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I've designed a product that utilizes a Raytac MDBT50Q-P1MV2 'pre-certified' MCU+Bluetooth module (based on Nordic nRF52840) and am now considering what it would take for me to legally sell such a product in the US.

It seems the two obvious hurdles are FCC and Bluetooth and I believe (hope) that utilizing the Raytac modules instead of the nRF52840 series directly have given me a leg up there. I've also intentionally chosen the integrated antenna module to avoid undoing any of those certifications. Here's what I believe the 'pre-certified' module buys me (see pages 49 onward):

  • BT 5.1 / BT 5.2 Declaration ID's (is this even needed for BLE?)
  • FCC Certification for BLE (IEEE 802.15.4)

I've read some conflicting information, but I believe the truth is even with an integrated antenna on a pre-certified module I still need my own FCC Part 15B EMC testing. That seems to agree with this Raytac blog-post (generalized for all their modules) I found. I will be reaching out to some testing laboratories and hope they will give me guidance here.

Where things are really murky is the Bluetooth 'Certification'. The Raytac modules themselves already have DID and QDID's, but Raytac's blog makes it sound like I need my own DID. And notably the DID topics are relevant to BT 5.2 and BT 5.1, but I am only using BLE functionality. Is it right that I would need to join Bluetooth's SIG membership (free?), purchase a DID (not free!), then activate my DID with Raytac's QDID (maybe free?). Is this process necessary for BLE? Does it involve testing? Any idea what purchasing your own DID costs?

Additional background on the product for context:

  • BLE device adhering to both FTMS (Fitness Machine Service) and CSC (Cycling Speed Cadence) profiles
  • An rs485 transceiver
  • A 3.5" TFT display
  • A 12v to 5v switching regulator for a 3A USB fast-charging interface (Type A)
    • I'm tempted to drop this all together and use only a LDO regulator for 3.3v for the module if it complicates testing/certification
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  • \$\begingroup\$ Still digging, but I think this page explains the fees related to an "End Product Listing". I think I'd need to pay $9,600 then $120 for each additional profile? And that doesn't explain the testing. \$\endgroup\$
    – DrTarr
    Dec 11, 2022 at 21:54
  • \$\begingroup\$ did you ever bring this product to the market? I am considering a similar path of bringing a product to the market with a pre-certified Bluetooth module and wanted to see if you did go through these steps and what overall costs you occurred compared to your estimate here. \$\endgroup\$ Oct 20, 2023 at 13:31

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After talking to some industry experts I've found that using the pre-certified module above would still require:

  • FCC Part 15b testing (unintentional radiator) - It seems the module covers the intentional radiator portion of testing but not the unintentional
  • KDB 996369 testing - It seems like this one may be strongly recommended, not required
  • Bluetooth Certification
    • Joining of Bluetooth SIG (free)
    • Purchase of a Declaration ID from Bluetooth ($9,600 plus $120 for each GATT profile)
    • Any necessary compliance testing (maybe none if the existing registered QDID for the module has already been tested against the GATT profiles you're using) - This one seems case-by-case
    • Listing of your product in the Bluetooth End Product Listing

For me, the Bluetooth DID fee is the huge disappointment and dwarfs the other costs. Overall, my guess is it'd take about $15,000 to get a Bluetooth device to market using the pre-certified module.

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