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Publication Number: 685804 Rule Parts:  Publication Date: 04/09/2007
Keyword: 2.953,2.1073, 2.1043, No lead NOPb, RoHS directive

First Category: Administrative Requirements
Second Category: Equipment Authorization Process

Question:   What are the FCC requirements when a device is updated to comply with the European RoHS directive (also referred to as NOPb requirement)?

Answer:   The FCC does not regulate the No lead NOPb, RoHS directive. However, updating a device to comply with the European RoHS directive may change the RF characteristics of the original equipment tested for equipment authorization and therefore current rules and policies for responsibility for compliance for Verification (2.953), Declaration of Conformity (2.1073), or Changes in certified equipment (2.1043) apply.
RF safety requirements must be also considered. For fixed and mobile devices, there should not be any evaluation and filing requirements.  For portable devices, a SAR re-evaluation is required. A Class II permissive change is required if SAR tests show an increase in levels. A Class I is needed if the SAR tests show a decrease in levels. 


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