Posted by Priscilla Soerachmat, December 31, 2023
Permissive Change Policy: What it is and how it can save manufacturers time and money
The Federal Communications Commission (FCC) has a "permissive change policy," which is a set of rules that allow companies or organizations to make certain changes to their existing certifications without needing to get a new approval. The manufacturer of the complete device or the company that initially obtained FCC certification or authorization for the device must seek approval for changes.
In simple terms, it's like having permission to make small changes to something you already have, like your smartphone or a radio transmitter, without having to go through a lot of paperwork or waiting for a long approval process. This policy makes it easier for businesses to adapt and improve their products or services without too much government regulation, as long as the changes don't cause any major problems or interference with other communication systems.
For example: Let's say an integrator integrates a Silex module into their product, and they've received approval from the FCC to sell it in the market. However, they later discover that they want to use a higher gain antenna than what’s already approved. Without having to go through the entire approval process again, they will be able to make a permissive change to the existing approval. This would save them time and money.
Now, let’s dive deeper into permissive changes and what you need to know.
Types of permissive change:
The FCC typically distinguishes between major and minor permissive changes. Major changes might involve significant alterations to the service or equipment, while minor changes are more routine or administrative in nature.
Classes of Permissive Changes:
- Class I Permissive Changes: Class I changes are considered minor changes that do not affect the device's emissions, frequency stability, or RF output. They typically include changes to the device's labeling, user manual, or enclosure.
- Class II Permissive Changes: Class II changes are more significant than Class I changes but still do not affect the device's emissions characteristics. These changes might involve modifications to the device's hardware, software, or other aspects that have minimal impact on its RF performance.
- Class III Permissive Changes: Class III changes are more substantial and encompass modifications that may impact the device's RF emissions or RF performance. These changes require a higher level of scrutiny and testing to ensure compliance with FCC regulations.
Who should file for a permissive change?
Typically, the responsibility of the equipment manufacturer or the party that holds the original equipment authorization to file for the permissive change. This means that the manufacturer of the complete device or the company that initially obtained FCC certification or authorization for the device must seek approval for changes.
If a module manufacturer supplies a component (e.g., a Wi-Fi or Bluetooth module) to other companies that integrate it into their products, the module manufacturer is not typically the one to file for permissive changes with the FCC. Instead, it's the responsibility of the company that incorporates the module into their device to ensure compliance with FCC regulations and request any necessary approvals or modifications to the equipment authorization. This is because the FCC authorization typically covers the entire device and not just individual components or modules.
The module manufacturer may provide documentation and support to assist their customers in the process of seeking permissive changes or ensuring that the integrated device remains in compliance with FCC rules, but the ultimate responsibility for obtaining FCC authorization for the complete product lies with the company that markets and sells the final device. They must consider how the module integration affects the device's regulatory compliance and address any necessary permissive changes accordingly.
What are the Federal Communications Commission (FCC) guidelines for making antenna permissive changes?
For this particular blog, we will focus specifically on permissive changes for antennas, which is one of the most common forms we see today.
Section II of the 178919 D01 Permissive Change Policy document outlines guidelines for making antenna permissive changes in compliance with FCC regulations. It distinguishes between Part 15 equivalent-type antennas and antenna replacement for licensed service transmitters.
For Part 15 certification applications, a list of approved antennas with their specifications and photographs is necessary. Equivalents can be substituted without a Class II permissive change, except for specific cases outlined in the document. In these cases, changes in antenna patterns or types may require a Class II permissive change.
Equivalent antennas must match the same type and have similar characteristics as the previously authorized antenna. Higher gain antennas or new types require a Class II permissive change, and § 15.203 requirements apply.
For licensed service transmitters, antenna changes are permitted if they adhere to RF exposure compliance and ERP/EIRP rules. Integral antennas, where the antenna is non-removable, do not require authorization requests. Otherwise, equipment authorization applications are necessary for antenna changes.
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Let Silex Technology Help You with Your Permissive Change
Silex certification services help you lower costs, improve lead times, and reduce risk. Our certification experts can help you navigate the complexities of Permissive Change Policy eligibility and regulatory compliance. We'll give you a step-by-step approach to getting certified. Our 20+ years of experience as a Wi-Fi module provider will help you plan for compliance considerations, so there's no delay in product certification, and you can launch on time and on budget.
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We know what it takes to meet the ETSI, FCC, and other wireless testing specifications for wireless radio manufacturers. In fact, many device manufacturers outsource their certification responsibilities to Silex because of our experience. Let us guide you through the certification process. Learn more >>
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Keeping Up with Regulatory Compliance Changes
Once regulatory certification and country registration(s) are done, it's critical to stay on top of the regulatory changes to remain compliant. Silex Technology closely monitors the ever-changing certification requirements and proactively informs customers of upcoming changes and required renewals. We also publish updates regularly on the Silex Unwired blog to keep customers informed.
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