Industrial IoT and smart metering: ISED certification and the Canadian Representative

Written by Koby Smutylo, lawyer (Law Society of Ontario, called 2001), ISED Canadian Representative since 2010. Last reviewed 20 August 2026.

What is specific to this category

The 902–928 MHz band. Canada's licence-exempt 915 MHz band is harmonized with the US, and LoRaWAN, proprietary sub-GHz and many metering radios operate there under RSS-247 or RSS-210. Test data from FCC Part 15.247 work is largely reusable; see from FCC to ISED. Meter-reading systems that use licensed spectrum follow their own RSS and licensing requirements with the utility.

Modules everywhere. A gateway typically contains a certified LoRa module, a certified cellular module and a certified Wi-Fi/BLE module. Under RSP-100 section 8 the host relies on those certifications and does not need its own unless it adds a radio or departs from the module grant conditions. The module makers, if outside Canada, need Canadian Representatives for their IC numbers; the integrator needs one only for certifications it holds. Integrators ordering letters they do not need is common in this category. See one representative letter per IC ID.

Field life. Electricity, water and heat meters are installed for fifteen to twenty years and sold as replacements throughout. RSP-100 requires the Canadian Representative to be maintained for as long as the product is offered in Canada. Utilities procuring meters increasingly ask the manufacturer who its representative is and whether it will exist for the asset life. See how long must a Canadian Representative be appointed. Kamstrup's metering products are an example of the category; see clients.

Enterprise customers and utilities ask for the letter. Unlike consumer products, industrial buyers often request the ISED certificate and supporting documents, including the representative letter, as part of procurement. Keep the letter in the technical file.

Firmware-defined radios and variants. Regional variants of the same hardware (different bands, different power) may be separate certifications or one certification with multiple HVINs; the CB decides. Letters follow the IC numbers.

Typical certification path

RSS-247 or RSS-210 for sub-GHz and 2.4 GHz, RSS-130-series for cellular IoT, RSS-102 exemption, RSS-Gen. For gateways using only certified modules, often no new certification at all. CB issues the IC number where a certification is needed. Applicants outside Canada order the representative letter at application; we issue the same business day.

Products we have represented

Smart electricity, water and heat meters, LoRaWAN gateways and sensors, asset trackers, industrial controllers and cellular IoT modules for manufacturers in Denmark, Germany, the United States, China and Taiwan.