International Type Approvals
Worldwide Type Approval Overview
To give an overview of the requirements for worldwide regulatory type approval it is important to understand that each country will have its own specific requirements. Let’s start with describing what information is required to obtain requirements about a specific country.
Requirements to obtain a quote
In order to provide an accurate quote we require a minimum of a data sheet that lists all technologies, power supplies and a brief description of what the product does. In some cases we may have specific follow up questions regarding power output, frequency specifications, etc. Or we may just ask for a test report. We will also require the HS Code (Harmonized Code) for many different countries. We use this code to confirm if approval or what type of approval is required. As an example in countries such as China this will help determine if CCC approval is required in addition to SRRC approval.
In Russia this may help determine if the Custom Union Certificate is applicable.
Testing requirements
While many of the basic requirements are the same from country to country there
are some variants required for each country. There may be many different
requirements between countries there are 2 important differences that stand out.
Is in-country testing required or do they accepting foreign test reports?
In country testing
Many times when a manufacturer is going to obtain type approval in multiple
countries they are surprised when they have to do the same exact test in several
different countries. An example is if you are applying for approval in Brazil, China
and Indonesia you will be required to send a sample(s) to each of these countries for
testing in an authorized lab. In each country you may find that they perform the same
basic test. While this appears redundant and repetitive to the manufacturer countries,
such as those listed above, do not accept foreign test reports and the required in country testing is a part of the process that cannot be bypassed.
While each country will perform many of the same tests in many cases they may have additional test requirements specific to their country. It is important to understand the entire spectrum of tests to be performed before samples are sent so that the manufacturer can anticipate and perform pre-testing when possible to assure a smooth and expeditious testing process once the sample reaches the foreign test lab.
In the event that there are testing issues we first try to resolve these by sending the specific test failure reports or questions to the manufacturer. Should that fail to resolve the testing issues in an expedient manner then other forms of communication are utilized. These could include, but are not limited to, phone calls, Skype conference or an in person visit by the manufacturer's engineer to the test lab.
Depending on the test requirements and the EUT (Equipment Under Test) there are two different testing configurations for the EUT, Conducted testing and Radiated testing. In some cases one sample of each is required. Typically if conducted testing is required the manufacturer is required to solder leads to the PCB at the antenna connection and have the leads extended out of the product. Foreign test labs will not disassemble any EUTs at the lab. The sample configuration must be completed prior to shipping samples to the labs.
Testing software, and in many cases normal operating software, must be included with the samples. Typical testing software requirements include the set up instructions and the necessary software/firmware for testing similar to the requirements for conducted testing on FCC part 15. The most common testing requirements are:
Continuous transmission: In the case of half duplex transmission it should be possible to transmit continually without a response being necessary.
The equipment should allow them to set up the frequency channel, the output power, the data transfer rate, the carrier mode (transmit un-modulated carrier, modulated carrier (random carrier).
New samples are best as in some countries used samples are stopped in customs. After testing, in most cases, the samples are returned to the manufacturer. Samples may be imported under a temporary importation for testing purposes only and must be exported soon after testing. This avoids high import taxes and duties. Under temporary importation you have a limited time period in the country. Usually this is 90 to 120 days. This is one of the reasons to make sure the samples will pass the required testing before importation. If there are extensive testing issues that cause the samples to be in the country past the temporary importation time limit samples will have to be exported and then imported again. We have not had this happen before but it is important for the manufacturer to be aware of this requirement.
Foreign Test reports
While the statement that a country accepts foreign test reports seems clear it is important to understand how this is interpreted in each country.
Some countries take the FCC or CE test reports and transfer technical information from them to an application specific for their country. They do not submit the actual test reports.
Other countries will submit the actual test report along with the certificate or grant. Some manufacturers will perform FCC approvals but not go the extra step and obtain the FCC grant as in many cases for their purposes it is not required. CSIA always recommends that when obtaining the FCC testing you obtain the grant as it is required in addition to the test reports in many cases for international approvals. In the case of the CE certificate we recommend that the manufacture obtain CB approval at the same time. While not all countries will require the CB certificate in many instances it is part of the requirements so if you have both CE and CB certificates you are covered in most countries that accept foreign test reports.
While some countries say they accept both FCC and CE test reports depending on the EUT, and whether you are have obtained FCC or CE certificates, some requirements could still be missing. In countries such as Nicaragua and Venezuela the standard FCC test report is acceptable. Typically testing to Part 15, etc. But when you go to a country such as South Africa or Belarus they could require test standards that are specific to a CE test report that may not be required for FCC testing.
In-country legal entity to hold the certificate
What is an in-country legal certificate holder? Many countries allow
the certificate to be issued in the name of a foreign manufacturer.
But there are those countries that require the certificate be issued in
the name of a legal entity, an individual or a company, which has an
address in the country and is registered or affiliated with a specific
organization. Countries such as Azerbaijan, Brazil, Cambodia, Gambia,
Oman, etc. require an in-country certificate holder.
In many cases the manufacturer has a branch office or a distributor
that can fulfill this requirement. In the event that the manufacturer
does not have an in-country certificate holder available we can provide
this service. Depending on the length the certificate is valid for this
service would have to be renewed when the certificate comes due for
renewal. Using this service of hiring an in-country certificate holder does
not impact importation or marketing of the product. As an example in countries such as Australia it is important to have an agent hold the certificate, (in the case of Australia it is called a Compliance Folder), instead of the distributor. If you have distributors, every distributor must have a compliance folder so you would pay the fee for each distributor. If you had 8 distributors you would pay the fee 8 times for 8 compliance folders. If you have an agent holding the compliance folder then you only have to have one compliance folder and you can have as many distributors as you want. This allows for more commercial freedom. Example: if you have a distributor and you or they decide not to continue the relationship you would need to find another distributor and go through the compliance process with them. If you have an agent and decide to go to a new distributor there is no compliance process required just notify your agent.
In country legal representative
This is different than an in country legal certificate holder. While an in country legal certificate holders responsibility and purpose is to be the holder of the certificate, or in other words the certificate is issued in their name, the in country legal representative in most cases fulfills a requirement by certain countries that a legal resident of that country be the one who submits the actual application for approval. In most of these cases the certificate can still be issued in the name of a foreign manufacturer. In the event that the manufacture does not have an in-country certificate holder available we can provide this service. Typically when CSIA provides this service we require an LoA from the manufacturer so that our local agent can represent your company for presenting the application to the local regulatory agency.
Separate safety approval requirements
Many manufacturers are aware of the Telecom regulatory requirements but
may not know that separate safety approvals may also be required. In some
cases this is offered by the same agency that regulates the telecom approvals
but in some countries you will be required to go to a separate agency. The
requirement for this separate safety approval is determined by several different
standards.
In Russia a EAEU approval is required if the product operates on over
50VAC or 75VDC. Because of the agreement between several different
countries this certificate is valid in Russia, Armenia, Belarus and Kazakhstan.
This is good for safety only. Each country's specific telecom approval is still
required if the product falls into that category so you would still need to obtain
a separate telecom approval for each of these countries.
For Argentina (CNC) the threshold is 50V and in Mexico (NOM NYCE) it is 24V. South Africa requires SABS approval for any device with an electrical component and any device that plugs into the mains requires an additional NRCS approval. If telecom (ICASA) approval is also required this may take the place of SABS safety requirements in South Africa.
Similar to Telecom regulatory approvals the EUT could require in-country testing and in-country certificate holder or in some cases we can leverage CE or UL test reports and the manufacturer can hold the certificate. A list of “base” documents similar to what is required for Telecom approval also needs to be submitted.
These safety approvals may have their own marking requirement in addition to the Telecom marking requirement.
It is also important to note that many countries will require a specific plug configuration. Many times it can be easier to buy an already approved and configured power supply. That is a decision the manufacturer needs to make after weighing all the facts.
Just as with Telecom certificates many Safety certificates have different expiration dates and may require renewal every few years.
Other requirements (documents, authorization letters, etc.)
Most of the projects will require the same “base” document list. User guide (A copy translated into the native language may be required.), interior and exterior pictures, a close up picture of the label showing the model number, data sheet or sales brochure, manufacturer and factory information, factory inspection certificate, schematics, block diagram with descriptions, BOM, authorization letters, Make and Model you want to see on the certificate, test reports and grants as required. All documents must reflect the same model number as the one you want to see on the certificate.
Note that we are aware the manufacturer is very sensitive to providing schematics, block diagrams and BOM. In most cases these are considered to be proprietary. However in many countries these are required or they will not issue an approval. We are happy to sign NDA’s with all clients and the agencies will not give this information out to anyone. Some countries do not require these 3 proprietary documents but you should be prepared to provide them.
In addition to this “base” list there may be country specific requirements that will vary. As an example in Paraguay the Authorization letter has an unusual requirement. The PoA must be signed by the manufacturer. Then the PoA must be notarized to verify this signature. Next this document must be presented to the Secretary of State to have them notarize the notary signature. Next the document must be presented to the closest Paraguayan consulate for a final signature. The original is then sent via Fed-Ex to Paraguay.
We provide a document list at the start of the project. In most cases this document list will suffice to obtain the approval. But we ask that our clients be prepared as the project progresses as the agency reviews the information and in some cases they may come back and ask for clarification or other additional documents.
Regarding samples we also notify the client of the number and configuration required. As noted above during the discussion of sample configuration these samples must be new not used or they will more than likely never make it into the country. In most cases the manufacturer is responsible for shipping the samples into the country although we assist with shipping information and if needed in most cases we can provide contact information for shipping companies if required. In certain situations we will request the samples be sent to our offices and we will import the EUT into the country. The client will still be responsible for the importation cost.
Factory Inspections
The manufacturer should be aware that some countries require proof that
the factory where the product is being produced has been inspected.
These inspection certificates must be current. We have all heard of
ISO 9001. This is a common verification process. But some countries
require a different inspection scheme.
In Brazil they require this certificate be presented in the original format
as well as translated into Portuguese in the format of a “sworn translation”.
This official translation or "sworn translation" is a translation that has to be
done by specific professionals that are authorized by Brazilian government.
But there are different inspection schemes that may be required. One
example is CIG023. This is required for products that are seeking Argentina
safety approval. Another example of a country that requires CIG023 is
Belarus. If a factory is not being inspected or the certification is not current
then an inspection of the factory is required. There are many inspectors that
do nothing but travel around to perform these inspections. Typically the manufacturer would be required to pay for the inspection, meals, transportation,
lodging, etc. A large percentage of the products in the world are produced in China and as you can imagine they have many factories.
Many of these factories produce a multitude of products for several different manufacturers. So even if you have not specifically asked for a CIG023 inspection of this factory for your specific product there is a good chance that the factory is already being inspected to CIG023 at the request of a different manufacturer. In this case you can use that certificate.
For approvals in China, they have a different type of approval scheme. This is called CQC. CQC factory inspection lead time varies from 3 months to 6 months depending on the inspection findings. The factory must be inspected for a specific type of product. While it may have been inspected for Audio/Video Products if you have Mobile radio products that inspection would not apply and an inspection for Mobile radio products would need to be conducted.
Renewals
Telecom and Safety certificates have different expiration dates depending on the country. This can vary from a valid certificate length of one year to the life of the product.
As an example in Brazil ANATEL places products into one of 3 Categories. Category 1, 2 or 3. Category 1 requires a renewal each year. Category 2 requires a renewal every 2 years and Category 3 does not require a renewal.
Russia issues EAEU Declarations and Certificates valid for 1-5 years. Telecom Declarations are valid for as long as the manufacturer wants as long as no product changes occur. The Telecom Certificates are valid for 1-5 years.
In Mexico products that operate outside 900 MHz, 2.4 GHZ and 5.0 GHz, will be issued a
temporary certificate the first year and then the manufacture can apply for a permanent certificate the following year. Products that fall into the (900-928MHz, 2.4GHz and 5.0GHz) will utilize a different certification process.
The requirements for the actual renewal depend on the country and EUT. In some cases even though in-country testing was required for the initial approval we can obtain a renewal with paper work only. In other cases re-testing at every renewal is required. Many countries require a sample from the warehouse of the distributor so that they can be sure they are testing a sample from inventory that is being sold in their country. You may have heard this referred to as Market Surveillance.
Typically when you renew the certificate if you have obtained certificate holder service it also will require renewal at this time.
We notify our clients of renewal requirements with enough time to decide if they want to proceed or let the certificate expire. As we all know in today’s ever changing world, technology has a short shelf life.
In summary CSIA is your international equipment type approval company with nearly two decades of experience navigating the global regulatory compliance landscape.