The new Spectrum Management System and the RSP-100

On January 20, 2016 Innovation, Science and Economics Canada (formerly Industry Canada) gave notice that they are  releasing the following documents:

Issue 11 of RSP‑100 has been significantly changed from the previous issue due primarily to the implementation of the Department’s new online Spectrum Applications Modernization – Commercial Software Implementation (SAM‑CSI) tool and Issue 6 of DC-01 has also been changed significantly from the previous issue from the implementation of the SAM-CSI tool.

Those wishing to certify radio equipment will now need to do so through the Spectrum website which can be found here.
The services offered through the new Spectrum Management System include certification, registration of terminal equipment, registration of wireless test sites and various search tools. The new Spectrum Management System offers a more streamlined and effective approach for registering and certifying radio apparatuses with Innovation, Science and Economics Canada.
The requirement for out of country applicants to have a Canadian Representative remains.
As before clients  are required to apply for certification or registration of specific equipment types, the certifications and registrations which are available through the new Spectrum Management System are listed below:

  • New Single Product Certification/Registration
  • New Family Product Certification/Registration
  • Add New Product to Existing Certification/Registration (C1PC, C2PC)
  • Product Modification (C3PC, C4PC)
  • Multiple Listing of Certification/Registration
  • Full Transfer of Certification/Registration
  • Partial Transfer of Certification/Registration
  • New Test Site Registration
  • Renew Test Site Registration
  • Telecommunications Apparatus Register (TAR)

For our current clients, if you currently hold an equipment certification or registration, your existing account structure and account number will remain the same.

New clients and new companies will be given an account number generated by the Spectrum Management System. For accounts with multiples services, new Spectrum Management System account numbers will be generated sequentially. These changes will not effect certification or registration numbers, these numbers will remain the same and can be used as an identifier when obtaining services from Innovation, Science and Economic Development Canada.
The new changes to the system allow for us to provide more efficient applications to our Canadian Representative clients concerning RSP-100 certifications. The modernization of the application system by virtue of the Spectrum Management System is a welcome change the we are certain our Canadian Representative clients will be able to take advantage of.
If you have any questions or would like more information regarding radio equipment certification in Canada (RSP-100 and others) or require a Canadian Representative for your application to Innovation, Science and Economic Development Canada (formerly Industry Canada), call or email Koby Smutylo at 613 869 5440 or koby@lawyercorporation.ca.

 

Notice re RSP – 100 – Certification of Radio Apparatus

Companies applying to certify radio apparatus and broadcasting equipment should ensure that they follow the updated RSP – 100 – Certification of Radio Apparatus released by Innovation, Science and Economic Development Canada (formerly Industry Canada) in November, 2014.

On

November 13, 2014, Innovation, Science and Economic Development Canada released “The Radio Standards Procedure for Certification of Radio Apparatus (RSP-100 Issue 10)“, which sets out the requirements for certification of radio apparatus and broadcasting equipment in Canada.  Also on November 13, 2014, Innovation, Science and Economic Development Canada (formerly Industry Canada) released “RSS-Gen- General Requirements for Compliance of Radio Apparatus” .

What’s New? 

(1)  Issue 10 of RSP-100 has been entirely modified. There are numerous changes to the content including the numbering of sections. Consequently, all changes may not be captured in this list.

 

(2)  Sections 2.3, 2.4, 3, 4, and 7 have been added to RSP-100, Issue 10; they were previously in RSS-Gen, Issue 3.

 

(2.7) Licence-Exempt Radio Apparatus

Certain types of radio apparatus are permitted to operate without licensing from Industry Canada. These are typically low-output power devices that are intended primarily for consumer or commercial applications.

Licence-exempt (unlicensed) radio apparatus share spectrum with licensed radio services and must operate on a no‑interference, no-protection basis in relation to all other radio systems. Licence-exempt radio apparatus may not cause radio interference to, and cannot claim protection from interference caused by, licensed radio services.

(4.5) Transfer of a Certification

Certification ownership may be transferred from the current owner to a new entity that wishes to assume all of the previous owner’s responsibilities associated with the certificate. To transfer the ownership, the new entity shall send a letter to the Bureau providing a copy of a signed letter from the current certificate holder, authorizing the Department to transfer the ownership from the current owner to the new entity and change the certificate file information to reflect the new owner’s information. The letter must also attest that the equipment covered by the certificate is identical in design and construction to the originally-approved model.

A completed and signed copy of Annex A is also required.

(5) Modification of Certified Radio Equipment

5.1  General

Modifications to certified radio equipment may require re-certification of the radio equipment. The certificate holder shall inform the certification body or the Department of any changes that may affect compliance with the technical requirements of the standards under which the device was originally certified. These changes may require either complete or partial re-testing. Full details shall be submitted to the certification body or to the Department, including any test results where applicable.

5.2  Class I Permissive Change

A Class I permissive change includes those modifications in the radio equipment that:

  • do not change the electrical characteristics beyond the rated limits established by the manufacturer;
  • do not change external or internal mechanical characteristics significantly enough to require new photographs to identify the modified radio equipment; and
  • do not change the model number.

A Class I permissive change does not require notification to Industry Canada. However, when Class I permissible changes are made, the certificate holder must ensure that the attestation of compliance with RSS-102, last submitted, continues to be valid.

5.3 Class II Permissive Change

A Class II permissive change includes those modifications in the radio equipment which do change the electrical characteristics beyond the rated limits established by the manufacturer, without violating the minimum requirements of the applicable standard. A Class II permissive change requires notification to Industry Canada. However, when Class II permissible changes are made, the certificate holder must ensure that the attestation of compliance with RSS-102, last submitted, continues to be valid.

(6.2) Post-certification Audits, Investigations and Quality Control

Post-certification audits will be conducted by the Bureau and the CB in order to ensure continuing compliance. The Department may request from a certificate holder random radio equipment samples at the certificate holder’s expense for post-certification audit testing, or as a result of radio interference complaints. In the event of an investigation of non-compliance, the certificate holder will be asked to provide to the Department records of the quality control process, as well as any relevant information that would help to identify issues related to compliance. It is expected that all certificate holders will be able to demonstrate a quality control process used for production inspection and testing in accordance with good engineering practices.

Our Canadian Representative Service includes a free non-obligation consultation that offers reasonable guidance of how to efficiently get a license for certified equipment for your business.

 

If you have any questions or would like more information regarding radio equipment certification in Canada or require a Canadian Representative for your application to Innovation, Science and Economic Development Canada (formerly Industry Canada), call or email Koby Smutylo at 613 869 5440 or koby@lawyercorporation.ca.

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Industry Canada Now Part of Newly Created “Innovation, Science and Economic Development Canada”

Innovation, Science and Economic Development Canada was recently formed by Canada’s Trudeau government by the amalgamation of Industry Canada and the Ministry for Science and Technology. The motive here is clear, to closer associate science and technology with economic growth and development. As technology becomes a key driver of economic growth it has become clear that governments must engage and foster the science and technology sectors. While economies have always been directly linked to technology and innovation, they have rarely been governed or regulated as one industry. The recent reorganization of Industry Canada is the first sign of the new government recognizing the intrinsic link between the two sectors and the pivotal role they will play in Canada’s future. Foreign technology companies operating in Canada might be wondering how exactly this restructuring will affect them, particularly might their obligations change under the new ministry. Additionally, will the pairing of Industry Canada and the Ministry of Science and Technology possibly open new avenues for investment or streamline business processes.

Simply, for companies applying to Innovation, Science and Economic Development Canada for certification or registration of wireless products under RSP-100 there will be no material change of substance or procedure. Similarly, compliance and liaison obligations will remain the same for the time being. For our clients this means business as usual and in case of change our clients will be duly notified and the proper arrangements and corrections will be made.

In the long run, this coupling of ministries could signify new opportunities for our wireless technologies clients. As developments occur and the nature of this fledgling organization becomes clear we will actively bring to our clients opportunities for growth. We do forecast that reporting across our clients organization will be come streamlined, as prior compliance to the Ministry of Science and Technology mandates and those of Industry Canada will now be owed to one organization. This will result in improved communication and report with the Ministry and sprout long lasting relationships. Clients wishing to explore consolidation of reporting or legislation compliance should contact Smutylo Law+ to explore their options.

If you have any questions or would like more information regarding Industry Canada; Innovation, Science and Economic Development Canada; Canadian Representatives or RSP-100 (Certification of Radio Apparatus) procedures call or email Koby Smutylo at 613 869 5440 or koby@lawyercorporation.ca.

Radio Equipment User Manual Notice Requirement for Certification

Radio equipment of any kind, including bluetooth and Wifi devices, must meet specific Innovation, Science and Economic Development Canada (formerly Industry Canada) regulatory requirements and technical standards before it can be imported, sold or used in Canada. The process of demonstrating compliance to Industry Canada is called “certification”. Over the last few years, we have served as the Canadian Representative of many foreign manufacturers of radio devices applying to Innovation, Science and Economic Development Canada (formerly Industry Canada) for certification under Canada’s technical standards outlined in RSS-210 and RSS-310 as well as other regulatory requirements. While the certification process is fairly straightforward, sometimes we are asked to clarify certain of the requirements. For example, recently, we were asked by a client whether the user manual of a particular radio product is required to include any specific notice. We answered in the affirmative: pursuant to section 8.4 of RSS-Gen, notice must be displayed in a conspicuous location, either in the user manual or on the device, or both, that the device complies with Innovation, Science and Economic Development Canada’s license-exempt RSSs and that operation of the device is subject to the following two conditions: the device may not cause interference and the device must accept any interference, including interference that may cause undesired operation of the device. In addition, we thought it prudent to draw the client’s attention to the requirement in RSP1-100 that the notice must be in both English and French and that variable formats are acceptable for providing the notice (i.e., in paper form, CD, DVD, or insert with download link on the company’s website).

We are always pleased to be called upon to assist our foreign clients navigate the sometimes confusing Canadian regulatory environment and, best of all, for those companies that have appointed us as their Canadian Representative, there is no extra charge for this guidance.

If you have any questions or would like more information regarding the Radio Equipment Certification Procedure or Innovation, Science and Economic Development Canada, call or email Koby Smutylo at 613 869 5440 or koby@lawyercorporation.ca.

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Radio Equipment Certification – Certifying Multiple Devices? One Application or Multiple Applications

Any radio equipment introduced into the Canadian market must first be certified by Innovation, Science and Economic Development Canada (formerly Industry Canada), but certification is not required where the equipment is imported exclusively for demonstration or trial purposes and not for distribution.  To be certified, radio equipment must meet the standards and specifications of the  Engineering Bureau of Innovation, Science and Economic Development Canada or a recognized Certification Body (“CB”).  If the radio equipment satisfies the applicable standards and specifications, a Certificate will be issued indicating compliance with applicable standards or specifications for the purposes of section 21(1)(b) and (c) of the Radiocommunication Regulations.

According to Innovation, Science and Economic Development Canada, “Certification of equipment for use in Canada guarantees that:

  • The equipment meets the technical requirements under Canada’s Radiocommunication Regulations. Certified equipment also meets the regulations of the International Telecommunication Union (ITU) of which Canada is a member.
  • The requirements and standards for specific types of equipment are the same for all manufacturers and importers of radio apparatus.
  • The use of spectrum efficient radio devices is encouraged. Greater efficiency in spectrum use allows a greater number of Canadians to benefit from radiocommunication services.”

Radio equipment for which certification must be obtained is set out in Category I Equipment Standards List, which includes broadcasting transmitters, portable radio transmitters, digital scanner receivers, cellular phones, remote car alarms and starters, garage door openers and wireless computer links.  Category II Equipment, i.e. electronic transformers or ballasts, alarm keypads, intelligent battery chargers, satellite TV receivers, VCR‘s and computers, is not required to be certified though it must meet certain technical standards.

As part of the certification testing process of a radio device, attention is given to the following:

  1. the radio frequency and RF output power;
  2. the radio frequency circuitry;
  3. functional capabilities; and
  4. a test report.

Recently, a client inquired regarding whether it was required to individually certify each model of its radio device, in this case a smart watch.  The answer is that Industry Canada permits “family certification” of multiple models if they are electrically identical and provided that each model is assigned a unique model number by the manufacturer.   However, if the devices are not “electrically identical”, each device must be certified individually.

If you are applying to certify a radio device in Canada and need more information, click here for Innovation, Science and Economic Development Canada’s Radio Equipment Certification Procedure – RSP-100 or give us a call or send us an email.  

Don’t forget that each application must include the identity of a representative in Canada who is capable of responding to enquiries and who can provide post-certification audit samples at no charge to Industry Canada.  This is a service we provide for companies based in the United States, Europe, Asia and elsewhere.  

If you have any questions or would like more information regarding the Radio Equipment Certification Procedure , call or email Koby Smutylo at 613 869 5440 or koby@lawyercorporation.ca.

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Frequently Asked Questions Regarding Canadian Certification of Radio Equipment

Answers to frequently asked questions regarding Innovation, Science and Economic Development Canada (formerly Industry Canada) wireless certification can be found here.

Radio Equipment Certification – When is Innovation, Science and Economic Development Canada (formerly Industry Canada) certification required?

It is the final production model that must comply with the applicable Radio Equipment Certification requirements.  See Category I Equipment Standards List for specific information regarding what radio equipment is subject ot certification by Industry Canada.

Radio equipment imported only for demonstration or trial purposes does not need to be certified.  However, such equipment may require a developmental radio license.  Contact Innovation, Science and Economic Development Canada (formerly Industry Canada) for more information.

Information regarding the application is available on Innovation, Science and Economic Development Canada’s website.  Each applicant must provide the name, contact information and Innovation, Science and Economic Development Canada (formerly Industry Canada) registration particulars for such applicant’s representative in Canada.  The representative must be a person capable of responding to Innovation, Science and Economic Development Canada enquiries and who, if required, can provide post-certification audit samples at no charge to Innovation, Science and Economic Development Canada.

We are pleased to be the Canadian Representative for many new radio equipment technologies.  For more information regarding our services, click here.

 

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