Canadian Representative for manufacturers in the United States

Written by Koby Smutylo, lawyer (Law Society of Ontario, called 2001), ISED Canadian Representative since 2010. Last reviewed 27 August 2026.

How certification usually runs from the US

The United States is the best-served country on ISED's list of recognized certification bodies by a wide margin: of the bodies ISED currently recognizes to certify equipment to Canadian requirements, roughly twenty are US-based, against a handful in Canada and a scattering in Europe and Singapore. Most of the TCBs a US manufacturer already uses for FCC work are on that list.

That means the practical workflow is simple. One test campaign at a US laboratory produces data for both regulators; the TCB issues the FCC grant and the ISED certificate from the same file. The only additional inputs on the Canadian side are an ISED Company Number for the applicant and the Canadian Representative letter. The TCB asks for both as part of the ISED application, and that request is usually the moment a US regulatory manager first hears the words "Canadian Representative." See from FCC to ISED and the certification process overview.

The four things US applicants say

"Our TCB handles Canada." It handles the certification. It is not your representative. The two roles are separate and the TCB will tell you so when it asks for the letter. See representative vs certification body vs test lab.

"Our Canadian distributor can sign." It can, if it has a real Canadian place of business and accepts in writing the duty to respond to ISED and provide audit samples for as long as the product is sold in Canada. In our experience distributors often decline once they read the obligation, and an appointment tied to a distribution agreement tends to lapse the moment that agreement ends — which is a problem, because the certificate does not lapse with it.

"We have a Canadian subsidiary." If the subsidiary is the applicant on the ISED application and has a genuine place of business in Canada, no separate representative is needed. If the US parent is the applicant, one is. The test is the address of the applicant entity, not the corporate group.

"We'll deal with it at launch." The letter is an input to certification, not to sale. A file waits at the CB until the letter arrives, so ordering it at application rather than at launch is the difference between no delay and a week of one.

What we see from US applicants

Startups and non-RF companies. Hardware startups, and companies whose product simply happens to contain a radio — beverage dispensers, fitness equipment, appliances, medical devices — hit this requirement late, because nobody on the team thinks of themselves as an RF company. Bevi, a Boston maker of connected beverage dispensers, is an example; see clients.

Module makers. A US module maker needs a representative for each module certification it holds; the integrators designing that module in do not need one for the module. See one representative letter per IC ID.

Large certification programmes. Companies certifying several products a year, or families split by band, usually batch them onto one consolidated invoice rather than paying letter by letter.

Procurement. US corporate procurement generally requires a vendor form and a W-8BEN-E for a foreign supplier; we provide both without being asked twice. Purchase orders are accepted, and several certifications can go on one invoice.

Payment and timing

Card via Stripe is immediate. ACH and wire are accepted. We are in Ottawa on Eastern Time, so an order placed in the morning from the East Coast, or before early afternoon from the West Coast, is normally fulfilled the same day — the only country page on this site where "same business day" means the same working day you are having.

Audit samples

If ISED asks for a sample, it ships from the US to ISED's laboratory in Canada at the applicant's cost, documented as a regulatory sample. We coordinate and can advise on the customs entry. Because section 4.1 places that duty on the representative for the life of the product in Canada, the durability of the appointment matters more than its price; see how long must a Canadian Representative be appointed.

Our TCB is recognized by ISED. Do we still need a Canadian Representative?

Yes. Recognition under the Canada-US MRA lets the TCB issue the certificate. It says nothing about who represents the applicant in Canada. Section 4.1 turns on the applicant's company address.

Is the Canadian Representative the same as an importer of record?

No. The representative does not take title to goods, does not clear customs and is not liable for duties. It responds to ISED enquiries about the certified product and provides audit samples.

Can our US regulatory consultant act as our Canadian Representative?

Only if it has a Canadian place of business. A US address does not satisfy section 4.1, whatever the consultant's experience with Canadian files.

We already have an ISED Company Number. Is that enough?

No. The Company Number identifies the applicant to ISED; it does not appoint anyone in Canada. Both are required at application.

How fast can we get the letter?

Same business day once payment clears, in the same time zone as your East Coast team. There is no expedite fee because there is no slower option.

We split a family across several certifications. Are letter changes billed?

Changes within one certification are not. Adding models or HVINs under an existing IC number, correcting the applicant's details, or reissuing a letter is free, with no time limit and no cap on how many. Each separate IC certification number, including the band-split variants US applicants often end up with, is its own certification at US$499.