Federal Communications Commission Pre-Approval Guidance List

Federal Communications Commission Office of Engineering and Technology Laboratory Division has released a pre-approval guidance list on March 19th, 2021.

The requirements for the Telecommunications Certification Body (TCB) program, the Commission stated that while it intended to allow TCBs to certify a broad range of equipment, certain functions should continue to be performed by the Commission. To certify certain types of equipment for which the Commission has not yet established specific guidelines, where a new technology or new rule part is integral, where there is an obligation by the Commission to approve an authorization, or where there is a need to provide case-by-case guidance, the Commission has adopted the Pre-Approval Guidance (PAG) procedure.


There are three classes of applications for equipment authorization subject to a PAG review, prior to approval by a TCB:

Devices subject to special conditions where the authorization procedures to be used must be approved by the FCC prior to approval by a TCB:

  • RF exposure limits are not fully established or when the FCC has determined that Sections 1.1307 (c) or (d) applies.
  • When Section 2.1091(d)(4) of the FCC rules applies, and SAR or MPE (above 6 GHz) evaluation is required, except when related to a C2PC in U-NII Bands 5.925-7.125 GHz for an already certified module addressing RF exposure conditions for a specific host(s).
  • RF exposure evaluations using numerical simulations or computational modeling techniques.
  • Portable transmitters operating at frequencies below 100 MHz and SAR evaluation is required per published RF exposure KDB procedures; or portable transmitters operating at frequencies above 6 GHz and routine RF exposure evaluation is required.
  • Portable transmitters operating with source-based, time-averaged maximum output power according to wireless network or infrastructure requirements and separation distance requirements exceeding the “SAR Exclusion Threshold” in KDB Publication 447498 by either: (a) 8 times or more, for compliance with general population exposure requirements; or (b) 20 times or more, for compliance with occupational exposure requirements; and, when published RF exposure KDB procedures are not established for SAR testing or when SAR data is not provided to support compliance.
  • Mobile and portable devices incorporating mechanisms to actively control the output power, transmission intervals, transmission durations, transmission duty factors or other relevant parameters in a dynamic or non-systematic manner to mitigate the potential of RF exposure according to time-averaging considerations that may or may not contain a source-based time- averaged equivalent component to determine RF exposure compliance.
  • Devices for which a sample must be submitted to the FCC for pre-approval testing prior to approval by a TCB:

    • Unlicensed National Information Infrastructure (U-NII) devices with Dynamic Frequency Selection (DFS) capability (Part 15 Subpart E), including client devices operating in the DFS bands that have radar detection capability.
    • Devices for which there are new or unique operation or installation issues which are subject to FCC review prior to approval by a TCB:

      RF Exposure Evaluation

      • When SAR measurement is required, for all Time-Division Duplex (TDD) implementations, except when guidance is available in the published RF exposure KDB procedures
      • When simultaneous transmission SAR measurement is required (see enlarged zoom scan measurement and volume scan post-processing in KDB Publication 865664 D01). Regardless of SAR test exclusion or measurement requirements, when the simultaneously transmitted signals are coherent.
      • When the published RF exposure KDB procedures do not readily support the form factor, design or implementation of a product or exposure condition, or when non-standard phantom configurations or test procedures are used for SAR testing. Devices requiring, or tested with, a phantom or test configurations that are not specified in the published RF exposure KDB procedures. For example, when a flat phantom is not used for testing extremity SAR in hands, wrists, feet or ankles or when the SAM phantom or other specific phantoms (described in IEEE/IEC SAR measurement standards) is used for testing other exposure conditions, such as wrist-worn, head-worn devices or other use conditions that may require field reconstruction techniques or non-standard post-processing procedures to determine the 1-g SAR.
      • When SAR test reduction is applied not in accordance with KDB Publication 643646 to occupational handheld push-to-talk (PTT) radios, or when KDB Publication 643646 is applied and the highest reported SAR is > 6.0 W/kg.
      • When published RF exposure KDB procedures are not available or applicable for testing any uplink MIMO or transmit antenna diversity configurations, including all 3G/4G/5G technologies.
      • When dynamic antenna tuning is applied to optimize transmission efficiency for wide range frequency operations or other operating requirements
      • When a power reduction feature is used to reduce the transmit power; except: (i) when the power reduction is implemented using a single fixed level of reduction through static table look-up for all exposure test configurations in a single wireless operating mode of a frequency band and it is triggered by a single event or operation; or (ii) when simultaneous transmission requires power reduction and it is not implemented for satisfying SAR compliance requirements, where simultaneous transmission SAR test exclusion is applied according to the reported standalone SAR tested at the maximum output power level without any power reduction.
      • When power increase feature is applied to selectively boost the maximum conducted output power in specific wireless modes or operating configurations without exceeding the maximum output (e.g., radiated output, allowed by the equipment certification).
      • When proximity, device tilt, movement detection or other sensing features are used to reduce the transmit power; except when published RF exposure KDB procedures are applicable to the specific implementation and applied for testing (e.g., KDB Publication 616217)
      • When a low duty factor analysis report is required to qualify for SAR test exclusion or reduction without a prior KDB inquiry confirming acceptance of the analysis.
      • When published RF exposure KDB procedures are not applicable for mobile and portable devices designed to transmit simultaneously using multiple channels in single or multiple frequency bands, or transmit using “carrier aggregation techniques” for contiguous or non-contiguous channels. For example, devices using these techniques in 3GPP or 3GPP2 operations, or not in accordance with IEEE Std 802.11ac-2013 or KDB Publication 248227.
      • Technologies operating with wide channel bandwidths or transmission bands where the SAR probe calibration and tissue-equivalent dielectric medium may not fully support such wide band measurements or when specific KDB procedures are not applicable (e.g. IEEE Std 802.11ac-2013 in KDB Publication 248227)
      • Whensensor-arrayandvectormeasurement-basedSARsystemsareusedfortestingwireless technologies, products, exposure configurations or other conditions where KDB guidance are unavailable or insufficient
      • Wireless power transfer (WPT) applications, except for those applications that meet the established criteria in KDB Publication 680106 D01.

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