FCC testing for Motion Detector with ESP-WROOM-32

[digsub]

My end product prepped for resale is a Motion Detector (DT100) interfaced to an ESP-WROOM-32 module. The ESP-WROOM-32 simply takes data from the DT100 RJ45 RX/TX pin-out via Serial-to-TTL and then transmits via Wi-Fi. Other than that connection and sharing 5V power across CAT5, the modules are unchanged from their respective OEMs and in separate plastic enclosures.

The DT100 contains the 10.525 GHz Microwave Solutions MDU1720 X-Band microwave transceiver with modular approval FCC Id ROO-DU1720. The ESP-WROOM-32 has FCC ID 2AC7Z-ESPWROOM32.

Here’s the rub… For FCC/IC modular approvals to remain valid, transmitters cannot be co-located or operate in conjunction with any other antenna or transmitter.

So, is unintentional radiator testing alone adequate for my end product “dongle design” with separate transmitter enclosures and/or potential leeway in the notion of “operating in conjunction.”

Or in worst case, do I need full recertification of end product and transmitters? In fear of this cost, I’ve already tried making the DT100 and ESP-WROOM-32 hardware mutually dependent i.e. guaranteed not to be transmitting at the same time, but the integration was problematic.

Insight and understanding much appreciated!

[WiFive]

Separate enclosures means not colocated imo I think you just have to instruct the user to mount them at least 10cm apart

[digsub]

That's helpful! Is there any official guidance?