Lab Test Plan & Preparation¶

This section outlines the requirements for preparing the EverTag system for formal certification testing at an accredited laboratory. Proper preparation is critical to avoid delays and costly re-testing.

Pre-Certified Module Strategy¶

The EverTag Connectivity Module uses pre-certified RF modules for all intentional radio transmitters. This eliminates the need for per-radio characterization testing (DTM / Direct Test Mode) at the product level.

Module	Radio	Pre-certification	FCC Grant Holder
PAN B611-1 (nRF54L15)	BLE 6.0 + Wirepas Mesh (2.4 GHz)	FCC Part 15 Subpart C, CE RED	Panasonic / Nordic
ESP32-C5 WROOM-1	WiFi 802.11ax (2.4 + 5 GHz)	FCC Part 15 Subpart C, CE RED	Espressif

What this means: The individual radio characterization — conducted power, occupied bandwidth, spurious emissions, modulation accuracy per channel — was already performed by the module manufacturers during their certification. As long as we do not deviate from the module integration guidelines (antenna design, keep-out areas, trace impedance, max TX power), the module grants remain valid and we do not repeat these tests.

No DTM / Test Mode Firmware Required

Because both RF modules are pre-certified and integrated per their manufacturers' guidelines (approved antennas, compliant trace routing, firmware-enforced TX power limits), no special Direct Test Mode (DTM) firmware is needed for Phase 1 certification. The lab does not need to command individual radios into continuous transmit mode or sweep channels. All intentional radiator testing is covered by the existing module grants.

What the product-level lab testing focuses on:

Co-location / simultaneous operation — all radios active together (intermodulation, combined RF exposure)
Unintentional emissions (FCC Part 15B) — switching regulators, clocks, digital buses
Safety (UL) — AC mains isolation in the Power Base Module

Hardware Requirements¶

Test labs require specific hardware configurations to perform the necessary evaluations.

Test Samples¶

The engineering team must provide the following samples to the test lab. Due to our two-phase certification strategy, sample preparation differs by phase.

Phase 1: Initial Launch (BLE + Wirepas + WiFi)¶

For the initial certification run, the goal is to evaluate the base functionality without the complexities of the LTE modem or 60 GHz radar.

DNP Instructions: The Acconeer A121 IC (along with its dedicated LP5907 LDO and 24 MHz crystal) and the LTE Extension components (SIM7672E modem) MUST be explicitly marked as DNP (Do Not Populate) on the BOM for these test units.
Normal Operating Units (2-3): Fully assembled, functional units running production-equivalent firmware with all Phase 1 radios active (Wirepas Mesh + BLE advertising + WiFi connected). These are used for simultaneous operation testing, unintentional emissions, EMC immunity, and safety testing.
Un-potted/Open Units (1-2): Units without any potting compound or final enclosure sealing. These are required for the safety lab to inspect the internal construction, component markings, and PCB layout (creepage and clearance distances).

Conducted RF Units Not Required

Because both RF modules (PAN B611-1 and ESP32-C5 WROOM) are pre-certified with integrated antennas and we do not deviate from the module design, no conducted RF test units are needed. The lab does not need to disconnect antennas or solder coax pigtails. All radiated measurements are performed on the normal operating units with internal antennas intact.

Phase 2: Expansions (LTE / Radar) — Optional¶

When ready to certify the LTE and/or 60 GHz radar features, additional testing is required via a Class II Permissive Change (C2PC) filing:

Fully Populated Units: Units built with the LTE modem and/or Acconeer A121 radar populated, in addition to all Phase 1 radios.
Radar Test Firmware: The Acconeer A121 is also a pre-certified module (FCC Part 15.255). However, the lab may require the Acconeer Exploration Tool or test firmware to command the radar into Continuous Wave (CW) mode for 60 GHz spurious emissions verification during the C2PC evaluation.
Scope of C2PC testing: The lab does not re-evaluate Phase 1 radios individually. It verifies that adding the new transmitters (LTE and/or 60 GHz) does not create illegal intermodulation products or exceed combined RF exposure limits. This means:
- Radiated spurious emissions sweep with all radios active simultaneously (Phase 1 + Phase 2)
- Updated RF exposure (MPE) calculation for combined output of all co-located transmitters
- LTE intentional radiator testing only if the LTE module grant conditions require it for the specific integration

Support Equipment¶

The lab must be provided with all necessary equipment to operate and monitor the EverTag system during testing:

Power Supplies: The actual Power Base Module that will be sold with the product. Provide 2-3 units.
Wirepas Mesh Neighbor: At least one additional Wirepas node (can be another EverTag Station or a development board) to form a mesh network with the device under test. The DUT must be actively participating in the Wirepas mesh during simultaneous operation testing.
WiFi Access Point: A portable WiFi AP (dual-band) for the ESP32 to connect to during testing. Pre-configure the DUT with the AP credentials.
BLE Central (optional): A phone or BLE dongle to verify BLE advertising is active. Not strictly required — BLE advertising runs autonomously.
Cables: TC2030 programming cables (J1 for nRF54, J2 for ESP32) in case firmware needs to be reflashed. USB-C cable for J3 if populated (dev units).
Host Computer: A laptop with CB Admin app and terminal software for monitoring (if needed).

Firmware Requirements¶

Phase 1: Production-Equivalent Firmware (No DTM Required)¶

Because all RF modules are pre-certified, the lab testing uses production-equivalent firmware — the same firmware that will ship on production units. No special test mode builds are required.

The firmware must ensure all radios are simultaneously active during testing:

Radio	Required state during lab testing	How to verify
Wirepas Mesh (nRF54)	Joined to mesh network, actively exchanging packets with at least one neighbor node	LED1 shows green (sink connected) or blue (joined, no sink)
BLE (nRF54)	Advertising (connectable or non-connectable)	Visible on a BLE scanner app (e.g., nRF Connect mobile)
WiFi (ESP32)	Connected to AP in Station mode, actively sending traffic (e.g., MQTT keep-alive or ping)	LED2 shows green (WiFi + MQTT connected) or blue (WiFi connected)

Pre-configure before shipping to lab

Flash the production firmware, configure Wirepas network settings, WiFi AP credentials, and MQTT broker address before shipping units to the lab. Provide the lab with the portable WiFi AP pre-configured with the matching SSID/password. The units should power on and connect automatically — minimizing lab technician involvement and reducing test time.

Why DTM Is Not Needed¶

Traditional approach (no module grants)	Our approach (pre-certified modules)
Lab needs DTM firmware to command each radio into continuous TX on specific channels/modulations	Module manufacturer already did this during their certification
Conducted RF units with coax pigtails required	Not required — modules use integrated antennas per grant
Lab measures occupied bandwidth, TX power, spurious emissions per radio	Already on file in the module's FCC grant
Requires test mode CLI or vendor tools	Production firmware is sufficient

DTM / test mode firmware would only be required if we deviated from the module's certified conditions — e.g., different antenna, higher TX power, or modified RF trace routing. We do not deviate.

Phase 2: Radar Test Firmware (If Applicable)¶

If certifying the Acconeer A121 60 GHz radar via C2PC:

The A121 is a pre-certified module, but the lab may request CW mode for 60 GHz spurious emissions verification
Provide the Acconeer Exploration Tool (runs on host laptop, controls A121 via SPI through the nRF54 firmware bridge) or a dedicated radar test binary
All Phase 1 radios must also be active simultaneously during Phase 2 testing

Lab Test Matrix¶

Phase 1 Tests¶

Test	Standard	Radios active	Sample type	Notes
Radiated spurious emissions	FCC Part 15B (§15.109)	All (Wirepas + BLE + WiFi)	Normal operating unit	Verify no intermodulation products from combined TX exceed limits
Simultaneous TX / co-location	FCC KDB 520657	All simultaneously	Normal operating unit	All radios active, measure combined radiated emissions
RF exposure (MPE)	FCC KDB 447498	All simultaneously	Calculation + spot measurement	Combined RF power from all antennas; verify below 1 mW/cm² at 20 cm
Conducted emissions	FCC Part 15B (§15.107)	All	Normal operating unit	AC mains conducted emissions via Power Base Module
EMC immunity	EN 61000-4-x (CE only)	All	Normal operating unit	ESD, surge, conducted RF immunity
Safety (AC mains)	UL 62368-1 / IEC 62368-1	N/A	Open unit + normal unit	Creepage, clearance, dielectric withstand, earth continuity on Power Base Module
UL 498	NEMA 5-15 receptacle	N/A	Normal operating unit	Pass-through outlet safety

Phase 2 Tests (C2PC — If Applicable)¶

Test	Standard	Radios active	Notes
Radiated spurious emissions	FCC Part 15B + 15.255	All Phase 1 + radar (+ LTE if applicable)	Sweep includes 60 GHz band
Simultaneous TX / co-location	FCC KDB 520657	All radios	Verify Phase 1 + Phase 2 radios together
RF exposure (MPE)	FCC KDB 447498	All radios	Updated calculation with 60 GHz + LTE added
60 GHz intentional radiator	FCC Part 15.255	Radar	Only if A121 module grant requires additional verification in host product

2.4 GHz Coexistence — Lab Perspective¶

The device has three 2.4 GHz radio functions that can be active simultaneously:

Radio	Chip	Duty cycle	Coexistence mechanism
Wirepas Mesh	nRF54L15 (PAN611)	<0.1% (TDMA, ~1 ms packets)	Adaptive Frequency Avoidance (AFA) — built into Wirepas stack
BLE 6.0	nRF54L15 (PAN611)	Low (advertising intervals)	Same chip as Wirepas — internal scheduler manages time-sharing
WiFi	ESP32-C5 WROOM	Variable (bursty)	Separate hardware; 5 GHz preferred; 3-wire COEX GPIOs routed (FW TBD)

Why this is not a certification concern:

BLE and Wirepas share the same physical radio (nRF54L15) — they cannot transmit simultaneously. The Wirepas stack manages time-division internally. Combined emissions cannot exceed a single radio's output.
WiFi operates on a separate chip with a separate antenna. When on 5 GHz, there is zero 2.4 GHz contention. When on 2.4 GHz, Wirepas AFA automatically avoids occupied WiFi channels, and Wirepas duty cycle is <0.1%.
This is the same multi-radio pattern used by every smartphone and IoT gateway (BLE + WiFi). It is routine for FCC test labs.

The lab simply needs all radios active during the simultaneous operation sweep. No special coexistence test firmware is required — the production firmware's normal behavior demonstrates coexistence.

Documentation Requirements¶

The test lab will require a comprehensive set of documentation to understand the product and perform the evaluation. This forms the basis of the Technical Construction File (TCF).

Block Diagram: Showing all major components, clock frequencies, radio modules, and signal paths between MCUs.
Schematics: Full electrical schematics for all PCBs (Power Base Module + Connectivity Module).
Bill of Materials (BOM): Listing all components, with specific attention to safety-critical parts (transformers, fuses, varistors) and their individual certifications. DNP components clearly marked.
PCB Layout/Gerbers: To verify trace routing, antenna keep-out compliance, and module integration per manufacturer guidelines.
Module Grant References: FCC IDs for PAN B611-1 and ESP32-C5 WROOM-1, with documentation showing integration compliance (antenna type, TX power limits, keep-out areas).
User Manual (Draft): Including all required regulatory statements, installation instructions, and WiFi band preference guidance.
Operational Description: A brief technical description of how the device works, its intended use, radio characteristics, and coexistence approach (Wirepas AFA, 5 GHz WiFi preference, 3-wire COEX GPIO availability).