RSP-100 Canadian Representative checklist for certification bodies
For every application where the applicant's company address is outside Canada, confirm a Canadian Representative is identified, that the letter or declaration names this applicant and this product, that the representative has a real Canadian address and working contact details, that it expressly accepts the RSP-100 section 4.1 duties, and that the stated term is consistent with the product's expected market life. Record the representative against the certification file.
Trigger
- [ ] Applicant's company address on the Application and Agreement for Certification Services is outside Canada. If yes, RSP-100 section 4.1 applies regardless of the CB's location or the applicant's country.
- [ ] Applicant claims a Canadian address: confirm it is a place of business, not a mail-forwarding or virtual office. If it is not a real place of business, treat the applicant as foreign.
The letter or declaration
- [ ] Names the applicant by its legal name, matching the application and the intended REL listing.
- [ ] Names the product by IC certification number, or by PMN and HVIN with the IC number stated as pending.
- [ ] Lists the models covered, matching the application.
- [ ] Names the representative as a legal entity (or individual) with a Canadian street address.
- [ ] Gives a monitored email and a Canadian phone number.
- [ ] Contains an express acceptance of responsibility for responding to ISED enquiries and providing audit samples at no charge to ISED (the section 4.1 wording or its equivalent). A bare "we agree to act as Canadian representative" is not sufficient.
- [ ] States a term, and the term is realistic against the product's market life, or states that the appointment continues while the product is on the market.
- [ ] Signed and dated by a person with authority to bind the representative.
- [ ] If the CB uses its own form, the form is completed in full and countersigned where required.
Red flags
- Representative address is a PO box or a US "North American agent" address.
- Representative is the CB itself, or an affiliate of the CB.
- Representative is a distributor whose agreement with the applicant has a term shorter than the product's market life.
- Letter covers several unrelated IC numbers and applicants in one document.
- Generic email (info@ of a company with no visible connection to regulatory work) and no phone.
- Applicant cannot say who at the representative will answer an ISED enquiry.
Record keeping
- [ ] Representative's identity, address and contacts recorded on the certification file and transmitted to ISED with the application.
- [ ] Letter retained with the application.
- [ ] Procedure in place to update the record on notice of a change of representative, and to request a new letter on transfer of the certificate to a new holder.
What to tell applicants who ask
The requirement is ISED's, in RSP-100 section 4.1, not the CB's. Any Canadian entity that will accept the duties can serve. The appointment lasts for as long as the product is sold in Canada, so the applicant should choose a representative that will exist for that long. A letter can be obtained in a business day; see how it works. The CB may refer applicants to any provider or none; we publish our fee and turnaround so that CBs can pass them on without a quote cycle.
Sources. RSP-100, Issue 12, section 4.1 (Canadian representative), section 11 (certification services applications), section 12.2 (post-certification audits). This checklist reflects our reading of the procedure and our experience of what CBs check; it is not an ISED document.
A printable version is available on request to info@isedrepresentative.com. CBs and labs are welcome to link to this page; see for labs and certification bodies.