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nrf52 NFC tap to pair and the FCC

Hi all,

I have a customer that has requested NRC tap to pair functionality for their device, mostly for convenience. This is fine, but I'd like to know what they're getting into in terms of FCC certification of the whole device. We're using a pre-certified module with built in antenna for the BLE connection, though I know we'll still have to go through FCC unintentional transmitter testing. But I wasn't sure if there's additional FCC testing required specifically due to including the NFC antenna. 

This question is purely about FCC certification, not for the NFC forum nor any other regulatory agencies. 

Normally you don't have to certify passive NFC/RFID tags because they don't radiate energy. The NFC peripheral on the nRF52 has both RX and TX buffers, and I don't know if it acts as a passive or an active tag during its tap to pair mode. Is this an active tag? Is testing required for active tags? The example project documentation isn't really clear about this, so I'd appreciate the insight of someone who knows. 

Nathan

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