FCC FCC ID Labeling & Documentation Requirements 3 — Questions and Answers
Question 1: What is the purpose of a 'test setup photograph' in an FCC compliance test report?
- To document the exact physical configuration of the device, cables, and peripherals during testing, enabling the test to be reproduced and verifying the worst-case configuration was used (Correct answer)
- To provide a marketing image for the FCC public database
- To satisfy an aesthetic requirement in the test report format
- To record the equipment serial numbers of all instruments used in the test
Correct answer: To document the exact physical configuration of the device, cables, and peripherals during testing, enabling the test to be reproduced and verifying the worst-case configuration was used
Test setup photographs document the physical test configuration—cable routing, peripheral placement, device orientation, and antenna positioning—so that the test can be independently verified, repeated, and confirmed as representing worst-case operation.
Question 2: What is the 'Modular Approval' process under FCC rules and when is it used?
- A process that grants equipment authorization to a radio frequency module independently so it can be incorporated into host devices without requiring the host to undergo full RF testing (Correct answer)
- A process for certifying modular furniture that contains embedded electronics
- An abbreviated testing process for devices with modular power supplies
- A process for certifying devices that are sold in modules and assembled by the end user
Correct answer: A process that grants equipment authorization to a radio frequency module independently so it can be incorporated into host devices without requiring the host to undergo full RF testing
FCC Modular Approval (KDB 996369) allows an RF module to receive its own FCC authorization, permitting it to be integrated into a variety of host products; hosts that meet the grant conditions may only need to demonstrate compliance of the complete system rather than repeat full RF testing.
Question 3: What is a 'C2PC' (Class II Permissive Change) application and what triggers the need for one?
- An application to update an existing FCC authorization when a certified device is modified in a way that could affect its RF characteristics, requiring retesting (Correct answer)
- An application filed when a manufacturer changes the device's color or branding
- A routine annual renewal of an FCC equipment authorization
- An application required when the manufacturing facility moves to a new location
Correct answer: An application to update an existing FCC authorization when a certified device is modified in a way that could affect its RF characteristics, requiring retesting
A C2PC is filed when modifications to a certified device—such as adding a new frequency band, changing the antenna, or modifying power amplifier circuits—may alter the device's emissions or RF characteristics, requiring new test data to be submitted to the original granting authority.
Question 4: What happens to the FCC equipment authorization if the responsible party goes out of business or transfers the device to a new owner?
- The new owner must file a change of grantee application with the FCC to transfer the authorization, or the device can no longer be legally marketed in the US (Correct answer)
- The authorization automatically transfers to the retailer selling the device
- The authorization is automatically cancelled and the device must be recertified
- The manufacturer's successor company inherits all FCC authorizations without any filing
Correct answer: The new owner must file a change of grantee application with the FCC to transfer the authorization, or the device can no longer be legally marketed in the US
FCC authorizations are tied to the grantee of record; if ownership transfers, the new responsible party must file a change of grantee application to update the FCC records, ensuring there is always an identifiable responsible party for each authorized device.
Question 5: What does the FCC require manufacturers to retain regarding equipment authorization documentation, and for how long?
- Test reports, application materials, and design documentation must be retained for 10 years and made available to the FCC upon request (Correct answer)
- Documents must be retained only until the device goes out of production
- Documents need only be retained for 2 years after the last device is sold
- Only the original test report must be retained; all other documents may be discarded after certification is granted
Correct answer: Test reports, application materials, and design documentation must be retained for 10 years and made available to the FCC upon request
FCC Part 2.938 requires that manufacturers retain all records documenting compliance (including test reports) for 10 years from the date of authorization, and must make them available to the FCC for inspection or enforcement purposes.
Question 6: What is the FCC's 'post-market surveillance' program and how does it affect certified device manufacturers?
- An FCC program that tests devices purchased from retail to verify they continue to meet FCC rules after market entry, with non-compliant devices subject to enforcement action (Correct answer)
- A program requiring manufacturers to submit annual compliance reports to the FCC
- A program where manufacturers self-test devices quarterly and report results online
- A program where retailers monitor customer complaints about RF interference
Correct answer: An FCC program that tests devices purchased from retail to verify they continue to meet FCC rules after market entry, with non-compliant devices subject to enforcement action
The FCC's post-market surveillance involves purchasing and testing devices from the market to verify ongoing compliance; devices found non-compliant can result in enforcement actions including recall orders, fines, and market withdrawal, even for previously certified devices.
FCC FCC ID Labeling & Documentation Requirements 3
What is the purpose of a 'test setup photograph' in an FCC compliance test report?