Can you reuse FCC certification from a pre-certified RF chip and antenna for a new product?

Question

I am in the process of designing a board that turns a Gameboy into a Bluetooth controller. Due to size constraints, I would like to use the ESP32-PICO-D4 standalone chip by Espressif instead of one of the larger modules that has an integrated PCB antenna like the ESP32-WROOM-32. In Espressif's dev kit for this chip, they use a 3D chip antenna as shown in this image of the board.
_{(source: readthedocs.io)}

This antenna is the PRO-OB-440 by ProAnt AB as shown on their page here and the Digi-Key product page here.

As I would like to eventually sell this product, I know that there are certification requirements that should be taken into consideration. After reading up on this through the FCC's Title 47 CFR Part 15 under Subpart C - Intentional Radiators as well as an article from EMC FastPass about pre-certified RF modules, I saw that they were wanting to cut down on the number of products that needed certification by encouraging the re-use of pre-certified modules.

If I was to use the same chip and antenna together, would this pre-certification for the dev kit carry over to my product?

Note: The dev kit's certification documents can be found here.

(Also, I feel that my question is different from this one as that board uses an integrated PCB antenna while my question focuses on an RF chip combined with a surface mount antenna.)

Answer 1

Google "pre-certified chip" and you get a few dozen results, mostly for chip-and-pin payment. An RF chip is not so much pre-certified as tested by the manufacturer to verify that it is capable of meeting certification requirements when paired with the right antenna. A "pre-certified module" will usually have a shielding package that adds to the size, and that also reassures regulators by making it harder to modify the module after purchase. The same combination of chip and antenna could produce different results depending on connections, orientation, PCB parameters and routing, and if the agencies did not require such changes verified, no one would be selling the modules.

Yes, the module costs more and constrains your design. Below 10,000 units, it is still worthwhile, just to avoid months of delay and many thousands for testing. Any decent module is generally certified in multiple jurisdictions, giving you future flexibility, instead of needing a lab to test separately for each of those.

Many regulators have some form of Declaration of Conformity self-approval program; you are likely to need at least the paperwork for that even with a pre-certified module.