ANR031
C ERTIFICATION OF CUSTOM
MODULESH OW TO GAIN THE CERTIFICATIONOF RADIO MODULES WITH CUSTOM
FIRMWARE ?

V ERSION 1.6
J UNE 5, 2024

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ANR031 - Certification of custom modules

Revision history
Manualversion

Notes

Date

1.0

• Initial version

July 2022

1.1• Added examples on permissive change class 1 documentsin chapter Example documents

September 2022

• Added examples on declaration of identity documents inchapter Example documents
1.2

1.3

• Updated compatible radio settings in chapter Radio
configuration• Added radio settings of Wirepas radio module Thetis-I tochapter Radio configuration

October 2022

March 2023

• Updated chapter Example documents

1.4• Improved description of label information and firmware
flashed by customer

July 2023• Updated Important notes, meta data and document style• Updated Important notes
1.5• Added products Stephano-I, Daphnis-I and Orthosie-I

March 2024

• Improved description
1.6• Added reference to Bluetooth® Mesh products

June 2024

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Abbreviations
Abbreviation Name

Description

BYOF

Build Your Own Firmware

Approach where the firmware of the radio
module is provided by the customer

CE

Conformité Européenne

European conformity, indicating that a
product is in conformity with Community
harmonisation legislation.

FCC

Federal Communications
Commission

Independent agency of the United Statesfederal government that regulates
communications by radio, television, wire,
satellite, and cable across the United States.

HVIN

Hardware Version
Identification Number

Number identifying the hardware used for
Canada certification

IC

Industry Canada

Government agency, IC is responsible for thecertification for electronic and electrical
products entering the Canadian market.

ISED

Innovation, Science andEconomic Development
CanadaSee IC.

TCB

Telecommunications
Certification Body

Consultant supporting the FCC certification

TELEC

Telecom Engineering Center

Organization for Japanese radio equipment
certification and testing.

UKCA

United Kingdom Conformity
Assessed

Certification mark that indicates conformity
with the applicable requirements for products
sold within Great Britain.

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Contents
1 Introduction

4

2 How to gain the radio certification?
5
2.1
Firmware developed by Würth Elektronik eiSos . . . . . . . . . . . . . . . . . . 6
2.1.1 European Declaration of Conformity / CE . . . . . . . . . . . . . . . . . 6
2.1.2 United Kingdoms Declaration of Conformity / UKCA . . . . . . . . . . . 6
2.1.3 FCC Certification (USA) . . . . . . . . . . . . . . . . . . . . . . . . . . 6
2.1.4 Technical Acceptance Certificate ISED (Canada) . . . . . . . . . . . . 6
2.1.5 TELEC Certification (Japan) . . . . . . . . . . . . . . . . . . . . . . . . 7
2.1.6 Get the Bluetooth listing . . . . . . . . . . . . . . . . . . . . . . . . . . 7
2.2
Firmware developed by customer (e.g. BYOF) . . . . . . . . . . . . . . . . . . . 8
2.2.1 European Declaration of Conformity / CE . . . . . . . . . . . . . . . . . 8
2.2.2 United Kingdoms Declaration of Conformity / UKCA . . . . . . . . . . . 8
2.2.3 FCC Certification (USA) . . . . . . . . . . . . . . . . . . . . . . . . . . 8
2.2.4 Technical Acceptance certificate ISED (Canada) . . . . . . . . . . . . . 9
2.2.5 Get the TELEC (Japan) . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
2.2.6 Get the Bluetooth listing . . . . . . . . . . . . . . . . . . . . . . . . . . 9
2.3Radio configuration . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
3 Labelling of custom radio modules

13

4 Example documents

14

5 References18

6 Important notes

19

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1 Introduction
Würth Elektronik eiSos provides various certified radio modules enabling the radio data transmission in numerous radio frequency bands and radio standards. The radio modules are designed in a way that the mode of operation can be configured via external host micro controller
to meet best the requirements of the underlying application.
Nevertheless, there are still cases where an adoption or complete change of the firmware
is needed, like:• Integration of application code into the module for standalone operation.
• Enabling new interfaces like I2 C or PWM for external component connection.
• Adjusting the performance and low power capabilities for the underlying application.
Due to the change in firmware the radio certification of the adopted radio module must be verified again.
This application note describes in which cases the certification of an adapted radio module
can be inherited/derived from the certification of the Würth Elektronik eiSos standard productwithout the need of repeating the certification tests.

Please note that the certification of the end device, that integrates the radio
module, will not be considered in this application note.

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2 How to gain the radio certification?
There are mainly two cases of customized firmware:
1. Firmware that has been developed by Würth Elektronik eiSos (see section 2.1).
2. Firmware that has been developed by customer (see section 2.2). This targets firmwarea) that is provided by a customer and Würth Elektronik eiSos just brings it on the radio
module hardware during device production as a service (see section 2.2).
b) that is flashed on the radio module by customer itself.

Figure 1: A product and its certification consist of hardware and firmware parts

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2.1 Firmware developed by Würth Elektronik eiSos
In case the firmware has been created by Würth Elektronik eiSos, Würth Elektronik eiSos
ensures during the development process that the radio behavior of the new product will be kept
conform to the radio tests done during certification of the standard product.
In most cases, this allows to derive the radio certification of the new radio module from thestandard module. What this means for the individual certifications is shown in the following sub
chapters.
In case firmware adaptions are really needed that change the radio behavior,
Würth Elektronik eiSos will closely work with the customer to create a new or
update an existing certification. These cases are not considered in this chapter.

2.1.1 European Declaration of Conformity / CE
On base of the test reports of the standard product, Würth Elektronik eiSos can self declarethe conformity of the new product for CE. For proper documentation Würth Elektronik eiSos
sets up a "Declaration of Identity" document stating that the product variant is identically interms of radio parameters. With this, the conformity of the new product is proven and the same
Declaration of Conformity is valid.
2.1.2 United Kingdoms Declaration of Conformity / UKCA
UKCA works with designated EU standards. Therefore the UKCA declaration is based on
the EU test reports. On base of the test reports of the standard product, the UK representative
can self declare the conformity of the new product for UKCA. For proper documentation Würth
Elektronik eiSos sets up a "Declaration of Identity" document stating that the product variant is
identically in terms of radio parameters. With this, the conformity of the new product is provenand the same Declaration of Conformity is valid.
2.1.3 FCC Certification (USA)On base of the FCC ID of the standard product, Würth Elektronik eiSos can internally1 run a"Permissive Change Class 1" process. To properly document this approach Würth Elektronik
eiSos sets up a "Declaration of Identity" document stating that the product variant is identicallyin terms of radio parameters (see chapter 4 for an example). With this, the conformity of the
new product is proven and the same FCC ID is valid.
2.1.4 Technical Acceptance Certificate ISED (Canada)
See chapter FCC Certification (USA). Instead of the FFC ID, the IC uses the ISED number
to identify the product. Special care must be taken that the marketing name and HVIN is notchanged.
1

No official filing at FCC is needed to run "Permissive Change Class 1" process.

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2.1.5 TELEC Certification (Japan)
For Japan some official filing is required. To receive the TELEC certification for the new product, Würth Elektronik eiSos sets up a "Declaration of Identity" document that is placed at theJapanese authority by an assigned test house (operating as Conformity Assessment Body).
This will be done only on request of the customer and will generate additional costs.
2.1.6 Get the Bluetooth listing
If the module uses Bluetooth® technology, a Bluetooth® listing is required. The module itself
can be added to the listing of the standard product as long as the used Bluetooth® stack uses
the same qualified sub-components.

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ANR031 - Certification of custom modules

2.2 Firmware developed by customer (e.g. BYOF)
This chapter applies to the BYOF approach of Würth Elektronik eiSos, where customer provides the firmware for flashing by Würth Elektronik eiSos, as well as to the case that customer
is flashing the firmware in his production line.
In general it is not possible to reference the certificates or tests of the original product. The
exception is custom firmware that does not change the radio behavior w.r.t. original product. In
that case it is possible to reference to the original certificates and test reports, though.
Thus products with standardized radio protocols (e.g. Bluetooth® ) are suited for the development of radio equivalent custom firmware. Chapter 2.3 summarizes the information whichradio modules of Würth Elektronik eiSos can be used for radio equivalent custom firmware, andhow their radio must be configured to match the radio behavior of the original product. How theindividual certification then can be created is shown in the following sub chapters.
2.2.1 European Declaration of Conformity / CE
In case the new product has the same radio behavior as the original product, the customer
can declare the radio conformity of the new product with help of the test reports of the original
product (see figure 4 for example). Templates are available on request1 .
2.2.2 United Kingdoms Declaration of Conformity / UKCA
See chapter European Declaration of Conformity / CE. Instead of the CE marking the UKCA
marking is used.
2.2.3 FCC Certification (USA)In case the new product has the same radio behavior as the original product, the customer can
run a "Permissive Change Class 1" process to document the conformity of the new product.

Figure 2: Official statement of the FCC
To do so, it is essential to perform an internal documentation that the changes do not degrade
the characteristic reported. Official filing2 is not required.
Würth Elektronik eiSos’s form of documentation is a self declaration (see figure 6 for example).
12

Please use your direct contact or WCS@we-online.com for further information.
Official filing means documents that must be provided to FCC for approval.

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Templates are available on request1 .
With this, the old FCC ID is still valid and can be used in the end device.
2.2.4 Technical Acceptance certificate ISED (Canada)
See chapter FCC Certification (USA). In analogy to the FCC ID, the IC uses the ISED number to identify the product.
2.2.5 Get the TELEC (Japan)
The certification for Japan does not allow any sort of inheritance from an already existingcertification of another manufacturer. Thus a full certification process must be run.
2.2.6 Get the Bluetooth listing
If the module uses Bluetooth® technology, a Bluetooth® listing is required. In case of a custom
firmware, a new listing is required already on module level. When the listing of the new module
has been done, it is also possible to add the end product to this listing for free.
A Bluetooth® listing can be created out of the Bluetooth® listing of the utilized Bluetooth® stackand the Bluetooth® listing of the underlying radio chip. Please refer to application note ANR027 [1]for details on the listing process of the new radio module.

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2.3 Radio configuration
As described in the previous chapters, customers that develop their own firmware must attest
Würth Elektronik eiSos that the new firmware is compliant with the respective regulatory radio
laws. To prove that, the most convenient way is to use the same radio stack and configurationas used in the standard product of Würth Elektronik eiSos. This shows that custom firmware
is radio identical with the Würth Elektronik eiSos original product. The following products ofWürth Elektronik eiSos are suited for radio equivalent firmware development, in case the corresponding radio configuration is used:
Product

Adrastea-I

Radio configuration• Using stack ALT1250_03_00_00_00_11952_FW for LTE-M• Using stack ALT1250_03_00_00_00_11951_NB for NB-IoT

Calypso• Using SimpleLink SDK version 5.20.00.06 and NWP version 3.20.0.1• Using the LoRa radio of the STM32WLE5CCU6 chipset
Daphnis-I• Using STM32CubeWL SDK version 1.3.0 (including LoRaMac-nodeversion 4.6.0)• Using regional parameters 2-1.0.1 with TX power index 7 or lower• Using Bluetooth® LE radio of the nRF52805 (Bluetooth® LE or
Bluetooth® Mesh)• Using 1 MBit or 2 MBit phy
Proteus-e,
Ophelia-I• Output power register of the radio chip set to maximum 4 dBm• Maximum duty cycle of 25 %• Use Bluetooth® LE stack Nordic Semiconductor S112 inversion 7.3.01 or nRFConnect SDK [2]

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ANR031 - Certification of custom modules• Using Bluetooth® LE radio of the nRF52832 (Bluetooth® LE or
Bluetooth® Mesh)
Proteus-I• Using 1 MBit phy• Output power register of the radio chip set to maximum 4 dBm• Using Bluetooth® LE stack Nordic Semiconductor S132
Version 3.1.01 or nRFConnect SDK [2]• Using Bluetooth® LE radio of the nRF52832 (Bluetooth® LE or
Bluetooth® Mesh)
Proteus-II• Using 1 MBit or 2 MBit phy• Output power register of the radio chip set to maximum 4 dBm• Using Bluetooth® LE stack Nordic Semiconductor S132
Version 6.0.01 or nRFConnect SDK [2]Proteus-III,
Proteus-IIISPI,
Setebos-I,
Ophelia-III• Using Bluetooth® LE radio of the nRF52840 (Bluetooth® LE or
Bluetooth® Mesh)• Using 1 MBit, 2 MBit or LE-Coded phy• Output power register of the radio chip set to maximum 8 dBm• Using Bluetooth® LE stack Nordic Semiconductor S140
Version 7.0.11 or nRFConnect SDK [2]

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ANR031 - Certification of custom modules• Using Bluetooth® LE radio of the ESP32-C3 (Bluetooth® LE or
Bluetooth® Mesh)– Using Bluetooth® LE modes 1 MBit, 2 MBit or LE-Coded phy– Bluetooth® LE output power index 12 or 13 or smaller(depending on country, see Stephano-I user manual [3])Stephano-I,
Orthosie-I– Using Espressif ESP-IDF stack 5.0 or newer• Using WiFi radio of the ESP32-C3– Using WiFi modes 802.11b/g/n– WiFi output power index 74 or 80 or smaller (depending on
country, see Stephano-I user manual [3])– Using Espressif ESP-IDF stack 5.0 or newer• Output power register of the radio chip set to maximum 8 dBm
Thetis-I• Using 1 MBit phy• Using Wirepas Mesh Stack Version 5.x for Nordic Semiconductor
nRF52840

Table 1: Radio configuration

1

Newer versions of the corresponding Nordic Semiconductor Sxxx Bluetooth® stack can be also used.

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ANR031 - Certification of custom modules

3 Labelling of custom radio modules
For production and sale of radio modules, the label must contain the respective radio certification information. This may include the CE logo as well as the FCC ID and others.
When bringing a new custom firmware on the radio module hardware, the product has changed
and thus the label information must be updated as well. In that case the existing label of theoriginal product must be removed and replaced by a new label containing all certification relevant information of the new product.

Changing the firmware without updating and correcting the label information
voids the certification of the product.

In case the firmware has been developed by Würth Elektronik eiSos, Würth Elektronik eiSos
will take care of the correctness of the label information.
In case customer is flashing the firmware, he must take care of the correctness of the label
information.
In case Würth Elektronik eiSos brings a firmware developed by customer on the radio module hardware, the needed label information (CE declaration, FCC ID, ...) and the evidence2
that the product conforms with the dedicated national radio regulations must be provided to
Würth Elektronik eiSos before any device production may start.
Please refer to the user manual of the standard radio module, chapter "General labelling information", to check which information can be placed on the module label.

Figure 3: (Example) Proteus-III label containing the CE logo and the FCC ID R7T1101102

2

See chapter 2.2 how certification can be inherited from original product.

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ANR031 - Certification of custom modules

4 Example documents

Add your company header (name and logo) here

Internal documentation in case that no official filling is needed

DECLARATION OF IDENTITY RED
new product nameWe declare that the radio device
new product nameis equivalent regarding all radio equipment directive aspects, as there are for radio
spectrum, electromagnetic compatibility and safety aspects, to the product:reference product nameDue to the proven conformity of reference product name toname here the EN norms the reference product is conform to(can be found in the declaration of conformity chapter in the product’s user
manual)the new product complies to these standards alike.
Both, the new product and reference product, are electrical identical using the same chipsets, circuits, PCB and shielding. The firmware uses the same tested radio profiles as thereference product.

Monday, March 20, 2023

Internal documentation

Figure 4: Example RED Declaration of Identity1

Templates are available on request. Please use your direct contact or WCS@we-online.com for further information.

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ANR031 - Certification of custom modules

Add your company header (name and logo) here

Internal documentation in case that no official filling is needed

DECLARATION OF IDENTITY UKCA
new product nameWe declare that the radio device
new product nameis equivalent regarding all radio equipment directive aspects, as there are for radio
spectrum, electromagnetic compatibility and safety aspects, to the product:reference product nameDue to the proven conformity of reference product name toname here the UKCA norms the reference product is conform to(can be found in the declaration of conformity chapter in the product’s user
manual)the new product complies to these standards alike.
Both, the new product and reference product, are electrical identical using the same chipsets, circuits, PCB and shielding. The firmware uses the same tested radio profiles as thereference product.

Monday, March 20, 2023

Internal documentation

Figure 5: Example UKCA Declaration of Identity1

Templates are available on request. Please use your direct contact or WCS@we-online.com for further information.

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ANR031 - Certification of custom modules

Add your company header (name and logo) here

Internal documentation in case that no official filling is needed

DECLARATION OF IDENTITY FCC
new product nameWe declare that the product version

new product nameradio equivalent to the product version

reference product nameand thus inherits its FCCID

FCCID of the reference product (R7T….)

Both, the new product name and reference product name, are electrical equivalent anduse the same hardware and radio settings. As this modification does not degrade thecharacteristics it is rated as class I permissive change with no official filing needed.

Monday, March 20, 2023

Internal documentation

Figure 6: Example FCC Permissive change class 1 document stating radio identity1

Templates are available on request. Please use your direct contact or WCS@we-online.com for further information.

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ANR031 - Certification of custom modules

Add your company header (name and logo) here

Internal documentation in case that no official filling is needed

DECLARATION OF IDENTITY IC
new product nameWe declare that the product version

HVIN

PMN

UPN

FVIN

new HVIN

new PMN

new UPN

new FVIN

radio equivalent to the product version

HVIN

PMN

UPN

FVIN

reference HVIN

reference PMN

reference UPN

reference FVIN

and thus inherits its ISEDISED number of the reference product (5136A-…)

Both versions are electrical equivalent and use the same hardware and radio settings. As
this modification does not degrade the characteristics it is rated as class I permissivechange with no official filing needed.

Monday, March 20, 2023

Internal documentation

Figure 7: Example IC Permissive change class 1 document stating radio identity1

Templates are available on request. Please use your direct contact or WCS@we-online.com for further information.

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5 References[1] Würth Elektronik. Application note 27 - Bluetooth listing guide. http://www.we-online.
com/ANR027.
[2] Nordic Semiconductor. nRF Connect SDK.
Development-software/nRF-Connect-SDK.

https://www.nordicsemi.com/Products/[3] Würth Elektronik. Stephano-I user manual.
manual/2617011025000.

https://www.we-online.de/katalog/de/

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6 Important notes
The Application Note and its containing information ("Information") is based on Würth Elektronik eiSos GmbH & Co. KG and its subsidiaries
and affiliates ("WE eiSos") knowledge and experience of typical requirements concerning these areas. It serves as general guidance and shallnot be construed as a commitment for the suitability for customer applications by WE eiSos. While WE eiSos has used reasonable efforts toensure the accuracy of the Information, WE eiSos does not guarantee that the Information is error-free, nor makes any other representation,
warranty or guarantee that the Information is completely accurate or up-to-date. The Information is subject to change without notice. To
the extent permitted by law, the Information shall not be reproduced or copied without WE eiSos’ prior written permission. In any case, theInformation, in full or in parts, may not be altered, falsified or distorted nor be used for any unauthorized purpose.

WE eiSos is not liable for application assistance of any kind. Customer may use WE eiSos’ assistance and product recommendations forcustomer’s applications and design. No oral or written Information given by WE eiSos or its distributors, agents or employees will operate
to create any warranty or guarantee or vary any official documentation of the product e.g. data sheets and user manuals towards customer
and customer shall not rely on any provided Information. THE INFORMATION IS PROVIDED "AS IS". CUSTOMER ACKNOWLEDGESTHAT WE EISOS MAKES NO REPRESENTATIONS AND WARRANTIES OF ANY KIND RELATED TO, BUT NOT LIMITED TO THE NONINFRINGEMENT OF THIRD PARTIES’ INTELLECTUAL PROPERTY RIGHTS OR THE MERCHANTABILITY OR FITNESS FOR A PURPOSEOR USAGE. WE EISOS DOES NOT WARRANT OR REPRESENT THAT ANY LICENSE, EITHER EXPRESS OR IMPLIED, IS GRANTEDUNDER ANY PATENT RIGHT, COPYRIGHT, MASK WORK RIGHT, OR OTHER INTELLECTUAL PROPERTY RIGHT RELATING TO ANYCOMBINATION, MACHINE, OR PROCESS IN WHICH WE EISOS INFORMATION IS USED. INFORMATION PUBLISHED BY WE EISOSREGARDING THIRD-PARTY PRODUCTS OR SERVICES DOES NOT CONSTITUTE A LICENSE FROM WE eiSos TO USE SUCH PRODUCTS OR SERVICES OR A WARRANTY OR ENDORSEMENT THEREOF.
The responsibility for the applicability and use of WE eiSos’ components in a particular customer design is always solely within the authority of the customer. Due to this fact it is up to the customer to evaluate and investigate, where appropriate, and decide whether the device
with the specific characteristics described in the specification is valid and suitable for the respective customer application or not. The technicalspecifications are stated in the current data sheet and user manual of the component. Therefore the customers shall use the data sheets anduser manuals and are cautioned to verify that they are current. The data sheets and user manuals can be downloaded at www.we-online.com.
Customers shall strictly observe any product-specific notes, cautions and warnings. WE eiSos reserves the right to make corrections, modifications, enhancements, improvements, and other changes to its products and services at any time without notice.
WE eiSos will in no case be liable for customer’s use, or the results of the use, of the components or any accompanying written materials. IT IS CUSTOMER’S RESPONSIBILITY TO VERIFY THE RESULTS OF THE USE OF THIS INFORMATION IN IT’S OWN PARTICULAR
ENGINEERING AND PRODUCT ENVIRONMENT AND CUSTOMER ASSUMES THE ENTIRE RISK OF DOING SO OR FAILING TO DO SO.
IN NO CASE WILL WE EISOS BE LIABLE FOR CUSTOMER’S USE, OR THE RESULTS OF IT’S USE OF THE COMPONENTS OR ANY
ACCOMPANYING WRITTEN MATERIAL IF CUSTOMER TRANSLATES, ALTERS, ARRANGES, TRANSFORMS, OR OTHERWISE MODIFIES THE INFORMATION IN ANY WAY, SHAPE OR FORM.
If customer determines that the components are valid and suitable for a particular design and wants to order the corresponding components, customer acknowledges to minimize the risk of loss and harm to individuals and bears the risk for failure leading to personal injury
or death due to customers usage of the components. The components have been designed and developed for usage in general electronicequipment only. The components are not authorized for use in equipment where a higher safety standard and reliability standard is especiallyrequired or where a failure of the components is reasonably expected to cause severe personal injury or death, unless WE eiSos and customer
have executed an agreement specifically governing such use. Moreover WE eiSos components are neither designed nor intended for use
in areas such as military, aerospace, aviation, nuclear control, submarine, transportation, transportation signal, disaster prevention, medical,
public information network etc. WE eiSos must be informed about the intent of such usage before the design-in stage. In addition, sufficientreliability evaluation checks for safety must be performed on every component which is used in electrical circuits that require high safety andreliability functions or performance. COSTUMER SHALL INDEMNIFY WE EISOS AGAINST ANY DAMAGES ARISING OUT OF THE USE
OF THE COMPONENTS IN SUCH SAFETY-CRITICAL APPLICATIONS.

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List of Figures
1
2
3
4
5
6
7

A product and its certification consist of hardware and firmware parts . . . . . . .
Official statement of the FCC . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
(Example) Proteus-III label containing the CE logo and the FCC ID R7T1101102
Example RED Declaration of Identity . . . . . . . . . . . . . . . . . . . . . . . . .
Example UKCA Declaration of Identity . . . . . . . . . . . . . . . . . . . . . . . .
Example FCC Permissive change class 1 document stating radio identity . . . .
Example IC Permissive change class 1 document stating radio identity . . . . . .

5
8
13
14
15
16
17

List of Tables
1

Radio configuration . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12

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Contact
Würth Elektronik eiSos GmbH & Co. KG
Division Wireless Connectivity & Sensors
Max-Eyth-Straße 174638 Waldenburg
Germany
Tel.: +49 651 99355-0
Fax.: +49 651 99355-69
www.we-online.com/wireless-connectivity