Wearable devices: ISED certification and the Canadian Representative
Wearables are certified under RSS-247 (Bluetooth, Wi-Fi) and, where cellular, the RSS-130 family, with RSS-102 RF exposure evaluation that for body-worn and head-worn devices usually means SAR measurement rather than an exemption. Many qualify for e-labelling of the IC number. The Canadian Representative requirement applies in the usual way and the letter is typically the last item the CB waits for.
What is specific to this category
RF exposure is the technical gating item. RSS-102 sets the exposure limits and evaluation requirements. Wearables are worn on the wrist, in the ear or on the head, so the distances that let smart-home devices claim an exemption do not apply, and SAR testing at the relevant separation is normally required. The lab handles this, but it is the item most likely to extend testing; the representative letter should not add to the delay. See how it works.
E-labelling. Products without room for a physical label may display the IC certification number electronically under ISED's e-labelling provisions in RSS-Gen, with conditions on accessibility of the display and on packaging information. Wearables are the archetypal case. Confirm eligibility with your CB.
Cellular variants. An LTE or 5G watch adds licensed-band certification under the applicable RSS-130-series standards and often a separate certification from the Bluetooth/Wi-Fi one. Each IC certification number needs its own representative letter. See one representative letter per IC ID.
Hearables and modules. True-wireless earbuds frequently use a certified Bluetooth SoC module; charging cases sometimes carry their own radio. Whether the host needs its own certification depends on the module grant conditions (RSP-100 section 8). Sort this out before ordering letters.
Medical-adjacent claims. A wearable that measures ECG or blood oxygen may be a medical device under Health Canada's regime as well as radio apparatus under ISED's. The two are separate; the Canadian Representative under RSP-100 is not a Health Canada regulatory correspondent. See wireless medical devices.
Typical certification path
RSS-247 for Bluetooth and Wi-Fi, RSS-130 family for cellular, RSS-102 SAR, RSS-Gen. FCC testing is almost always combined. The CB issues the IC number; e-label or physical label and bilingual notices follow. The applicant, if outside Canada, orders the Canadian Representative letter at application; we issue the same business day.
Products we have represented
Fitness bands, smartwatches, hearables and head-worn devices for manufacturers in the United States, China, Taiwan and Korea.
Sources. RSP-100, Issue 12, sections 4.1, 5 (labelling) and 8. RSS-102 and RSS-Gen as published by ISED; confirm current issues with your lab.