What are the FCC rules on taking a chip out of its current packaging and putting it inside another unit?

Thread Starter

Riskinit

Joined Jan 28, 2022
65
I have a wifi module (Advantech WISE-4220) shown in this datasheet:

https://advdownload.advantech.com/p...1/file/WISE-4220_DS(081319)20190820175517.pdf

I can fairly easily disassemble the outer-plastic-casing and hold onto the chip/antenna pieces. If I remove the outer casing and put the chip/antenna, unmodified, into another plastic case am I breaking any laws regarding the FCC?

Note: I am only concerned about the FCC. The chip/antenna would be safely protected in a smaller plastic case and then put into a larger plastic case. It would not be combined with any other antennas or wifi systems. It would not be used in anyway outside its standard operation.

Any citations are appreciated.
 

Thread Starter

Riskinit

Joined Jan 28, 2022
65
Type acceptance is based on the device being as tested. The FCC ID on the device comes after extensive and expensive testing. Here's the documentation from the device you have: https://fcc.report/FCC-ID/M82-WISE4220

That said, if you are not reselling it, and you do not cause harmful interference, you aren't going to hear from the FCC.
I will be selling this "new" device. I am putting the WISE-4220 into a larger plastic case with push buttons and a 120 to 24vdc power supply. The form factor of the WISE-4220 is larger and bulkier than I would like.

So it sounds like I would have to at minimum keep the original casing on the device.
 

Ya’akov

Joined Jan 27, 2019
9,237
I will be selling this "new" device. I am putting the WISE-4220 into a larger plastic case with push buttons and a 120 to 24vdc power supply. The form factor of the WISE-4220 is larger and bulkier than I would like.

So it sounds like I would have to at minimum keep the original casing on the device.
Yes, to sell it, it has to be in the configuration the FCC type acceptance was granted for. So, you are stuck with the case.
 

Thread Starter

Riskinit

Joined Jan 28, 2022
65
I was able to determine from the manual the unit is marketed for use "in a wall, panel, or cabinet" and is class B compliant. And per FCC regulations I have to add a sticker to my panel indicating the panel contains an FCC Certified Transmitter Module with [insert FCC ID]. I have to state to the end-user how far away my device, and therefore the transmitter, must be from operators (20 cm). I am not a lawyer but it seems reasonable to me that I can use the device inside a box as long as it is clearly stated what is inside and that I follow installation requirements by the manufacturer.
 

drjohsmith

Joined Dec 13, 2021
852
The power supply (AC-DC) will be in the same pushbutton box and attached by wires to the WISE-4220 terminals as instructed by the manual.
" it seems reasonable to me that I can use the device inside a box as long as it is clearly stated what is inside and that I follow installation requirements by the manufacturer"

Unfortunately ,
The fcc regulations, basically say that the "total" device is what is certified,
If you are putting a module into your product, its the product that you are certifying

Its your risk,
if the product is found to be failing FCC,
then the fact you have a qualifying module might be mitigating,
but is not an excuse, you will still have to pay fine / jail etc.
 

Thread Starter

Riskinit

Joined Jan 28, 2022
65
" it seems reasonable to me that I can use the device inside a box as long as it is clearly stated what is inside and that I follow installation requirements by the manufacturer"

Unfortunately ,
The fcc regulations, basically say that the "total" device is what is certified,
If you are putting a module into your product, its the product that you are certifying

Its your risk,
if the product is found to be failing FCC,
then the fact you have a qualifying module might be mitigating,
but is not an excuse, you will still have to pay fine / jail etc.
I did a fair amount of reading on the subject yesterday and I wasn't able to conclusively locate text that suggests I can't take a certified device marketed for industrial purposes and put it inside another device (a panel, box, enclosure). Consider an extreme example: I buy a wifi-router and put it inside my house. Surely I don't have to certify my house if I go to sell the house with the wifi-router inside it. But if I was to modify the wifi-router I would then have to certify it.

I am not trying to be defensive, but I fail to see how putting the FCC certified unit, unmodified, inside a pushbutton box is fundamentally different from putting the device in a larger industrial panel or in a manufacturing plant.

Unless every project I have ever worked on with wireless devices inside panels is also breaking FCC regulations, in which case I concede the point, I think a device marketed for industrial applications can be used in this particular application.
 

drjohsmith

Joined Dec 13, 2021
852
I did a fair amount of reading on the subject yesterday and I wasn't able to conclusively locate text that suggests I can't take a certified device marketed for industrial purposes and put it inside another device (a panel, box, enclosure). Consider an extreme example: I buy a wifi-router and put it inside my house. Surely I don't have to certify my house if I go to sell the house with the wifi-router inside it. But if I was to modify the wifi-router I would then have to certify it.

I am not trying to be defensive, but I fail to see how putting the FCC certified unit, unmodified, inside a pushbutton box is fundamentally different from putting the device in a larger industrial panel or in a manufacturing plant.

Unless every project I have ever worked on with wireless devices inside panels is also breaking FCC regulations, in which case I concede the point, I think a device marketed for industrial applications can be used in this particular application.
You asked for our advice, and understanding of the rules,
 

Ya’akov

Joined Jan 27, 2019
9,237
Like many other products, if your product does not cause interference it is not likely to attract any attention from the FCC, whose primary intention is to prevent interference.
This is true, but if an infringing product is offered for sale the potential liability is quite large. Even without causing interference it can lead to penalties and consent decrees. It doesn’t seem like a good idea to risk a business on the probability the FCC will not enforce the rules, even if it is highly in favor.

[EDIT: s/o/i/]
 
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Thread Starter

Riskinit

Joined Jan 28, 2022
65
This is true, but if an infringing product is offered for sale the potential liability is quite large. Even without causing interference it can lead to penalties and consent decrees. It doesn’t seem like a good idea to risk a business on the probability the FCC will not enforce the rules, even if it is highly in favor.

[EDIT: s/o/i/]
I no longer intend to modify the WIFI module (and when I say module I mean the full consumer end product; think of a wifi router, or a cellphone, or a connectivity device.) We are no longer talking about a bare bones chip that needs soldered or glued down.

So imagine I put an FCC certified wifi router into a large industrial panel. Do I need to certify the large industrial panel? I would think not. Putting the FCC certified wifi router into a smaller box isn't going to change this scenario. Putting 10 wifi routers into the same industrial box might cause unintentional inteference though so I can't do that.

After reading the FCC regulations I believe this truly is a gray area. The only thing I have been able to pick up from the literature is I have to list that my device contains an FCC certified device, stay 20 cm away from it when not in use, and don't put near other antennas.

I enjoy being proved wrong though so please cite any specific regulations stating I can't throw a wifi-router into a larger box.
 

Ya’akov

Joined Jan 27, 2019
9,237
I no longer intend to modify the WIFI module (and when I say module I mean the full consumer end product; think of a wifi router, or a cellphone, or a connectivity device.) We are no longer talking about a bare bones chip that needs soldered or glued down.

So imagine I put an FCC certified wifi router into a large industrial panel. Do I need to certify the large industrial panel? I would think not. Putting the FCC certified wifi router into a smaller box isn't going to change this scenario. Putting 10 wifi routers into the same industrial box might cause unintentional inteference though so I can't do that.

After reading the FCC regulations I believe this truly is a gray area. The only thing I have been able to pick up from the literature is I have to list that my device contains an FCC certified device, stay 20 cm away from it when not in use, and don't put near other antennas.

I enjoy being proved wrong though so please cite any specific regulations stating I can't throw a wifi-router into a larger box.
I really don't think you have a problem when integrating the complete device into an enclosure so long as you don't change anything internal to it.
 

drjohsmith

Joined Dec 13, 2021
852
The "problem" is
all the "marbles" are in the hands of the FCC

All we are doing is highlighting it is as you thought , a grey area , and the risk

I have seen companies that refuse to take the risk,
and provide a "ethernet" or "PCIe" connection and "recommend" a radio unit that they can "sell" with the unit they design.
and say that their unit is only tested with this radio gear ,

What I can also say , is selling to Jo public , seems you can get away with a lot,
selling to companies / contracts with companies , can get very litigatious...

If they are selling on the system, they might ask you for the FCC certification of your unit, or legal "guarantee/ indemnity" of compliance.

I full see your augments,
As I understand things,
in the eye of the FCC, is its down to the supplier to ensure compliance, either by self certification or by a EM lab .
at best , "I did my best" is a mitigation ,
 

MisterBill2

Joined Jan 23, 2018
18,996
I no longer intend to modify the WIFI module (and when I say module I mean the full consumer end product; think of a wifi router, or a cellphone, or a connectivity device.) We are no longer talking about a bare bones chip that needs soldered or glued down.

So imagine I put an FCC certified wifi router into a large industrial panel. Do I need to certify the large industrial panel? I would think not. Putting the FCC certified wifi router into a smaller box isn't going to change this scenario. Putting 10 wifi routers into the same industrial box might cause unintentional inteference though so I can't do that.

After reading the FCC regulations I believe this truly is a gray area. The only thing I have been able to pick up from the literature is I have to list that my device contains an FCC certified device, stay 20 cm away from it when not in use, and don't put near other antennas.

I enjoy being proved wrong though so please cite any specific regulations stating I can't throw a wifi-router into a larger box.
One simple thing would be to contact the manufacturer of that item and explain that you want to include their product as part of your product, and so how can you work out the details. If you purchase their product to include then there is no infringement. And you will probably get a lot of cooperation as well. Possibly even assistance.
 
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