Canadian Representative for manufacturers in Taiwan
中文摘要。 依據加拿大 ISED(前身為 Industry Canada)RSP-100 第 4.1 條,公司地址位於加拿大境外的申請人辦理 IC 認證(ISED 無線設備認證)時,必須指定一名加拿大代表(Canadian Representative)。我們是位於渥太華的加拿大律師事務所 Smutylo Law+,自 2010 年起為境外製造商擔任加拿大代表:每件認證產品 499 美元,一次付費,只要該產品仍在加拿大市場銷售,代表關係即持續有效;修改一律免費,不限次數與期限;付款後當個工作日簽發簽署代表函(PDF),可直接提交給您的認證機構。申請表為英文,我們以英文回覆。繁體中文網站 · 立即申請
Taiwanese manufacturers need a Canadian Representative under RSP-100 section 4.1 because the applicant is outside Canada, and that holds however the file is routed. Testing is done at an ISED-recognized laboratory in Taiwan; the certificate is issued by a body on ISED's recognized list, which today means a body in North America, Europe or Singapore. Taiwan's ODM and module industries produce a particular pattern of who needs the letter, and it is not always the company whose name is on the box.
How certification usually runs from Taiwan
Taiwan's laboratories handle a very large share of the world's FCC and ISED test volume, and ISED recognizes Taiwanese wireless device testing laboratories, so the testing half of a Canadian file is routinely completed in Hsinchu or Taoyuan.
Where the certificate comes from is worth being precise about, because it is commonly described loosely. 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. Certification bodies based in Taiwan do not currently appear on it. What does appear is the North American arm of at least one major Taiwanese certification group — recognition sits with the US entity rather than the Taiwanese parent.
The practical effect for a Taiwanese manufacturer is usually invisible: you deal with the same familiar group, test locally, and the certificate issues under that group's recognized entity. But it matters when someone asks whether the file can be completed without leaving Taiwan, and it matters when you are checking a proposed CB against ISED's list. Check the list by entity name, not by brand.
Either way, the CB asks for the applicant's ISED Company Number and the Canadian Representative letter before it will issue.
When the ODM certifies and the brand sells
Taiwan's ODM industry produces a pattern that catches out anyone used to Western supply chains: the company whose name is on the box is frequently not the applicant on the ISED file.
Where the ODM holds the certification in its own name, which is the usual arrangement for products built to a customer's specification, the ODM is the applicant and the ODM needs the representative. The brand owner needs nothing for that certification. Where the brand certifies in its own name instead, the position reverses. It is never both, and the answer turns on whose name goes on the application rather than whose logo goes on the product.
The arrangement sometimes changes mid-life, when a brand owner takes over a certification it originally obtained through its ODM. That is a transfer of the certificate rather than a change of name, and the new holder needs its own appointment. See changing your Canadian Representative.
What we see from Taiwanese applicants
Module makers. Taiwan is a major source of Wi-Fi, Bluetooth and cellular modules used worldwide. Each module certification needs its own representative letter from the module maker, and the dozens of integrators downstream need nothing for that module. Module makers with many products usually settle several certifications on one invoice; see RF modules.
Legal names. Use the English legal name from the company registration exactly as your CB uses it. "Co., Ltd." against "Corp." is the usual cause of a CB return, and it costs a day at the worst possible point in the schedule. See attestation letter required fields.
Tight launch schedules. Taiwanese CBs move quickly and the representative letter should not be the last item on the list. Order at application, not at issue.
Multiple radios, multiple certifications. Devices with several radios, or families split by band, mean several IC numbers and several letters. One letter covers one IC number and every model under it; see one representative letter per IC ID.
Payment and timing
Card payment via Stripe in USD is immediate; wires from Taiwanese banks typically arrive in two banking days. Ottawa is twelve hours behind Taipei for most of the year, so an order submitted during the Taiwanese working day is processed overnight Taiwan time and the letter is normally in your inbox the next morning. We correspond in English.
Audit samples
Samples ship from Taiwan 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. Section 4.1 places that duty on the representative for as long as the product is offered on the Canadian market. See ISED audit samples.
Can a Taiwanese certification body issue our ISED certificate?
Check ISED's current list of recognized certification bodies by entity name before assuming so. Taiwanese-based bodies do not currently appear on it, although the North American entity of at least one major Taiwanese group does. Your testing can be done at an ISED-recognized laboratory in Taiwan either way.
We are the ODM. Does our customer need the representative, or do we?
Whoever is the applicant on the ISED application. If the certification is in the ODM's name, the ODM needs it. If the brand certifies in its own name, the brand does. Not both.
Our module is certified. Do our customers need their own letters?
Not for your module. An integrator designing in a certified module relies on your certification for that module. It needs a representative only for certifications held in its own name.
Does the letter expire?
The appointment runs for as long as the certified product is offered on the Canadian market. The US$499 fee is paid once and there is no renewal date.
Can we order before we have the IC number?
Yes. We need the applicant's exact legal name and address and the ISED Company Number; the IC number can follow. Ordering at application is the point.
We add models to a certified module all the time. Does each one cost?
No. Model and HVIN additions under an existing IC number are revisions, and revisions are free however many you ask for and however long after issue. That is the ordinary pattern for a Taiwanese module maker whose customer list keeps growing. What is not a revision is a second IC certification number, which is a separate certification with its own letter at US$499.
Sources. RSP-100, Issue 12, section 4.1. ISED Certification Bodies and Wireless Device Testing Laboratories (check current status).