Do you need a Canadian Representative for ICES-003 SDoC?
No. Equipment that complies with ICES-003 through a Supplier's Declaration of Conformity is Category II equipment, which ICES-Gen says "is exempt from certification and registration", and ICES-Gen contains no requirement to name a Canadian Representative. The Canadian Representative requirement lives in RSP-100 section 4.1 and applies to certified radio apparatus. If your product also contains a transmitter (Wi-Fi, Bluetooth, cellular, Zigbee), that radio is certified under an RSS standard and RSP-100, and a foreign applicant does need a representative for the certification, not for the ICES-003 declaration.
Two regimes, one product
ISED regulates the digital electronics in a product and the radio in a product under different documents. The digital side, "information technology equipment" in ICES-003, is covered by the Interference-Causing Equipment Standards and the general procedure in ICES-Gen. Compliance is by Supplier's Declaration of Conformity: the manufacturer or importer tests to the standard, keeps the report, labels the product, and declares. No application is filed with ISED and nothing is listed in the Radio Equipment List.
The radio side is covered by the Radio Standards Specifications (RSS-247 for Wi-Fi and Bluetooth, RSS-130 and RSS-132 for cellular, and so on) and the certification procedure in RSP-100. Compliance is by certification: a certification body reviews the test report, issues a certificate with an IC certification number, and the product is listed in the REL. RSP-100 section 4.1 requires a foreign applicant to name a Canadian Representative for that certification.
So a laptop with no radio is ICES-003 only and needs no representative. A laptop with Wi-Fi is ICES-003 for the digital portion and RSS-247 certification for the radio, and the foreign applicant for the certification needs a representative. The representative is appointed against the IC certification number, not the ICES declaration.
The three routes at a glance
| Radio apparatus (Category I) | Terminal equipment | Interference-causing equipment (ICES-003 etc.) | |
|---|---|---|---|
| Procedure | RSP-100 certification | DC-01 declaration and registration | ICES-Gen Supplier's Declaration of Conformity |
| Who decides compliance | A recognized certification body | The supplier declares; ISED registers | The supplier declares |
| Public listing | Radio Equipment List (REL) | Telecommunication Apparatus Register (TAR) | None |
| Identifier on the product | IC certification number and HVIN | ISED registration number and HVIN | "CAN ICES-003 (B) / NMB-003 (B)" style label |
| Canadian Representative for a foreign applicant | Required, RSP-100 s. 4.1 | Required, DC-01 s. 6 | Not required; the responsible party is defined by activity |
| Guide | Process overview | DC-01 terminal equipment | This page |
Who is the "responsible party" under ICES-Gen
Some providers offer an "ICES-003 responsible party" or "SDoC representative" service. The phrase comes from ICES-Gen section 3.2, which defines the responsible party as "the party that is involved in one of the activities listed in article 4 of the Radiocommunication Act relative to a specific model of interference-causing equipment. These activities are: manufacture, importation, distribution, lease, offering for sale, and sale."
Read that list again. The responsible party is whoever manufactures, imports, distributes, leases, offers or sells the equipment in Canada. A foreign manufacturer that sells directly into Canada is a responsible party. So is its Canadian importer. So is every distributor and retailer down the chain. The definition attaches by activity; it does not create an appointment, and there is no form on which a responsible party is named to ISED.
What the responsible party must do is set out in ICES-Gen section 5. The label on each unit "represents the manufacturer's or importer's self-declaration of compliance" (section 5.3.2). The manufacturer or importer "shall retain a copy of the test report for as long as the interference-causing equipment is manufactured, imported, distributed, leased, offered for sale, or sold in Canada and shall make the test report available to ISED upon request" (section 5.2). Keep the report, be able to produce it, label correctly. That is the obligation.
What you should have on file
A test report to the current issue of ICES-003 from a competent laboratory, identifying the model and the test configuration. The label text, in the form ICES-Gen prescribes, for example "CAN ICES-003 (B) / NMB-003 (B)" for a Class B device, applied to each unit. And the user manual notices required by the standard. If ISED asks, the party it asks is whoever it finds in the supply chain in Canada, which is why importers and distributors should hold a copy of the report as well as the manufacturer.
When a "responsible party service" makes sense, and when it does not
A Canadian company willing to hold the test report and answer an ISED request on your behalf can be a convenience, particularly for a manufacturer with no importer of its own. It is not required by ICES-Gen, it does not discharge the manufacturer's or importer's own obligations, and it should not be confused with the RSP-100 Canadian Representative. Paying an annual fee for an "ICES-003 representative" on the belief that ISED requires one is a mistake we would rather you did not make, including with us.
Where the product also has a certified radio, the question answers itself: appoint a Canadian Representative for the certification, and have that representative hold the ICES-003 report alongside the radio test report, so that one Canadian contact can answer ISED on either. That is the arrangement we recommend, and we can hold the ICES-003 report for a product we represent; say so when you order.
Sources. ICES-Gen, Issue 1 (with Amendment 1), sections 3.2, 3.3, 5.2 and 5.3.2. RSP-100, Issue 12, section 4.1. Confirm the current issue of ICES-003 with your laboratory before testing.
Does ISED require a Canadian Representative for ICES-003?
No. ICES-003 equipment is Category II, exempt from certification and registration, and ICES-Gen has no Canadian Representative provision. The requirement in RSP-100 section 4.1 applies to certified radio apparatus.
Who is the responsible party for ICES-003 in Canada?
Under ICES-Gen section 3.2, anyone who manufactures, imports, distributes, leases, offers for sale or sells the equipment in Canada. The status follows the activity; nobody is appointed.
My product has Wi-Fi. Do I need a Canadian Representative?
If the applicant for the Wi-Fi certification has an address outside Canada, yes, for the RSS-247 certification under RSP-100. The ICES-003 declaration for the digital portion does not add a second requirement.
Do I have to register an ICES-003 product with ISED?
No. There is no application, no fee and no REL listing. You test, label and keep the report.
What label goes on an ICES-003 product?
The ICES-Gen format, for example "CAN ICES-003 (B) / NMB-003 (B)" for Class B. ICES-Gen section 5.3.2 shows the accepted variants.
Will you hold our ICES-003 test report?
For a product we represent on a radio certification, yes; tell us when you order so that one Canadian contact can respond to ISED on either file.