For the first time in the history of the Telecommunications Certification Body (TCB) program, the TCB Exclusions List is empty. This means that all transmitter certification applications can now be processed by a TCB (like CKC Certification Services), unless either the TCB or the applicant so choose to submit directly to the FCC. However, this does means that TCBs will be held strictly accountable to following the “Permit But Ask” (PBA) procedures. The PBA List consists of three different types of PBAs:
1. Pre-authorization required (implantable transmitters)
2. FCC review/sample may be required (e.g. DFS testing, Boosters, etc.)
3. Devices in specific categories requiring specific guidance.
Applicants must provide to the TCB any prior FCC PBA details and correspondence (including PBAs obtained by the test laboratory) in order to properly process the application.
Devices subject to PBA rules require FCC intervention. This means in many cases that the TCB reviews the majority of the application materials and then the FCC reviews on the “special cases” part of the application. The benefit to applicants is that while certain transmitters, such as those under PBA rules, may take longer to certify than other transmitters being approved through TCBs, the change generally means faster certifications for transmitters previously mandated to be certified directly by the FCC.