Selling wireless products on Amazon.ca: ISED certification and the Canadian Representative

Written by Koby Smutylo, lawyer (Law Society of Ontario, called 2001), ISED Canadian Representative since 2010. Last reviewed 9 September 2026.

The two questions a marketplace seller has to answer

The first is whether the product is certified for Canada at all. Search the Radio Equipment List by the IC number on the label or by the manufacturer's name. If it is not there, it may not be imported, distributed, offered for sale or sold in Canada, whatever its FCC or CE status, and a marketplace that asks for compliance information will not accept an FCC ID in place of an IC number.

The second is whether the certificate covers the product as you sell it. The REL records the PMN, the name or model number "under which the product will be marketed/offered for sale in Canada" (RSP-100). A private-label seller who lists a factory's certified device under its own brand and model name is selling something the register does not recognize by that name. The fix is either a permissive change filed by the certificate holder adding your PMN to its certification, or a multiple listing under RSP-100 section 11.5, which gives you your own certificate for the same design. The second route makes you the applicant, and if your address is outside Canada, requires a Canadian Representative.

Who needs the Canadian Representative

The requirement attaches to the applicant on the certification, not to the seller. Three common positions:

You resell a branded product the manufacturer certified. The manufacturer, or its Canadian subsidiary, holds the certificate and any representative appointment. You need nothing beyond a listing that matches the REL entry, and it is worth keeping a copy of the manufacturer's certificate in case Amazon or a customs broker asks.

You are a private-label seller and the factory certified the design in its own name. The factory is the certificate holder. Your brand name must be added to the certification as a PMN, by the factory through its CB, or you obtain a multiple listing. Sellers who skip this step are the ones whose listings get questioned when a marketplace or a customer compares the label against the REL.

You are the applicant. Your company, wherever it is, applied for the certification and holds the IC number. If your address is outside Canada you need a Canadian Representative for as long as the product is sold here, and the representative's letter should be in your compliance file alongside the certificate. See how to appoint a Canadian Representative.

What Amazon.ca asks for

Amazon.ca's seller help page on radio apparatus, interference-causing equipment and terminal equipment states that under the Radiocommunication Act these products "must meet applicable technical standards and, in some instances, be certified or registered", and directs sellers to submit compliance information for affected listings. Sellers in Amazon's own forums describe supplying the IC certification number and label images showing the IC number and HVIN. Amazon's requirements change and are not published by ISED, so treat the help page as the current statement and your certificate and REL entry as the evidence that satisfies it. A Canadian Representative letter is not something Amazon has asked sellers for in the reports we have seen; it is what ISED and your certification body require of a foreign applicant, and it is what a Canadian importer or distributor doing diligence on you will ask to see.

Labelling

The product, not just the listing, must carry the IC number and HVIN in the form RSS-Gen prescribes, and the user manual must carry the required notices in English and French. An imported batch labelled only with an FCC ID is a common reason for a Canadian customer to complain, and a label without the IC number is a compliance defect regardless of what the REL says. See the labelling notes under RSS-Gen Issue 6.

What we do for marketplace sellers

For a seller that is or will be the certificate holder, we act as Canadian Representative for US$499 per certified product, paid once, with the signed letter the same business day, and we hold the certificate, the letter and the ICES-003 report together so that one Canadian contact can answer ISED. For a seller that is not the holder, the honest answer is that you do not need us; check the REL, keep the certificate, and make sure the PMN matches your listing.

Do I need ISED certification to sell a Bluetooth product on Amazon.ca?

Yes. Bluetooth and Wi-Fi devices are Category I radio apparatus and must be certified and listed in the REL before they are offered for sale in Canada.

Does an Amazon seller need a Canadian Representative?

Only if the seller is the applicant that holds the ISED certification and its address is outside Canada. A reseller of a manufacturer-certified product does not.

Can I use the factory's IC number for my own brand?

Only if your brand and model name are recorded on that certification as a PMN, or you obtain a multiple listing in your own name. A label that shows the factory's IC number on a product the REL lists under a different name is a mismatch.

Is an FCC ID enough for Canada?

No. FCC certification does not transfer. The product needs its own ISED certification and IC number. See from FCC to ISED.

What documents should an Amazon.ca seller keep?

The ISED certificate, the REL printout, the RSS test report, the ICES-003 report if applicable, label artwork showing the IC number and HVIN, and, if you are the applicant, the Canadian Representative letter.