RSP-100 is the Radio Standards Procedure that sets out the certification procedure for radio apparatus and broadcasting equipment in Canada. If you manufacture, import, or distribute products containing radio equipment (Wi-Fi, Bluetooth, push-to-talk radios, etc.), this is the key document you need to understand. The current version is Issue 12, published by Innovation, Science and Economic Development Canada (ISED) in August 2019.

For terminal equipment, please consult our DC-01 guide (coming soon).

What products need to be certified under RSP-100?

Under the Radiocommunication Act and the Radiocommunication Regulations, radio apparatus and broadcasting equipment are divided into two categories.

Category I equipment: certification required

Generally, products containing radio equipment (that is, products that intentionally emit radio waves) are classified by ISED as Category I equipment. These products must obtain and maintain certification as described in RSP-100.

Examples of Category I equipment:

  • Wi-Fi devices
  • Bluetooth devices
  • Broadcast transmitters
  • Point-to-point broadband links (used for backhaul)
  • Cellular networks and cellphones
  • Taxi and police push-to-talk radios

Category II equipment: Supplier’s Declaration of Conformity

Certain products fall under Category II and do not require certification (they do not need a Technical Acceptance Certificate, or TAC). However, they must still meet ISED’s technical standards, which include technical and administrative requirements such as the Supplier’s Declaration of Conformity (SDoC). These devices may also be licence-exempt.

For more information on Category II and licence-exempt products, please see our Category II and licence-exempt devices guide (coming soon).

Examples of Category II equipment:

  • Very low-power transmitters and stand-alone receivers
  • Most consumer electronic devices that unintentionally produce radio frequency emissions (computers, DVD players, etc.)
  • Satellite receivers

In short

If your radio equipment or broadcasting equipment falls under Category I, the product must be certified following the requirements of RSP-100. ISED’s radio equipment standards page lists which standards fall under Category I and which fall under Category II.

Certification requirements under RSP-100

For radio equipment or broadcasting equipment to be certified, applicants must follow the requirements set by RSP-100. The key requirements are appointing a Canadian representative (section 4.1), preparing and submitting applications for certification services (section 4.2), and complying with CS-03 when necessary (section 4.3).

The RSP-100 certification path at a glance
  1. Testing Test reports to RSS-Gen and the applicable RSSs
  2. Canadian representative Required if the applicant is outside Canada (s. 4.1)
  3. Application package ISED Forms A–D and supporting documents (s. 4.2)
  4. CB review An ISED-recognized Certification Body reviews the package
  5. Certificate and REL TAC issued and product listed in the REL (s. 6)
  6. Ongoing compliance Labelling, changes, audits and remedial action (s. 5, 10–12)

Canadian representative

RSP-100 section 4.1 requires the appointment of a Canadian representative for all applicants whose company address is not within Canada. The representative is identified in the signed Application and Agreement for Certification Services (ISED Form A). The Canadian representative is responsible for responding to all ISED enquiries regarding the certified product(s), including providing audit samples to ISED at no charge. The representative arrangement must be in place for as long as the product is offered on the Canadian market.

Key points to remember

  • The requirement is based on the applicant’s address. The address of the manufacturer, factory, importer, or brand owner does not determine whether a representative is required.
  • The representative must be able to receive enquiries and produce samples. The representative should be fluent in one of Canada’s official languages — when in doubt, give them a call. Ideally, the representative is also familiar with the entire certification process, so they can respond to ISED enquiries efficiently and accurately. A virtual office is generally not sufficient, since it cannot respond to enquiries or handle samples.
  • Arrangements must cover the entire market life of the product. This can be achieved with a single agreement covering the product’s commercial life, or with a renewal-based model, as long as there is no gap in coverage.

Our ISED Canadian Representative service is provided by experienced ISED certification specialists, so enquiries are handled by people who understand the certification process.

Preparing and submitting applications

RSP-100 section 4.2 requires applicants to prepare a complete ISED certification application package and submit it online through ISED’s Equipment Certification and Registration Services. A complete application package includes:

  • An Application Cover Letter describing the certification service being requested and the intended use of the radio product
  • Test report(s) that meet the requirements of RSS-Gen (General Requirements for Compliance of Radio Apparatus)
  • A completed Test Report Cover Sheet (ISED Form B)

For a comprehensive list of required documents, consult the Document Checklist for Certification (ISED Form C).

Key points to remember

  • A certification body reviews the application. Application packages are generally certified by an ISED-recognized Certification Body (CB), which reviews the complete package and either issues the certificate or raises any deficiencies.
  • The required documents vary with the certification service. The supporting documents depend on which certification service applies to your product, and identifying and preparing the right package can be complex. A certification expert can help with the submission and with responding to the CB.
  • Test your product to demonstrate compliance. The application package must include test reports demonstrating compliance with the applicable technical requirements. Depending on the device type, testing may need to be done by an ISED-recognized testing laboratory.

CS-03 compliance

Under RSP-100 section 4.3, radio apparatus designed to connect to the public switched network must also comply with ISED’s CS-03 standards, in addition to the applicable Radio Standards Specifications (RSSs). Section 4.4 adds that terminal equipment must also be registered following the procedure in DC-01.

Other requirements under RSP-100

Labelling requirements

RSP-100 section 5 requires products to meet the labelling requirements set out in RSS-Gen and the applicable standards. These labelling requirements specify what must appear on the label permanently attached to each unit, when the label can instead be shown electronically (e-labelling), and what information must be included in the user manual. RSS-Gen Issue 6 also adds an optional QR-code labelling method; see our RSS-Gen and RSS-310 Issue 6 article for details.

For additional information on labelling requirements, please consult our labelling guide (coming soon).

Listing requirements

The Radio Equipment List (REL) is maintained by ISED to provide the public with information on certified radio and broadcasting equipment manufactured, imported, or distributed in Canada.

Under RSP-100 section 6, certified Category I equipment must be listed in the REL, following the listing requirements set out in RSS-Gen.

User notice requirements

RSP-100 section 7 requires that any user notices required by the applicable RSS or Broadcasting Equipment Technical Standard (BETS) be included with each unit of the product offered for sale. The required notices must:

  • Be stated in both English and French, as specified in the applicable RSS or BETS
  • Be shown in a conspicuous location in the user manual or displayed on the product. Acceptable formats include paper, CD, DVD, or an insert with a download link to the company’s website.
  • Identify the product version each notice applies to, where more than one notice is required for multiple product versions

Where the user notices are only available in one language (English or French) at the time of certification, the applicant must provide a written declaration that the notices will be in both English and French when the product is made available for sale or lease in Canada.

Host and modular product requirements

RSP-100 section 8 covers host products and modular products. Radio products designed as modules for installation in a host product are considered modular products, and can obtain either modular approval (MA) or limited modular approval (LMA).

Hosts, modules, MA and LMA

Host product

Certified module Wi-Fi / Bluetooth

Certified module Cellular

If all intentional emissions come from certified modules, the host may not need its own certification.

Modular approval (MA)

The module meets all modular approval requirements, and can be integrated into hosts following its instructions.

Limited modular approval (LMA)

The module cannot meet one or more requirements. It is approved only for a specific host, and the applicant controls the final installation.

Handheld and wearable hosts

Cellphones, smartwatches and similar devices generally need host certification, especially with more than one module.

Host products. Host products are final products that contain one or more certified modules. The modules must be integrated following the requirements and instructions for intended use and configuration provided by the module certificate holder. The host product and its modules (that is, the final product) must meet all applicable requirements in RSS-Gen, including the radio frequency (RF) exposure requirements in RSS-102.

Does the host product need its own certification?

A host product on its own may not need to be certified separately, provided that all of its intentional radio emissions come from certified modules. Because the answer depends on the product, we recommend contacting a certification expert to determine the right compliance plan.

Example: handheld and wearable hosts

Handheld and wearable host devices (such as cellphones and smartwatches) generally require host certification, because modular certification is only adequate when the host contains a single transmitter module whose specific absorption rate (SAR) is exempt or below 0.4 W/kg. When a handheld or wearable host contains multiple modules, host certification is required in all cases, regardless of whether the modules transmit one at a time or simultaneously, and regardless of each module’s SAR value.

Modular approval (MA). Applicants must submit a complete MA certification application package, including the Modular Approval Attestation (ISED Form D) and the intended use and configuration instructions for integrating the module into a host. To obtain MA certification, the module must meet all of the requirements in the Modular Approval Attestation.

Limited modular approval (LMA). Applicants must submit a complete LMA certification application package, including the Modular Approval Attestation (ISED Form D) and the intended use and configuration instructions for integrating the module into a host. LMA is intended for modules that cannot meet one or more of the modular approval requirements. The applicant must demonstrate in the Modular Approval Attestation how they will retain control over the final installation, so that compliance of the end product is assured. In that case, the LMA certificate carries an operating condition stating that the module is only approved for use in a specific host. Applicants may also choose LMA for a module that does meet all of the MA requirements, provided they state the reason in the Modular Approval Attestation.

New single product vs new family product certification

RSP-100 section 9 describes the two services for certifying a new product. Both rely on a few key identifiers, which must be provided in the application:

  • Product Marketing Name (PMN): the name or model number under which the product is marketed in Canada. It is required at the time of certification, although its public listing can be temporarily deferred.
  • Hardware Version Identification Number (HVIN): identifies the hardware version of the product. It is required for every product and must appear on the label or e-label, so changing the HVIN means changing the label.
  • Firmware Version Identification Number (FVIN): identifies the firmware version that controls the product’s RF characteristics, where applicable (“N/A” is entered if no firmware is needed).
  • Host Marketing Name (HMN): the name or model number of the host, required when a module’s compliance is assessed in a host product.

New Single Product Certification

A New Single Product Certification covers a single product version, whether a final product or a module. It may be granted provided the applicant has never been granted certification for the assigned HVIN or ISED Certification Number (IC ID). The application must include the PMN (which can be identical to the HVIN), the FVIN where applicable, the HMN for modules assessed in a host, and the documents listed in ISED Form C.

New Family Product Certification

A New Family Product Certification lets multiple versions of a product design be certified together under a single ISED Certification Number (IC ID), provided that all product versions in the family meet these conditions:

  • The enclosure and general appearance of all versions are identical, except for enclosure colour and minor external cosmetic differences.
  • The family can include two or more versions built on one printed circuit board (PCB) design, with different frequency bands or technologies enabled by software.
  • It can include a new version of a certified product with minor PCB modifications that improve existing frequency bands or technologies, or add non-RF features.
  • All versions are identical, or differ only in ways permitted under Class I and Class III permissive changes (see below).

Two or more versions built on two or more PCB designs, with different frequency bands or technologies in identical enclosures, are not permitted in a family certification. Where the differences between versions would fall under Class II permissive changes, ISED approval for an exceptional circumstance must be submitted with the application.

The application must identify each version with at least one unique field (PMN, HVIN or FVIN), and include a detailed description of the hardware and software similarities and differences between versions (RF characteristics, circuit design, function, etc.), the HMN for modules assessed in a host, and the documents listed in ISED Form C.

Products sold together as a system. ISED no longer accepts different products sold together as a system (such as baby monitors or speaker systems) under a single family certification; each transmitter needs its own ISED Certification Number. The one legacy exception is telephone systems with a base unit and wireless handsets, which may share one certification and registration number. Even then, the base unit and the handsets must each have their own HVIN; only handsets that are identical to one another can share an HVIN.

Permissive changes

Any modification to a certified product may require recertification. Under RSP-100 section 10, the certificate holder must inform the CB or ISED of any change that may affect compliance with the technical requirements the product was originally certified against. RSP-100 groups permitted modifications into four classes:

Class What it covers Notice to ISED
Class I (C1PC) Changes that do not alter the fundamental RF characteristics or degrade unwanted emissions, and do not significantly change the product’s physical characteristics. This includes non-RF modifications. Not required, unless the HVIN or PMN also changes
Class II (C2PC) Hardware changes that affect the RF characteristics or unwanted emissions while still meeting the original standard’s requirements, significant physical changes, and any change to the PMN or HVIN. New frequency bands cannot be added through hardware changes. Required
Class III (C3PC) Firmware changes that affect the RF characteristics, including enabling frequency bands without hardware changes. A new, unique FVIN is required. Required
Class IV (C4PC) A certified module (MA or LMA) integrated into a new host product, where this changes the module’s original RF emission characteristics or RF exposure assessment. The HMN is required. Required

Multiple modules in one product. A final product that uses more than one stand-alone certified module capable of transmitting simultaneously qualifies as a Class I change only if all of the following conditions are met: the product is designed to be used at a distance of more than 20 cm; the modules were certified for stand-alone use; the sum of the Maximum Permissible Exposure (MPE) ratios of all simultaneously transmitting antennas is below 1.0 at 20 cm; and the final product meets all applicable standards. Otherwise, it falls under Class IV.

Filing a change. Under section 11, each class is filed through its own certification service. For all of these services, the product must comply with the latest issue of the applicable standards. Where no new testing is needed, the application must include a statement of compliance with the latest issue.

Multiple listings and transfers. Section 11 also covers two related services. A Multiple Listing of Certification lets the existing certificate holder or another company obtain a new ISED Certification Number based on an existing certification for an identical product, with authorization from the original certificate holder. A Transfer of Certifications moves certificates to a new owner: a full transfer (company takeover) keeps the existing ISED Certification Numbers, while a partial transfer (product line takeover) requires new ones.

Certification retention and audits

Compliance does not end at certification. Under RSP-100 section 12, certificate holders and all associated responsible parties (manufacturers, importers, distributors, and vendors) have a regulatory obligation to ensure the product continues to meet all applicable standards throughout its entire life cycle.

Post-certification audits. ISED and CBs conduct post-certification audits to ensure continuing compliance. When requested, the certificate holder must provide random product samples, at its own expense, for audit testing or for investigating radio interference.

Quality control. If ISED investigates possible non-compliance, the certificate holder will be asked to provide records of its quality control process and any other relevant information. Certificate holders should be able to demonstrate a quality control process for production inspection and testing that follows good engineering practices.

Remedial action. If ISED determines that a product is non-compliant, the certificate holder will be asked to provide satisfactory remedial action to bring the product back into compliance. If the certificate holder cannot be reached or does not respond, ISED will contact the other responsible parties (importers, distributors, and vendors) to take prompt and effective remedial action.

Reminder

Make sure ISED can always reach you or your ISED Canadian Representative. If an enquiry or audit request goes unanswered because contact details are out of date, a minor issue can turn into costly non-compliance.

Confidential information. Applicants must indicate which documents submitted for certification are confidential. Block diagrams, operational descriptions, parts lists and tune-up information, software-defined radio and security information, and schematic diagrams qualify for confidential treatment. ISED may consider other documents on request, with appropriate justification, before the application is submitted.

How Northern Certification can help you

RSP-100 is easier to navigate with an experienced partner. Northern Certification helps manufacturers bring radio products to the Canadian market, from first assessment to ongoing compliance:

  • Compliance strategy: confirming whether your product is Category I or Category II, which standards apply, and which certification service fits, whether a single product, a family, a permissive change, or a multiple listing.
  • Testing coordination: identifying data gaps and coordinating testing with appropriate laboratories.
  • Submission support: preparing a complete application package for an ISED-recognized Certification Body, and helping you resolve any issues the CB raises.
  • Expert Canadian representation: acting as your Canadian representative under section 4.1 for as long as your product is on the market. Compared to other providers, our representatives are experienced ISED certification specialists, well placed to respond to ISED enquiries quickly and accurately.

ISED certification

Get help with testing, the application package, and the CB submission for your radio product.

Get certification help

Canadian Representative letter

Get your attestation letter, backed by certification specialists.

Get a representative letter

Not sure which you need? Contact us and we’ll help you work it out.

Sources

This article is provided for general information and reflects our reading of RSP-100, Issue 12, as of the publication date. It is not legal or regulatory advice. ISED updates its standards and procedures from time to time, so always confirm requirements against the latest official ISED publications, or contact us for guidance on your specific product.

All articles