Does a mobile data device still need PTCRB certification if it uses a module that is already certified?

Answer 1

Let me start answering this question by clarifying the terminology used by PTCRB. Here are some important definitions taken from PTCRB NAPRD03:

End product:

End Products are defined as devices that

-Utilize a standard interface (USB, PCMCIA, Compact Flash, MMC, RS-232, IEEE-1394.)

-Obtain power from the standard interface or have a provisioned power source

-Include a fully self-contained USIM/SIM socket

-Utilize a self-contained antenna or provide an external antenna connector.

When an End Product is connected to (but not embedded within) a host device (PC, PDA, etc.), no certification of the host device is required. By its design and intended user application, an End Product must be consistent with the terms of its FCC / IC type acceptance (e.g. type of antenna, distance from user, etc.). In all cases, the End Product shall not alter its antenna system in any way from that allowed by the associated Type Acceptance or other regulatory approval.

Integrated Device:

Any device type that embeds a PTCRB-certified module. In order to be considered an integrated device, the PTCRB-certified module must be embedded in full accordance with the module's Initial PTCRB certification.

Module:

Modules are devices that do not directly connect to a host via a standard interface. A module may or may not include its own antenna system. Modules almost always require additional certification when integrated within another device.

For further clarity:

If you are interfacing your custom circuitry/computer to a PTCRB End Device using an industry standard interface, then no further certifications are required.

PTCRB certified modules(aka integrated modules), in my opinion, should be called "pre-certified" because they all have to be certified again on the final platform of the End Product, which costs between $27k-45k according to AT&T.

Where the question is most relevant is regarding some of the modules coming onto the market that claim they are PTCRB certified. The grey area is that they are actually an Integrated Device where the module has been certified and then integrated onto a carrier board that has been PTCRB approved on a specific test platform, and as long as you employ the "module" in the manner in which they were certified then they do not require additional PTCRB certifications. Buyer beware on these modules - if it does not fall into the PTCRB definition of the End product, then your safest assumption is that it will require additional PTCRB certifications(take it from me - I have been burned with this once!).

Some good due diligence to do would be to contact the vendor to verify their PTCRB certification, and how it was certified. Follow it up and contact their test lab to confirm how the device is certified to be used. At a minimum, the most important thing to do is to contact the wireless service provider to see if they will permit the device on their network as they are ultimately the ones with the final say.