Conformity Assessment for Finished Products Incorporating Certified Wireless Modules: Test Report Omissions and Requirements Released

Regarding your inquiry on whether test reports for pre-certified wireless transmitter/receiver modules can be omitted during the conformity assessment of a finished product, as well as the necessity for additional Electromagnetic Compatibility (EMC) or Specific Absorption Rate (SAR) reports, please find the detailed professional guidance below.

Omission of Wireless Performance Test Reports

If your finished product incorporates a wireless module that has already obtained a Certification of Conformity, you may indeed omit the submission of test reports and supporting documents for the specific test items (e.g., frequency, power output, and other wireless performance metrics) that were covered during the module's original certification. This provision is designed to reduce the burden of redundant testing, recognizing that the wireless module independently satisfies the technical standards set by the National Radio Research Agency (RRA).

Necessity of Finished Product Conformity Assessment

It is crucial to understand that the certification of a component does not exempt the entire finished product from conformity assessment. The integration of a wireless module into a final product involves various factors—such as peripheral circuitry, housing, and power supplies—that may create new electromagnetic interactions not present in the standalone module. Therefore, the following test reports are mandatory for the finished product:

• Electromagnetic Compatibility (EMC) Test Report: Even with a certified wireless module, the finished product's overall configuration can affect electromagnetic emissions and immunity. You must submit a test report proving that the entire device, with all components integrated, complies with domestic EMC standards to prevent malfunctions and interference with other devices.
• Specific Absorption Rate (SAR) Test Report: If the finished product is intended to be used in close proximity to the human body (e.g., smartphones, tablets, wearables, or certain IoT devices), a SAR test report is mandatory. SAR measures the rate at which energy is absorbed by the human body when exposed to a radio frequency (RF) electromagnetic field. This is a critical safety requirement separate from the module's functional performance.

Customs Clearance and Regulatory Compliance

From the perspective of import customs clearance, products that have not successfully completed the required conformity assessments may be subject to clearance delays or may be prohibited from entering the domestic market. The KC Mark and the corresponding Conformity Assessment Certificate are essential prerequisites for domestic distribution, serving as key indicators of product safety and reliability.

Professional Conclusion

In conclusion, while you can omit the wireless performance test reports for the pre-certified module, you must still conduct and submit EMC and (if applicable) SAR test reports for the finished product itself. We strongly recommend collaborating with accredited testing laboratories and certification consultants from the early stages of product development to ensure all regulatory requirements are met, thereby preventing unnecessary costs and ensuring a smooth market launch.