WA2ST4315BNTracking Device

Applicant Declaration QSF27-14-04 Rev 1.4 April 25, 2025 Page 1 of 1 Original Issue: Jan. 4, 2021 SGS North America Inc. 620 Old Peachtree Road SUITE 100 Suwanee, Georgia 30024 United States Applicant Legal Business Name ST SUNLAB Ltd. Address A-1705, 1706, 32, Digital-ro 9-gil, Geumcheon-Gu, Seoul, South Korea FRN 0034948679 Grantee Code WA2 FCC ID: WA2ST4315BN Authorized Contact Name Hun Shin Contact Phone +82-10-8889-4629 Contact Email [email protected] I, the undersigned, certify that I am an authorized signatory for the Applicant and therefore declare; a) in accordance with 47CFR2.911(d), all of the statements herein and the exhibits attached hereto are true and correct to the best of my knowledge and belief. b) in accepting a Grant of Equipment Authorization issued by a TCB, under the authority of the FCC, as a result of the representations made in this application, the Applicant is responsible for: (1) labeling the equipment with the exact FCC ID as specified in this application, (2) compliance statement labeling pursuant to the applicable rules, (3) compliance of the equipment with the applicable technical rules, c) if the Applicant is not the actual manufacturer of the equipment, appropriate arrangements have been made with the manufacturer to ensure that production units of this equipment will continue to comply with the FCC’s technical requirements. d) in accordance with 47 CFR 2.909 and KDB394321, the Applicant has read, understood and agrees to accept that they are the responsible party and agree to abide by their responsibilities as specified under 47 CFR 2.909 and KDB394321. e) in accordance with ISO 17065, FCC KDB641163, FCC KDB610077, KDB394321 and RSP-100, the Applicant has read, understood, accepts and agrees to abide by the post market surveillance requirements. (1) the Applicant understands, accepts and agrees that a sample may be requested for surveillance testing. (2) the Applicant shall make provisions to always have a production sample available upon request by SGS, FCC and/or ISED. (3) the Applicant shall, upon request by SGS, at the Applicant’s expense, provide a production sample of the requested product to SGS, FCC and/or ISED as instructed. The sample shall include all support devices, cables, software, accessories or other hardware or software required for evaluation, review, certification and audit surveillance of products certified by SGS. f) neither the Applicant nor any party to the application is subject to a denial of Federal benefits, that includes FCC benefits, pursuant to Section 5301 of the Anti-Drug Abuse Act of 1988, 21 U.S.C. §862 because of a conviction for possession or distribution of a controlled substance. See 47CFR 1.2002(b) for the definition of a “party” for these purposes. g) the Applicant has read, understood, accepts and agrees to abide by the SGS North America, Inc. terms and conditions as specified in the TCB Application Form 731 (QSF27-14-01). Link to CFRs: https://www.fcc.gov/wireless/bureau-divisions/technologies-systems-and-innovation-division/rules-regulations-title-47 Link to KDBs: https://apps.fcc.gov/oetcf/kdb/index.cfm Link to RSP-100: https://www.ic.gc.ca/eic/site/smt-gst.nsf/eng/sf01130.html Link to the Covered List: Covered List Applicant Signature: Date: February 13, 2026 Print Name: Hun Shin Title: Manager *NOTE: This declaration cannot be signed by an Agent, it shall be signed by an authorized person listed in the FCC database

FCC COVERED LIST DECLARATION LETTER Page 1 of 1 Revision 1.0 SGS North America Inc. 620 Old Peachtree Road SUITE 100 Suwanee, Georgia 30024 United States Applicant Legal Business Name ST SUNLAB Ltd. Address A-1705, 1706, 32, Digital-ro 9-gil, Geumcheon-Gu, Seoul, South Korea FRN 0034948679 Grantee Code WA2 FCC ID: WA2ST4315BN Authorized Contact Name Hun Shin Contact Phone +82-10-8889-4629 Contact Email [email protected] ST SUNLAB Ltd. (“the applicant”) certifies: - the equipment for which authorization is sought is not “covered” equipment prohibited from receiving an equipment authorization pursuant to section 2.903 of the FCC rules. - as of the date of the filing of the application, the applicant is not identified on the Covered list, established pursuant to §1.50002, as an entity producing “covered” equipment. - the software to be loaded prior to marketing of the equipment identified above is not “covered” software manufactured by any entity including predecessors, successors, parents, subsidiaries, affiliates or any entity which has rebranded or relabeled the software produced by the entity(ies) identified on the “Covered List”. - the device is not capable of storing or running software listed on the covered list and therefore is not inherently compliant. NOTE: Justification/evidence explaining how compliance is met must accompany this letter Link to the Covered List: Covered List Applicant Signature: Date: February 13, 2026 Print Name: Hun Shin Title: Manager *NOTE: This declaration cannot be signed by an Agent, it shall be signed by an authorized person listed in the FCC database

UNITED STATES DESIGNATED AGENT LETTER Date: 13-Feb-2026 TO: Federal Communication Commission Equipment Authorization Branch 7435 Oakland Mills Road Columbia, MID 21046 Applicant U.S. designated agent Company Name: ST SUNLAB Ltd.Company Name: Suntech International USA, Inc. FRN: 0034948679FRN: 0034617449 Grantee Code: WA2 Contact Name: Hun ShinContact Name Henry Park Address: A-1706, 1705 GreatValley, 32, Digital-ro 9-gil, Geuncheon-gu, Seoul, South Korea Address: 6060 Corte Del Cedro City/Province/Zip: Seoul City/Province/Zip: Carlsbad, CA, 92011 USA Telephone: +82-10-8889-4629Telephone: 833-282-3731 Fax: +82-2-6327-5654Fax: - Email: [email protected]: [email protected] Applicable Equipment: FCC ID: WA2ST4315BN ATTN: Director of Certification: We, ST SUNLAB Ltd. and Suntech International USA, Inc. understand and acknowledge the applicants consent and the designated agent’s obligation to accept service of process in the United States for matters related to the applicable equipment, and at the physical U.S. address and e-mail of the designated agent listed above. We, ST SUNLAB Ltd. and Suntech International USA, Inc. acknowledge the applicant’s acceptance of its obligation to maintain an agent for service of process in the United States for no less than one year after either the grantee has permanently terminated all marketing and importation of the applicable equipment within the U.S., or the conclusion of any Commission-related administrative or judicial proceeding involving the equipment, whichever is later. Applicant ST SUNLAB Ltd. U.S. designated agent Suntech International USA, Inc. Name (Printed): Hun Shin Name (Printed): Henry Park Title: Manager Title: VP of product engineering Signature: Signature:

ST SUNLAB Ltd. A-1705, 1706, 32, Digital-ro 9-gil, Geumcheon-gu, Seoul, South Korea Date : February 13, 2026 Federal Communications Commission Authorization and Evaluation Division 7435 Oakland Mills Road, Columbia, MD 21046 LETTER FOR AUTHORIZATION FCC ID: WA2ST4315BN To whom it may concern: I, the undersigned, hereby authorize SGS Korea Co., Ltd. and hereafter referred to as SGS Korea, to act on our behalf in all manners relating to application for equipment authorization, including signing of all documents relating to these matters. Any and all acts carried out by SGS Korea Co., Ltd. on our behalf shall have the same effect as acts of our own. I, the undersigned, hereby certify that we are not subject to a denial of federal benefits, that includes FCC benefits, pursuant to Section 5301 of the Anti-Drug Abuse Act of 1988, 21 U.S.C. 853(a). In authorizing SGS Korea as our agent, we still recognize that we are responsible to: a) comply with the relevant provisions of the certification program; b) make all necessary arrangements for the conduct of the evaluation, including provision for examining documentation and access to all areas, records (including internal audit reports) and personnel for the purposes of evaluation (e.g. testing, inspection, assessment, surveillance, reassessment) and resolution of complaints; c) make claims regarding certification only in respect of the scope for which certification has been granted; d) do not use our product certification in such a manner as to bring the Certification Division into disrepute and not make any statement regarding our product certification which the Certification Division may consider misleading or unauthorized; e) upon suspension or cancellation of certification, discontinue use of all advertising matter that contains any reference thereto and return any certification documents as required by the Certification Division; ST SUNLAB Ltd. A-1705, 1706, 32, Digital-ro 9-gil, Geumcheon-gu, Seoul, South Korea f) use certification only to indicate the products are certified as being in conformity with specified standards; g) endeavor to ensure that no certificate or report nor any part thereof is used in a misleading manner; h) ensure that any reference to our product certification in communication media such as documents, brochures or advertising, complies with the requirements of the Certification Division; i) keep a record of all complaints made known to the us relating to the product’s compliance with requirements of the relevant standard and to make these records available to the Certification Division when requested; j) take appropriate action with respect to such complaints and any deficiencies found in products or services that affect compliance with the requirements for certification; k) document the actions taken. This authorization is valid until further written notice from the applicant. Sincerely Yours Name : Hun Shin Title : Manager Company Name : ST SUNLAB Ltd.

ST SUNLAB Ltd. A-1705, 1706, 32, Digital-ro 9-gil, Geumcheon-gu, Seoul, South Korea Date : February 13, 2026 Federal Communications Commission Authorization and Evaluation Division 7435 Oakland Mills Road, Columbia, MD 21046 REQUEST FOR CONFIDENTIALITY FCC ID: WA2ST4315BN Pursuant to Sections 0.457 and 0.459 of the Commission’s Rules (CFR 47), and Section 552 (b) (4) of the Freedom of Information Act, ST SUNLAB Ltd. hereby requests confidentiality and treatment of certain information accompanying this application. The materials contain trade secrets and proprietary information not customarily released to the public. The public disclosure of these matters might be harmful to the Applicant and provide unjustified benefits to its competitors. We are also hereby request Short-Term Confidentiality for 180 days after the grant as outlined in Public Notice DA 04-1705. This provision will give , ST SUNLAB Ltd. temporary confidentiality of commercially sensitive information prior to product release. The requested Permanent and Temporary Confidential exhibits are listed as follows: CONFIDENTIAL LIST Permanent 1 Block Diagram 2 Operational Descriptions 3 Schematics 4 Tune up Procedure Short-Term 5 External Photos 6 Internal Photos 7 Test-Setup Photos 8 User Manual The Applicant understands that pursuant to Rule 0.457, disclosure of this application and all accompanying documentations, where applicable, will not be made public before the date of the Grant for this application. Sincerely Yours, Name / Title : Hun Shin / Manager Company Name : ST SUNLAB Ltd.

38mm 9mm 21mm 34mm Label Information

FCC ID: WA2ST4315BN According to KDB 447498 D04 Interim General RF Exposure Guidance v01 1. MPE-based Exemption General frequency and separation-distance dependent MPE-based effective radiated power (ERP) thresholds are in Table B.1 [Table 1 of § 1.1307(b)(1)(i)(C)] to support an exemption from further evaluation from 300 ㎑ through 100 ㎓. Table 1: THRESHOLDS FOR SINGLE RF SOURCES SUBJECT TO ROUTINE ENVIRONMENTAL EVALUATION RF Source Frequency Minimum Distance Threshold ERP f L (㎒) f H (㎒) λ L / 2π λ H / 2π W 0.3 - 1.34 159 m - 35.6 m 1 920 R2 1.34 - 30 35.6 m - 1.6 m 3 450 R 2 /f 2 30 - 300 1.6 m - 159 mm 3.83 R 2 300 - 1 500 159 mm - 31.8 mm 0.012 8 R 2 f 1 500 - 100 000 31.8 mm - 0.5 mm 19.2 R 2 Subscripts L and H are low and high; λ is wavelength. From § 1.1307(b)(3)(i)(C), modified by adding Minimum Distance columns. The table applies to any RF source (i.e., single fixed, mobile, and portable transmitters) and specifies power and distance criteria for each of the five frequency ranges used for the MPE limits. These criteria apply at separation distances from any part of the radiating structure of at least λ/2π. The thresholds are based on the general population MPE limits with a single perfect reflection, outside of the reactive near-field, and in the main beam of the radiator. For mobile devices that are not exempt per Table B.1 [Table 1 of § 1.1307(b)(1)(i)(C)] at distances from 20 ㎝ to 40 ㎝ and in 0.3 ㎓ to 6 ㎓, evaluation of compliance with the exposure limits in § 1.1310 is necessary if the ERP of the device is greater than ERP 20 ㎝ in Formula (B.1) [repeated from § 2.1091(c)(1) and § 1.1307(b)(1)(i)(B)]. If the ERP is not easily obtained, then the available maximum time-averaged power may be used (i.e., without consideration of ERP only if the physical dimensions of the radiating structure(s) do not exceed the electrical length of λ/4 or if the antenna gain is less than that of a half-wave dipole. SAR-based exemptions are constant at separation distances between 20 ㎝ and 40 ㎝ to avoid discontinuities in the threshold when transitioning between SAR-based and MPE-based exemption criteria at 40 ㎝, considering the importance of reflections. 2. RF Exposure Test Exemptions for Single Source Mode Frequency Range (㎒) Minimum Separation Distance (㎝) Maximum Average Target Power (㏈m) Maximum Tune up (㏈) Maximum Average Output Power Ant. Gain (㏈i) ERP Limits P th (㎽) Ratio Result (㏈m) (㎽) (㏈m) (㎽) Bluetooth Low Energy 2 402 ~ 2 480 20 0 2.0 2 1.585 2.01 1.86 1.535 768 0.002 Pass Mode Frequency Range (㎒) Minimum Separation Distance (㎝) Maximum Average Target Power (㏈m) Maximum Tune up (㏈) Maximum Average Output Power Ant. Gain (㏈i) ERP Limits P th (㎽) Ratio Result (㏈m) (㎽) (㏈m) (㎽) LTE Band 2 1 850 ~ 1 910 20 23 2.0 25 316.228 0.11 22.96 197.697 768 0.257 Pass LTE Band 4 1 710 ~ 1 780 20 23 2.0 25 316.228 0.78 23.63 230.675 768 0.300 Pass LTE Band 5 824 ~ 849 20 23 2.0 25 316.228 -3.38 19.47 88.512 421.888 0.210 Pass LTE Band 12 699 ~ 716 20 23 2.0 25 316.228 0.12 22.97 198.153 357.888 0.554 Pass LTE Band 13 777 ~ 787 20 23 2.0 25 316.228 -0.47 22.38 172.982 397.824 0.435 Pass IoT-NTN Band 23 2 000 ~ 2 200 20 23 2.0 25 316.228 1.82 24.67 293.089 768 0.382 Pass IoT-NTN Band 255 1 626.5 ~ 1660.5 20 23 2.0 25 316.228 0.87 23.72 235.505 768 0.307 Pass Note ; - ERP (㏈m) = Maximum average power (㏈m) + Antenna gain (㏈i) -2.15 - Maximum average target power is the manufacturer’s declared rated power. - Maximum average output power = Maximum average target power (㏈m) + Maximum tune up (㏈). - The EUT not support simultaneous mode. 3. Conclusion: No SAR is required.

Model name: ST4315BN Item Contents Antenna Type PCB Pattern Antenna Antenna peak gain 2.01 ㏈i Manufacturer / Model name ST SUNLAB Ltd. / ST4315BN Address of manufacturer A-1705, 1706, 32, Digital-ro 9-gil, Geumcheon-gu, Seoul, South Korea Test Laboratory Radina Co., Ltd. Antenna Length 2.0 cm Antenna Width 0.6 cm Antenna Information Length Width Copyright 2017 by Radina Co., Ltd. All Rights Reserved. 3D Radiation Pattern YZXZXY Bluetooth (2.4G) ST4315BN BluetoothPassive Measurement Data

SGS Korea Co., Ltd. 4, LS-ro 182beon-gil, Gunpo-si, Gyeonggi-do, Korea, 15807 Tel. +82 31 428 5700 / Fax. +82 31 427 2370 http://www.sgsgroup.kr Report Number: F690501-RF-RTL006727 Page: 2 of 36 RTT7081-02(2020.10.05)(0) A4(210 mm * 297 mm) INDEX Table of contents 1. General Information -------------------------------------------------------------------------------------- 3 2. Transmitter Radiated Spurious Emissions and Conducted Spurious Emissions ---------- 8 3. 6 ㏈ Bandwidth and 99 % Bandwidth ---------------------------------------------------------------- 24 4. Maximum Peak Conducted Output Power --------------------------------------------------------- 29 5. Power Spectral Density --------------------------------------------------------------------------------- 33 6. Antenna Requirement ----------------------------------------------------------------------------------- 36 SGS Korea Co., Ltd. 4, LS-ro 182beon-gil, Gunpo-si, Gyeonggi-do, Korea, 15807 Tel. +82 31 428 5700 / Fax. +82 31 427 2370 http://www.sgsgroup.kr Report Number: F690501-RF-RTL006727 Page: 3 of 36 RTT7081-02(2020.10.05)(0) A4(210 mm * 297 mm) 1. General Information 1.1. Testing Laboratory SGS Korea Co., Ltd. (Gunpo Laboratory) - 10-2, LS-ro 182beon-gil, Gunpo-si, Gyeonggi-do, Korea, 15807 - 4, LS-ro 182beon-gil, Gunpo-si, Gyeonggi-do, Korea, 15807 - Designation number: KR0150 All SGS services are rendered in accordance with the applicable SGS conditions of service available on request and accessible at http://www.sgs.com/en/Terms-and-Conditions.aspx. Phone No. : +82 31 688 0901 Fax No. : +82 31 688 0921 1.2. Details of Applicant Applicant : ST SUNLAB Ltd. Address : A-1705, 1706, 32, Digital-ro 9-gil, Geumcheon-gu, Seoul, South Korea Contact Person : Shin, Hun Phone No. : +82 10 8889 4629 1.3. Details of Manufacturer Company : Same as applicant Address : Same as applicant 1.4. Description of EUT Kind of Product Tracking Device Model Name ST4315BN Serial Number Conducted: 001 Radiated: 002 Power Supply DC 13.5 V Frequency Range 2 402 ㎒ ~ 2 480 ㎒ (Bluetooth Low Energy) Modulation Technique GFSK Number of Channels 40 channels (Bluetooth Low Energy) Antenna Type PCB Pattern Antenna Antenna Gain ※ 2.01 ㏈i H/W Version REV1.0 S/W Version 99.0.5 FVIN N/A SGS Korea Co., Ltd. 4, LS-ro 182beon-gil, Gunpo-si, Gyeonggi-do, Korea, 15807 Tel. +82 31 428 5700 / Fax. +82 31 427 2370 http://www.sgsgroup.kr Report Number: F690501-RF-RTL006727 Page: 4 of 36 RTT7081-02(2020.10.05)(0) A4(210 mm * 297 mm) 1.5. Test Equipment List Equipment Manufacturer Model S/N Cal. Date Cal. Interval Cal. Due Signal Generator R&S SMA100B 106887 10/20/2025 Annual 10/20/2026 Spectrum Analyzer R&S FSV30 103455 02/02/2026 Annual 02/02/2027 Spectrum Analyzer Agilent N9020A MY53421758 09/10/2025 Annual 09/10/2026 Spectrum Analyzer Agilent N9030A US51350132 12/03/2025 Annual 12/03/2026 Attenuator AEROFLEX/INM ET 40AH2W-6 1 03/12/2025 Annual 03/12/2026 High Pass Filter Wainwright Instrument GmbH WHKX3.0/18G-10SS 21 06/17/2025 Annual 06/17/2026 High Pass Filter Wainwright Instrument GmbH WHNX7.5/26.5G-6SS 15 06/09/2025 Annual 06/09/2026 Power Sensor R&S NRP-Z81 100669 05/24/2025 Annual 05/24/2026 DC Power Supply Agilent U8002A 019258024 10/24/2025 Annual 10/24/2026 Preamplifier H.P. 8447F 2944A03909 08/07/2025 Annual 08/07/2026 Signal Conditioning Unit R&S SCU-18F 100959 01/05/2026 Annual 01/05/2027 Preamplifier MITEQ Inc. JS44-18004000-35-8P 1546891 10/20/2025 Annual 10/20/2026 Loop Antenna Schwarzbeck Mess-Elektronik FMZB 1519 1519-039 10/01/2025 Biennial 10/01/2027 Bilog Antenna Schwarzbeck Mess-Elektronik VULB 9163 01126 03/05/2025 Biennial 03/05/2027 Horn Antenna R&S HF906 100326 02/24/2025 Annual 02/24/2026 Horn Antenna Schwarzbeck Mess-Elektronik BBHA 9170 9170-540 12/05/2025 Annual 12/05/2026 EMI Test Receiver R&S ESU26 100109 01/21/2026 Annual 01/21/2027 Turn Table Innco systems GmbH DS 1200 S N/A N.C .R. N/A N.C.R. Controller Innco systems GmbH CONTROLLER CO3000-4P CO3000/963/38 330516/L N.C.R. N/A N.C.R. Antenna Mast Innco systems GmbH MA4640-XP-ET MA4640/536/38 330516/L N.C.R. N/A N.C.R. Anechoic Chamber SY Corporation L × W × H (9.6 m × 6.4 m × 6.6 m) N/A N.C.R. N/A N.C.R. Coaxial Cable SENSORVIEW NMST-13A26-NMST-5 m TPC240219000 4 10/13/2025 Semi- Annual 04/13/2026 Coaxial Cable SENSORVIEW NMST-13A26-NMST-10 m TPC240219000 1 10/13/2025 Semi- Annual 04/13/2026 Coaxial Cable RFONE PL360P-292M292M- 1.5M-A 20200324002 10/10/2025 Semi- Annual 04/10/2026 Note; For equipment listed above that has a calibration date or calibration due date that falls within the test date range, care was taken to ensure that this equipment was used after the calibration date and before the calibration due date SGS Korea Co., Ltd. 4, LS-ro 182beon-gil, Gunpo-si, Gyeonggi-do, Korea, 15807 Tel. +82 31 428 5700 / Fax. +82 31 427 2370 http://www.sgsgroup.kr Report Number: F690501-RF-RTL006727 Page: 5 of 36 RTT7081-02(2020.10.05)(0) A4(210 mm * 297 mm) 1.6. Summary of Test Results The EUT has been tested according to the following specifications: APPLIED STANDARD: FCC Part 15 Subpart C, RSS-247 Issue 4 and RSS-Gen Issue 5 Section in FCC Section in IC Test Item(s) Result 15.205(a) 15.209 15.247(d) RSS-247 Issue 4 6.6 RSS-Gen Issue 5 8.9 Transmitter Radiated Spurious Emissions and Conducted Spurious Emission Pass 15.247(a)(2) RSS-247 Issue 4 6.3.1(a) RSS-Gen Issue 5 6.7 6 ㏈ Bandwidth & 99 % Bandwidth Pass 15.247(b)(3) RSS-247 Issue 4 6.3.2 Maximum Peak Conducted Output Power Pass 15.247(e) RSS-247 Issue 4 6.3.1(b) Power Spectral Density Pass 15.207 RSS-Gen Issue 5 8.8 AC Power Line Conducted Emission N/A 1) Note; 1) The AC power line test was not performed because the EUT use battery power for operation and which do not operate from the AC power lines. 1.7. Test Procedure(s) The measurement procedures described in the American National Standard of Procedure for Compliance Testing of Unlicensed Wireless Devices (ANSI C63.10-2020 for FCC and ANSI C63.10-2020+Cor.1-2023 +C63.10a-2024 +…

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