Changing your Canadian Representative
To replace a Canadian Representative, appoint the new one, obtain its letter for the affected IC certification numbers, and notify the certification body that issued each certificate so it updates the record with ISED. Do it before the old appointment ends so there is no gap. A company rename under the same legal entity is a letter revision; a transfer of the certificate to a new legal entity is a CB process and the new holder needs its own appointment.
Replacing the representative
Reasons are usually one of: the previous representative has ceased trading or stopped responding; a distributor or lab relationship has ended; the applicant is consolidating several certifications under one representative; or the applicant wants a representative with a longer or more secure term.
The steps:
- List the IC certification numbers affected. If you do not have a register, your CB's records and ISED's Radio Equipment List will show the certifications held by your company.
- Order a letter from the new representative for each certification (one letter per IC number; see one representative letter per IC ID). Several certifications can go on a single invoice.
- Send the new letter to the CB that issued each certificate with a short notice that the Canadian Representative has changed effective the letter date. The CB updates its file and transmits the change to ISED.
- Notify the outgoing representative in writing that its appointment has ended, so there is no confusion if ISED contacts it.
There is no ISED fee for the change and no re-certification. CBs may charge an administrative fee for updating the record; most do not.
Avoiding a gap
RSP-100 section 4.1 requires a valid appointment at all times while the product is on the market. Appoint the new representative before terminating the old one. If the old representative has already disappeared, appoint the new one immediately and notify the CB; a prompt replacement is what ISED and the CB will want to see.
Company rename, same legal entity
If your company changes its name but remains the same legal person (same registration number, same incorporation), the certificate holder has not changed. Ask us to reissue the letter in the new name through the revision form and notify the CB of the rename with the corporate document evidencing it. The CB updates the holder's name on the certificate and REL listing.
Transfer of the certificate to a new holder
If the product line is sold, or a reorganisation moves the certificate to a different legal entity (a new subsidiary, an acquirer), the certificate holder changes. That is a transfer under RSP-100's provisions for modification of certification information, handled by the CB with documentation from both the old and new holders. The new holder is a new applicant for section 4.1 purposes and needs its own Canadian Representative appointment and letter. The old holder's appointment does not carry over. We see this mistaken for a rename regularly; see the example in case examples.
Moving to a Canadian entity
If you establish a Canadian subsidiary with a real place of business and transfer the certificate to it, the requirement for a separate Canadian Representative falls away, because the applicant is now in Canada. The transfer is still a CB process.
What we do when we are the outgoing representative
If you move away from us, tell us and we confirm the end date in writing to you and, on request, to your CB. We do not charge for withdrawal and we do not hold records hostage.
Sources. RSP-100, Issue 12, section 4.1 (requirement and continuity), section 10 (modification of certified products), section 11 (certification services applications).
Do I have to tell ISED directly?
No. The CB that issued the certificate updates the record and transmits the change to ISED. If the CB no longer exists, contact ISED's Certification and Engineering Bureau for direction.
Can the new representative's letter cover all my certifications in one document?
It can, but CBs file by certification, so one letter per IC number is cleaner and is what we issue.
Is there a deadline to appoint a replacement?
No stated period. The requirement is continuous, so the answer is "immediately."