ISED audit samples: who provides them, and who pays?
The certificate holder provides the sample and pays for it and its shipping. RSP-100 section 4.1 makes the Canadian Representative responsible for "providing audit samples at no charge to ISED," and section 12.2 says samples are provided "at the certificate holder's expense." The representative's job is to receive the request, reach the applicant, and make sure the sample arrives correctly; the applicant supplies and funds it.
The two provisions
Two parts of RSP-100 speak to audit samples and they fit together.
Section 4.1, on the Canadian Representative: the representative "shall be responsible for responding to all enquiries from ISED regarding the certified product(s), including providing audit samples at no charge to ISED."
Section 12.2, on post-certification audits: "Post-certification audits will be conducted by ISED and the CB in order to ensure continuing compliance. The technical acceptance certificate (TAC) holder shall provide random radio product samples at the certificate holder's expense, when requested by ISED or the CB, for post-certification audit testing, or for determining radio interference."
Read together: ISED will not pay for samples, the certificate holder bears the cost, and the Canadian Representative is the party ISED holds responsible for making the sample appear. A representative that accepts the appointment is accepting that it will make this happen, not that it will pay for it.
How a request unfolds
ISED's Certification and Engineering Bureau, or the CB acting in its audit program, contacts the Canadian Representative (sometimes the certificate holder directly) identifying the IC certification number and specifying what is wanted: usually one or more production units of a named model, sometimes with accessories, firmware at a stated version, or test-mode instructions. A deadline is given.
The representative acknowledges receipt, notifies the applicant the same day, and relays the specification and deadline. The applicant selects units from production stock (not golden samples; "random" is the word in section 12.2), packages them with the documentation requested, and ships them to the address ISED specifies, which is normally ISED's laboratory in the Ottawa area. The applicant pays for the units, export documentation and freight. Customs: the shipment is a regulatory sample, not a commercial import, and should be documented as such to avoid duty disputes at the border; the representative can advise on paperwork if the applicant's forwarder is unfamiliar with Canadian entries.
ISED tests the sample against the RSS standards on the certificate. If it passes, the file closes. If it fails, ISED raises the non-compliance with the certificate holder through the representative and the CB, and the consequences range from corrective action to suspension or revocation of the certificate.
Why a missed request is serious
If the representative cannot reach the applicant, or the applicant does not ship in time, the product is in non-compliance with the procedure under which it was certified, and ISED may suspend the certificate. Most failures we have seen are not refusals; they are stale contact details, an applicant that has reorganised, or a representative that stopped checking its inbox. This is why we keep two contacts per appointment and confirm them annually, and why choosing a representative that will still be there in year six matters more than the fee. See common Canadian Representative mistakes.
What the representative should and should not do
Should: acknowledge promptly, relay precisely, track the deadline, help with Canadian shipping and customs questions, and confirm delivery to ISED.
Should not: make technical statements about the product, select or modify the sample, or negotiate the scope of the audit without the applicant's instructions. The representative is a conduit with a duty to make the sample appear, not the certificate holder's engineering department.
Sources. RSP-100, Issue 12, section 4.1 (representative's responsibility for audit samples) and section 12.2 (post-certification audits, samples at the certificate holder's expense).
Does the representative need to keep stock of my product in Canada?
No. RSP-100 does not require samples to be held in Canada; it requires that they be provided when requested. Applicants ship from production stock when asked.
How often are audit samples requested?
Infrequently for any single certification; ISED's audit program is sample-based across the market. Over a decade of representing many certifications, requests arrive a few times a year in total. The infrequency is what makes stale contact details dangerous.
Can the sample be returned afterwards?
Sometimes, on request, after testing; ISED's practice varies and testing may be destructive. Budget on the basis that the units are consumed.