Pluto vs CE and FCC marking: the past and the present

Hi

We are planning to use the PLUTO to complement our system (through programming the PLUTO and adding an additional RF stage at TX and at the RX).

I am digging into the CE and FCC marking, to develop it further, demonstrate, and later place it into the market. We don't want to venture out in our work, away from either EU or US rules. In putting it all together, we need to understand how the parts and the whole thing are made to conform. 

In previous PLUTO versions, we understood that the CE and FCC markings were indicated as crossed, showing clearly that it did not conform. That would be OK for us, since we were interpreting the PLUTO as for:
 - the EU: to be used in R&D, not for RF testing (but to be tested itself), as a prototype (not a finished product), so that it could be commercialised in the EU without the CE marking. We would then add an additional module in a similar way. OK

 - the US: to be interpreted as a sub-assembly (again not as a finished product, as for the EU) and as a test equipment "intended primarily for purposes of performing measurements or scientific investigations", so that it could be commercialised in the US without the need for FCC marking. We would then add an additional module in a similar way. OK

But, ironically, now that the PLUTO has the CE and FCC marking, we may now need to change the way that our module will be seen, by itself and altogether, in the EU and US perspectives.

Could anyone shed some light on this?
How is the PLUTO now seen as compliant for the EU? Not anymore as a prototype, for R&D, etc? Or with the sent antennas, for a specific band and use? And for the US, as a "digital device", an "unintentional radiator" (if so, not with the antennas)? Or again, for a specific band, with the sent antennas?

I know that, for us, we need to deal with our own marking or non-marking. But we also need to understand the whole and all parts in it.

I did read AD's https://wiki.analog.com/resources/eval/user-guides/ad-fmcomms2-ebz/certification, about the FMCOMS and ADI Boards
“Certification

Both CE and FCC are necessary for system level products. Because ADI boards are custom built evaluation kits destined for professionals (you) to be used solely at research and development facilities for such purposes, they are considered exempt from the EU product directives and normally are not tested for CE or FCC compliance.

If you choose to use your board to transmit using an antenna, it is your responsibility to make sure that you are in compliance with all laws for the country, frequency, and power levels in which the device is used. Additionally, some countries regulate reception in certain frequency bands. Again, it is the responsibility of the user to maintain compliance with all local laws and regulations."

Many thanks!



(I've later added the lines from "I did read AD's (…) with all local laws and regulations." "
[edited by: JMGil at 2:27 PM (GMT 0) on 25 Jun 2019]