Canadian Representative for manufacturers in Japan
日本語の要約。 カナダ ISED（旧 Industry Canada）の RSP-100 第4.1条により、会社所在地がカナダ国外にある申請者は、IC認証（ISED 無線機器認証）を取得する際にカナダ代理人（Canadian Representative）を指定しなければなりません。当事務所はオタワのカナダ法律事務所 Smutylo Law+ で、2010年より海外メーカーのカナダ代理人を務めています。認証製品1件につき US$499（一回払い）。その製品がカナダ市場で販売されている間、代理人を継続して務めます。記載内容の変更（型番追加・訂正）は回数・期限の制限なく無料です。お支払い後当営業日内に署名済みの代理人証明書（PDF）を発行し、そのまま認証機関に提出いただけます。申込フォームは英語で、返信も英語で行います。日本語ページ · 申し込む
Japanese manufacturers need a Canadian Representative under RSP-100 section 4.1 because the applicant's company address is outside Canada. Testing can be done at an ISED-recognized laboratory in Japan; the certificate is issued by a body on ISED's recognized list, which today means North America, Europe or Singapore. Japanese regulatory teams typically want the full documentation set and a formal invoice before ordering, and want to know that the representative will still be in place for the whole, often very long, life of the product.
How certification usually runs from Japan
ISED recognizes wireless device testing laboratories in Japan, so RSS test data can be produced domestically.
The certification decision sits elsewhere. 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; Japanese-based certification bodies do not currently appear on it. In practice the certificate is issued by the North American CB the manufacturer already uses for its FCC programme, working from the Japanese test data, or by a European body where the EU file is leading. Confirm any proposed CB against ISED's current list by entity name, since some certification groups hold recognition through one national entity and not another.
The CB requests the applicant's ISED Company Number and the Canadian Representative letter as part of the ISED application. See the certification process overview.
Products that outlive their paperwork
The obligation in RSP-100 section 4.1 runs for as long as the certified product is offered on the Canadian market. For most consumer electronics that is a few years. For a Japanese industrial controller, medical imaging system, machine-tool component or automotive module it can be fifteen or twenty, and replacement units are often still supplied long after the original production run has ended.
That makes duration a real question rather than a formality, and Japanese regulatory teams raise it more often than any other market. An appointment carrying an expiry date is a liability over that span, because a renewal missed in year eleven is an obligation breached without anyone noticing. The harder question is whether the representative will still exist and still be reachable at the far end of the product's life, and that is a question about the provider rather than about the fee.
See how long must a Canadian Representative be appointed and why a lawyer as your Canadian Representative.
What we see from Japanese applicants
Documentation first. Japanese regulatory teams almost always ask for our terms, a sample letter and a formal invoice before placing an order — more consistently than any other market. All are available up front: terms of service, the letter structure at attestation letter required fields, and a pro-forma invoice on request. Asking for them does not commit you to anything.
Multiple certifications per programme. Products with several radios, or families certified separately by band, mean several IC numbers and several letters. Manufacturers with a steady certification flow usually put them on one consolidated invoice rather than paying letter by letter.
Entity naming. Use the English legal name on the corporate registration, rendering "Kabushiki Kaisha" as "Co., Ltd." or "Corporation" consistently with the CB's application and the eventual REL listing. Inconsistency between the application and the letter is the most common cause of a return.
Group structures. Where a Japanese group certifies through a US subsidiary, the applicant entity is the one that needs the representative. Tell us which entity will appear on the application before we draft.
Payment and timing
Card via Stripe in USD is immediate; wires from Japanese banks arrive in one to two banking days. A formal invoice in USD is provided, purchase orders are accepted, and several certifications can go on one invoice. Ottawa is thirteen hours behind Tokyo for most of the year, so an order placed during the Japanese working day is handled overnight Japan time and the letter is normally in your inbox the next morning. We correspond in English.
Audit samples
Shipped from Japan to ISED's laboratory in Canada at the applicant's cost, documented as a regulatory sample; we coordinate and can advise on the Canadian entry. See ISED audit samples.
Can a Japanese certification body issue our ISED certificate?
Japanese-based bodies do not currently appear on ISED's list of recognized certification bodies. Check the list by entity name before assuming a familiar certification group can issue from its Japanese office. Testing at an ISED-recognized Japanese laboratory is unaffected.
How long does our appointment last?
For as long as the product is offered on the Canadian market. The US$499 fee is paid once and there is no renewal date, so the appointment cannot lapse through a missed renewal. Once a year we ask you to confirm which products are still on sale in Canada.
What if your firm ceases to practise?
The appointment can be transferred to another representative and the change notified to ISED through your certification body. This is a question worth asking any prospective representative; see changing your Canadian Representative.
Do we need a separate letter for each radio in one product?
One letter covers one IC number. A product certified under a single IC number needs one letter regardless of how many radios it contains; separate IC numbers need separate letters.
Can we see the letter before paying?
We provide a sample letter showing the exact structure and wording. The signed letter naming your company issues after payment clears, the same business day.
Is there a charge to correct the letter after issue?
No. Corrections and additions under the same IC number — a model added, a company name or address amended, a letter reissued — are free, with no time limit and no cap on how many you request. Where a product family is later split into a second IC certification number, that 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).