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PTCRB process for device incorporating the nRF9160

I am familiar with the PTCRB certification process for an IoT device incorporating a certified module. https://www.ptcrb.com/wp-content/uploads/2020/08/10_Steps_to_PTCRB_Cert_for_Cell_Enabled_IoT_Devices.pdf. In our previous devices, we have a separate microcontroller running our code and the PTCRB certification for the end device controls the firmware version on that microcontroller. How does this work when using the nRF9160 where the firmware is running on the module? Does the certification process become more complicated, or does a user of the module just submit the application firmware version running on the nRF9160 as the end device firmware version?

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