United States
& Canada

A module record is not a completed host dossier

“The supplier sent a module report. Can we freeze the North American gateway?”

The condition-monitoring team has a useful starting point: an identifiable module and its original operating envelope. The proposed host changes the antenna, firmware power controls and simultaneous radio state. Those changes create engineering questions even when the module’s own identity is unchanged. A record about a component becomes useful host evidence only through the conditions and configuration it actually covers.

Carry the authority map, configuration matrix and separate-territory discipline forward. The original teaching-node-v1 remains generic 2.450 GHz QPSK, 20 kbit/s information, 10 ksymbol/s, RRC roll-off 0.35 and 80 ksample/s at D3. It has not become Wi-Fi, Bluetooth or a legal operating mode. G02-NA-MA is a named local integration study; its gateway Wi-Fi capability is a separate, incompletely specified radio.

Classify the function and intended activity

A product can contain several regulated functions. Intentional radiation is designed into the transmitter. Digital clocks and USB activity may create a separate unintentional-radiator question. Incidental radiation is a different definition, not a convenient label for every unwanted emission. Read the definitions and the applicable device provisions before assigning an authorization procedure. Part 15’s general operating conditions also remain relevant after the equipment paperwork is assembled. [US-15]

Now identify the proposed activity. Testing a prototype, submitting an application, importing units, offering them for sale and operating them are different claims. A source that supports one activity need not settle the others. For Canada, RSS-Gen separates Category I and II equipment, certification and licensing; a licence-exempt operating category does not mean there are no technical or documentary obligations. [CA-GEN]

Trace the U.S. authorization question

Part 2 Subpart J defines equipment authorization procedures. Section 2.906 describes Supplier’s Declaration of Conformity (SDoC); §2.907 describes certification. Which procedure is available or required comes from the relevant equipment rules and exceptions. The existence of SDoC is not permission to choose it for any transmitter. [US-ROUTE]

Responsibility has an identity too. Under §2.909, the grantee has certification responsibilities; SDoC has its own responsible-party rules, including U.S. location. The U.S. agent for service of process in a certification application under §2.911 is a distinct role. A supplier contact, a test laboratory and an importer cannot be collapsed into “our compliance partner.” Current eligibility and covered-equipment provisions must also be reviewed for the actual applicant and supply chain. [US-ROUTE]

Part 15 is a rule structure, not one limit table

Part 15 is organized around general provisions and different equipment categories. Subpart B addresses unintentional radiators, with the authorization table in §15.101. Subpart C includes intentional-radiator requirements; §15.201 contains certification requirements and specified alternatives or exceptions. A real product review follows the exact category, including the exception’s conditions, rather than treating every emission as the same kind of radiator. [US-15]

The technical questions also remain separate. Antenna requirements appear in §§15.203–15.204, restricted bands in §15.205, and general radiated-emission requirements in §15.209. Device-specific provisions can add or change conditions. Measurement procedures, detector/averaging treatment and incorporated editions have their own references. Section 15.247 is a candidate to investigate for particular spread-spectrum or digitally modulated systems; “2.450 GHz” alone does not establish that this generic node meets its scope or bandwidth conditions. [US-15]

Certification, SDoC and KDB have different roles

A certification record, test report and KDB attachment do different work. The record identifies an authorization and its conditions. The report describes evidence about specified equipment. KDB guidance explains procedures within its scope. Reading a KDB catalogue establishes that an attachment exists; it does not establish that you have read the integration instructions. The 996369 publication lists separate certification, OEM manual and integration documents. Here the cited integration discussion comes from the actual D04 v02 attachment, pages 1–2. [US-MODULE] [US-INTEGRATE]

Labels and user information are another part of the record. Part 2 includes identification, eligible electronic labelling, retention and SDoC information provisions; §15.212 adds modular host identification/instruction conditions. A module label that becomes hidden inside the host raises a different documentation question from a visible module label. An electronic display option carries conditions; it is not a reason to omit identification. [US-ROUTE] [US-15]

Change review is similarly bounded. Section 2.1043 distinguishes permissive-change classes and circumstances requiring a new grant. Class III concerns qualifying software-defined-radio changes, not every firmware update. Software changes with no RF-emission effect are treated differently from changes to reported radio characteristics. The actual grant holder and relevant TCB must determine the applicable procedure; a numeric version comparison cannot do it. KDB 178919 is a discovery route to the detailed policy, whose attachments need to be read for the actual case. [US-ROUTE] [US-CHANGE]

Read the module integration envelope

Use Antennas in Real Products for the feed, mounting and installation context, and Coexistence and Technology Selection for simultaneous radio states. Here those physical facts become evidence dependencies.

Section 15.212’s modular provisions include antenna, power regulation, integration instructions and final-configuration RF exposure conditions. Limited modular approval has additional control and specified-condition considerations; “module” does not imply unrestricted use in any host. D04’s host guidance explicitly separates integration checks from other host functions and simultaneous-transmitter assessment. Read the actual grant conditions and supplier instructions together. [US-15] [US-INTEGRATE]

A duty factor of 0.10 gives −10 dB for a simple period-average energy-equivalent power only if on-level is fixed and off-power is zero. The on-time value does not change. This average cannot replace a specified detector or averaging interval, and two radio EIRPs in dBm must not be added to invent an exposure result. Read the final configuration with the exposure specialist.

Build Canada's own requirement chain

Canada needs its own chain: product/category, applicable general and specific radio standards, exposure requirements and any separately applicable interference-causing equipment standard. RSS-Gen Issue 6 distinguishes Category I certification from Category II certification exemption; Category II equipment still has applicable requirements and retained test evidence. The specific RSS can take precedence where its requirements differ from RSS-Gen. A receiver or host is not automatically routed as a complete transmitter. [CA-GEN]

RSS-247 Issue 4 is an example of a specific standard. Its scope describes particular FHS, DTS, hybrid and LE-LAN equipment; §2 identifies Category I treatment, licence exemption within that scope and the RSS-Gen relationship. This is a source-routing example, not a determination that the narrowband teaching waveform qualifies. Exposure belongs to the applicable RSS-102 family; digital-host treatment must follow RSS-Gen’s current subassembly distinction. Under Issue 6 §4.6, exclusively radio-enabling subassemblies are treated differently from additional digital functions. Do not assign ICES-003 from the mere presence of a processor. [CA-247] [CA-GEN]

For a digital apparatus with integrated radio modules, ICES-003 §1.4 points back to the relevant RSS and host requirements; §1.5 contains scope exemptions. RSS-102 §8 addresses combined exposure using the applicable exposure quantities and assessment conditions. These are separate source reviews; the model’s EIRP arithmetic settles neither. [CA-ICES] [CA-EXPOSURE]

Trace Canadian records and responsible roles

RSP-100 describes certification procedures, identities, modules and changes. An applicant whose company address is outside Canada must meet the Canadian-representative requirements in §4.1. RSS-Gen’s current text separately describes Category I records, the Radio Equipment List (REL), recognized certification bodies and recognized testing laboratories with appropriate scope. A body’s name is insufficient: recognition must cover the actual task. REC-CB §5 and REC-LAB §§5/7 distinguish body competence/accreditation from the laboratory’s recognized standards scope. Category II treatment differs. [CA-RSP] [CA-GEN] [CA-CB] [CA-LAB]

Keep certification number, product marketing name (PMN), hardware version identification number (HVIN), firmware version identification number (FVIN) and host marketing name (HMN) distinct. RSP-100 defines their roles; RSS-Gen’s current identification and host provisions govern the record/label correspondence. RSS-Gen §9.3.1 requires the applicable user information and notices in English and French, including the final host’s relevant module information. Host identification and eligible e-labelling have their own conditions. [CA-RSP] [CA-GEN]

Compare evidence while retaining both decisions

Shared hardware can make evidence reuse efficient, but evidence reuse is a claim about a report and a requirement. Compare exact specimen, radio state, antenna, feed, host loads, supply, installation, method/edition, laboratory scope, detector, bandwidth, geometry and uncertainty/decision rule. A formal report for a different configuration is a mismatch; a matched preliminary report is useful engineering evidence at a different maturity. Neither should be relabelled to look complete.

ISED’s adopted-method list demonstrates how to perform that review. It distinguishes dated and undated references, lists accepted editions and attaches conditions to alternate procedures, including certain FCC KDB methods. Acceptance of a test procedure does not make an FCC grant a Canadian certificate. A footnote referring to an older RSS issue must be reconciled with the current specific standard, not silently assumed current. [CA-METHOD]

Audit the package before antenna and firmware freeze

The route builder turns the package into eight review gates for each country. G1 establishes the declared identity/category/source; G2 records the module document’s identity and envelope. G3–G6 compare antenna, power/software, host evidence and concurrency/exposure. G7 retains the actor and documents; G8 retains method, source version and activity dates. A recorded gate means only that the exercise’s predicates are documented.

Validation comes first. An explicit mismatch takes summary precedence as challenge, while every unknown remains visible. Without a mismatch, missing or overdue evidence gives inspect. Only a fully documented teaching packet reaches review packet trace complete. This wording does not mean equipment authorized. A reviewed absent function can close only that function with a reason; missing evidence is never interpreted as absence.

All presets use frozen synthetic evaluation 2026-09-08 and editorial review due 2026-12-07 inclusive. The following day triggers a source recheck, not revocation of a grant or expiry of a report. Actual source research on 2026-09-09 is separately recorded in the source cards.