and certification requirements.

The major changes released in this update include:

• Carrying out emissions testing on the product with the module installed
• Requiring more information on the TCB when the module uses a trace antenna
• Requiring grantees to provide test mode information to module integrators
• Ensuring that the grantee has a statement regarding end devices being tested for EMC
• Reducing ambiguity in module integration instructions
• Increasing consistency in test plans and final test reports
• Giving grantees the responsibility for providing restriction of use documentation to the integrator 

Staying Up to Date with KDB 996369 D03 & D04

Since most of the changes in this update affect instructional and guidance documentation, it’s important to ensure that your DoC and technical file are up to date. Our product testing and certification experts help ensure that your product remains certified under the new requirements.