We have pre-production product (based similar to the NRF9160dk setup with a NRF9160 (LTE-M, GPS) and a bridged NRF52840 (BLE). We are working through certifications for CSA, CE, FCC etc...
One big sticking point is this line in the FCC certification for the NRF9160:
"The antenna of this transmitter must provide a separation distance of at least 20 cm from all persons. Installers and end-users must be provided with antenna installation instructions and transmitter operating conditions and instructions for satisfying RF exposure compliance."
While our product is normally not near any humans while operating, there is essentially no reasonable way to ensure a human could never come within 20cm of the antenna if they wished to. We cannot put a 20cm radius protective dome around the antenna.
We were recommended to check out "end-device" modules but all of the devices we have seen so far re-use the Nordic FCC ID and maintain the same 20cm stipulation. We have considered SAR testing but this seems like an extensive testing and may require assistance/participation from Nordic Semi to actually complete it.
I'm not understanding what the end-devices actually solve towards certifications since we would still need to do unintentional radiation FCC testing once we attach it to our boards or make any modifications to our underlying boards.
We only transmit every few minutes and can provide instructions and warnings to not use the device while the antenna is activated but otherwise I do not see how we can reasonable resolve this.
We are really stuck on this and trying to understand what options we have.
Best regards
