The FCC has allowed certification of modular transmitters since 2000, under an informal public notice. (Modular transmitters are those intended for use inside another device, such as the Wi-Fi and Bluetooth transmitters used in laptops.)

In April 2007, the FCC released a Second Report and Order that moved the modular procedures into the rules, with slight changes. (The First R&O was about something else.) Those new rules have not yet taken effect because they entail new information collection, and hence require approval by the Office of Management and Budget.

This morning, as part of the OMB approval process, the FCC published a notice in the Federal Register requesting comment on the information collection — NOT on the substantive rules. The deadline for comment is December 24, 2007.

Circumstances vary, but we do not ordinarily advise clients to comment in response to these notices.

Because of the comment period, the new modular rules will not take effect at least until the first quarter of 2008.

In the meantime, manufacturers can continue to obtain certifications under the 2000 public notice.