Canadian Representative for manufacturers in China
中文摘要。 根据加拿大 ISED（原 Industry Canada）RSP-100 第 4.1 条，公司地址在加拿大境外的申请人在办理 IC 认证（ISED 无线设备认证）时，必须指定一名加拿大代表（Canadian Representative）。我们是位于渥太华的加拿大律师事务所 Smutylo Law+，自 2010 年起为境外制造商担任加拿大代表：每件认证产品 499 美元，一次付费，只要该产品仍在加拿大市场销售，代表关系即持续有效；修改一律免费，不限次数与期限；付款后当个工作日内签发签字代表函（PDF），可直接提交给您的认证机构。申请表为英文，我们以英文回复。中文版网站 · 立即申请
Chinese manufacturers are the largest group of applicants needing a Canadian Representative under RSP-100 section 4.1. Testing is normally done at an ISED-recognized laboratory in Shenzhen, Shanghai, Dongguan or Suzhou; the certificate itself is issued elsewhere, because ISED does not currently recognize any certification body in mainland China. Order in the Chinese evening, pay by card in USD, and the signed letter is normally issued before your next working day begins.
How certification usually runs from China
The split that catches Chinese applicants out is between the laboratory and the certification body. ISED recognizes wireless device testing laboratories in mainland China, so RSS test data is produced locally and the testing half of the file never leaves the country.
The certification decision is different. ISED's published list of recognized certification bodies covers bodies in Canada, the United States, Germany, Spain, the United Kingdom, the Netherlands, Austria and Singapore. Mainland China is not on it, and neither is Hong Kong. In practice your lab submits the file to a Canadian CB or, far more often, to a recognized CB in the United States. Several CB groups with a large Chinese testing presence hold their ISED recognition through a North American entity rather than the Asian one, which is why the certificate can carry a US address even when every other document in the file is Chinese.
The CB asks for the applicant's ISED Company Number and the Canadian Representative letter as part of the application. Check ISED's current list if your lab proposes a CB you have not used before.
Which entity is the applicant
More letters are redrafted for Chinese applicants over this question than any other, because a Chinese supply chain routinely involves three or four companies with a plausible claim to the product.
The applicant is whichever entity is named on the ISED application, and that is settled when the certification file is opened rather than afterwards. It is often a Hong Kong or BVI holding company rather than the Guangdong factory that builds the device. Where a Shenzhen ODM certifies in its own name and a Western brand sells under its own label, the ODM is the applicant and the ODM needs the representative; where the brand certifies in its own name, the brand does. One of the two, never both.
The consequence runs past the paperwork. An appointment is personal to the applicant named in the order, so if the certificate later moves from the holding company to the factory entity, that is a transfer rather than a rename and the new holder needs its own appointment. See changing your Canadian Representative.
What we see from Chinese applicants
Legal name in English. The applicant name on the letter must match the English legal name on the application and the REL listing, and that should match the name on the business licence translation your lab is using. "Shenzhen XYZ Technology Co., Ltd." in one place and "Shenzhen XYZ Tech Ltd" in another causes a CB return and costs a day. Send us the exact string your lab has. See attestation letter required fields.
Labs ordering for clients. Many Chinese labs order the letter on the client's behalf as part of a turnkey FCC/ISED package. We issue the letter naming the client as applicant; the lab can settle several certifications on one invoice and bill its own clients.
Modules. Most Chinese consumer devices integrate certified Wi-Fi and BLE modules from Chinese module makers. The module maker needs the representative for the module certification; the device maker needs one only for certifications it holds itself. See one representative letter per IC ID and RF modules.
Volume and timing pressure. Chinese certification programmes run to tight launch windows and the representative letter is often the last item anyone thinks of. It is an input to certification, so order it at application rather than when the CB chases you for it.
Payment and timing
Card payment through Stripe in USD works with UnionPay co-branded Visa and Mastercard and with most corporate cards; it is the fastest route. Wires in USD are accepted and typically arrive in two to three banking days. We invoice in USD and a formal invoice is available for your finance department.
Ottawa is twelve hours behind Beijing for most of the year, which works well: orders submitted in the Chinese afternoon or evening are processed during the Ottawa business day and the letter is usually in your inbox when you start the next morning. We correspond in English; Chinese-language enquiries are welcome and we reply in English.
Audit samples from China
If ISED requests a sample, you ship from production stock to ISED's laboratory in Canada, as a regulatory sample rather than a commercial import, at your cost. We coordinate and can advise on the Canadian customs paperwork. The duty to provide the sample sits with the representative under section 4.1, which is the reason to hold the appointment with a firm that will still be reachable years after certification. See ISED audit samples and why a lawyer as your Canadian Representative.
Can a Chinese certification body issue our ISED certificate?
Not currently. ISED's list of recognized certification bodies does not include any body in mainland China or Hong Kong, so the certificate is issued by a CB in Canada, the United States or Europe. Testing can still be done at an ISED-recognized laboratory in China.
Our lab says it will "handle everything including Canada". Is the letter included?
Ask specifically. Labs handle testing and manage the CB relationship; the Canadian Representative is a separate appointment that the applicant makes. Many labs order it from us on the client's behalf, but it is not automatically part of a test quotation.
The applicant is our Hong Kong company. Does that change anything?
No. Hong Kong is outside Canada for the purposes of section 4.1, so a Hong Kong applicant needs a Canadian Representative on the same terms.
Do we need a new letter for each model?
No. One letter covers one IC number, including every model listed under it. Adding models by permissive change does not need a new letter; a new IC number does.
Can we pay in RMB?
We invoice and are paid in USD. Card payment in USD through Stripe is the route most Chinese clients use; wires in USD are also accepted.
Our lab orders the letter for us. Can it also request corrections later?
Yes, and there is no charge for them. A corrected legal name, an added model under the same IC number, or a reissued letter costs nothing, with no time limit and no cap on how many corrections you need — a practical point when the applicant name has to match the CB's records exactly. A new IC certification number is a separate certification at US$499.
Sources. RSP-100, Issue 12, section 4.1. ISED Certification Bodies and Wireless Device Testing Laboratories (check current status).