Canadian Representative for manufacturers in Germany and the European Union
Zusammenfassung auf Deutsch. Nach RSP-100 Abs. 4.1 der kanadischen Behörde ISED (früher Industry Canada) muss jeder Antragsteller mit Firmensitz außerhalb Kanadas für die IC-Zertifizierung (ISED-Funkzulassung) einen kanadischen Vertreter (Canadian Representative) benennen. Wir sind die Anwaltskanzlei Smutylo Law+ in Ottawa und übernehmen diese Rolle seit 2010 für ausländische Hersteller: US$ 499 je zertifiziertem Produkt, einmalig – wir bleiben Ihr kanadischer Vertreter, solange das Produkt auf dem kanadischen Markt angeboten wird; Änderungen des Schreibens sind unbegrenzt und kostenlos; unterzeichnetes Bestätigungsschreiben (PDF) am selben Werktag nach Zahlungseingang, direkt an Ihre Zertifizierungsstelle weiterleitbar. Das Formular ist auf Englisch; wir antworten auf Englisch. Deutsche Seite · Jetzt anfordern
German and other EU manufacturers can have the ISED certificate issued by a European certification body recognized under the Canada-EU mutual recognition arrangement, and still need a Canadian Representative under RSP-100 section 4.1. The role is not the EU authorised representative under the Radio Equipment Directive wearing a different hat. It is narrower, ISED-specific, held at a Canadian address, and it lasts for as long as the product is offered on the Canadian market.
How certification usually runs from Germany
Europe is the second-best-served region on ISED's list of recognized certification bodies, after North America. The current list includes three German bodies, two in Spain, one in the Netherlands and one in Austria, alongside the Canadian, US, UK and Singapore entries. German manufacturers therefore have a genuine domestic route: test at a German or European laboratory recognized by ISED, and have a recognized European body issue the certificate.
The alternative — and the more common route for manufacturers whose US programme is already running — is to let the North American CB handling the FCC file issue the ISED certificate from the same test data. Either way, the CB asks for the applicant's ISED Company Number and the Canadian Representative letter before issuing. Confirm your CB's recognition on ISED's current list; recognitions carry expiry dates and are renewed on a rolling basis.
Canadian Representative versus EU authorised representative
German regulatory departments are the most likely of any market to assume these are the same species of obligation, because the RED's Article 11 authorised representative is the role they administer every day. They are not the same, and the differences matter for the technical file.
The RED authorised representative acts for a non-EU manufacturer in respect of EU conformity obligations: it holds the EU declaration of conformity and technical documentation and is the contact point for EU market surveillance authorities.
The ISED Canadian Representative acts for a non-Canadian applicant in respect of a specific ISED certification: it responds to ISED enquiries about that certified product and provides audit samples at no charge to ISED. It does not hold your technical documentation, it is not a market surveillance contact, and it is appointed per certification rather than per product placed on the market.
A German manufacturer selling into Canada needs the Canadian one. Recording the wrong role in the technical file, or naming the EU authorised representative on the ISED application, is a predictable source of CB returns. See the requirement explained.
What we see from German and EU applicants
Industrial and automotive applicants. German applicants skew to industrial automation, metering, automotive tier-one suppliers and medical devices — products with long service lives and formal change control, where a certificate issued today may still be live in a decade. The appointment has to last as long as the product is sold in Canada; see how long must a Canadian Representative be appointed. Kamstrup, a Danish metering manufacturer, is an example of the category; see clients.
Entity naming. Use the legal form exactly as registered — GmbH, AG, SE, GmbH & Co. KG — matching the CB's application. German legal forms are frequently abbreviated inconsistently between the commercial register extract and the certification paperwork, and the CB will return the file.
Change control. Manufacturers with formal ECR/ECO processes ask what happens to the appointment on a permissive change. Nothing: a permissive change adds models under the existing IC number and the existing letter continues to cover them. A new IC number needs a new letter. See one representative letter per IC ID.
Data protection. Our handling of personal data is set out in the privacy policy. We hold only the contact details needed to operate the appointment, under Canada's PIPEDA, and our payment and form processors are named there — the question German procurement asks first.
Procurement. Supplier onboarding forms and a pro-forma invoice are provided on request; purchase orders are accepted, and several certifications can go on one invoice.
Payment and timing
Card via Stripe in USD is immediate. SEPA is not available for USD invoices, but wires from EU banks arrive in one to two banking days. We invoice in USD. The six-hour difference means an order placed in the German morning is processed early in the Ottawa day and the letter is normally issued by the German afternoon.
Audit samples
Shipped from the EU to ISED's laboratory in Canada at the applicant's cost, documented as a regulatory sample; we coordinate. See ISED audit samples.
Is the Canadian Representative the same as our EU authorised representative?
No. The RED authorised representative covers EU conformity obligations and holds your technical documentation. The Canadian Representative answers ISED enquiries about a specific certification and provides audit samples, from an address in Canada.
Our certification body is in Germany. Do we still need one?
Yes. Recognition of the CB under the Canada-EU MRA lets it issue the certificate. Section 4.1 turns on the applicant's company address, not the CB's.
Can our German parent appoint one representative for the whole group?
The appointment names the applicant entity on the ISED application. If several group entities hold certifications in their own names, each needs the representative for its own certifications. Several certifications for one applicant can go on a single invoice.
Does a permissive change require a new letter?
No. Models added under an existing IC number are covered by the existing letter. A new IC number requires a new one.
What happens if we stop selling the product in Canada?
The obligation runs while the product is offered on the Canadian market. Tell us when a product is withdrawn and we will close the appointment for that certification.
Our group entity names change. Does a corrected letter cost anything?
No. A corrected applicant name or address, an added model under the same IC number, or a reissued letter is free, with no time limit and no cap on how many you request. Where certifications move between group entities, note that the appointment is personal to the applicant named in the order and a transfer needs a new appointment; see the entity question above. A new IC certification number is a separate certification at US$499.
Sources. RSP-100, Issue 12, section 4.1. ISED Certification Bodies recognized under the Canada-EU MRA (check current status). Directive 2014/53/EU (RED), Article 11.