Already certified? What the RSS-Gen Issue 6 transition means for your test reports
ISED refreshed its Certification and Engineering Bureau questions and answers in July 2026, and one of the revised entries answers the question every manufacturer asks when a standard changes: what happens to the products you already certified. The short answer is that your certification and your Radio Equipment List entry survive — ISED says there is "no need to update the certification submission or the REL listing" for Category I equipment — but that relief is conditional. Once the transition period expires, the product must comply with the current issue of the standard, the test report must be updated to demonstrate it, and the updated report must be kept on file for as long as the product is on the Canadian market. For RSS-Gen Issue 6, published July 30, 2026, that clock runs out on July 30, 2027.
What ISED updated
The Certification and Engineering Bureau (CEB) and the Directorate of Regulatory Standards (DRS) maintain a running list of answers to questions put to them by applicants, labs and certification bodies. The page was last modified on July 22, 2026, and eleven of its ninety-nine entries now carry an "Updated July 2026" marker — including the general questions on standard transitions and on equipment for which no Canadian standard exists, several RSS-102 entries on RF-exposure simulation reports and TAS algorithms, and four entries on the recognition requirements for certification bodies under the mutual recognition arrangements.
This is not a rule change. The Q&A does not make law; the Radiocommunication Act and the standards do. What the July revision does is state ISED's position plainly enough that you can plan around it, and the timing is not accidental: RSS-Gen Issue 6 and RSS-310 Issue 6 were published eight days later.
What happens when a transition period ends
The operative entry is question 2, on whether products already on the market at the end of a transition period can keep using the old issue of the standard. ISED's answer starts from the statute: any product placed on the Canadian market must comply with the applicable standard at the time it is manufactured, imported, distributed, leased, offered for sale, or sold in Canada. That list of verbs comes straight from paragraph 4(3) of the Radiocommunication Act, and it is the reason the obligation does not stop at the moment of certification. Section 2.1 of the Radiocommunication Regulations points to the Category I and Category II equipment standards lists, "as amended from time to time" — so the standard that binds you is whichever issue is on that list today, not the one you tested against.
RSS-Gen Issue 6 sets its own transition in section 3.1. Applications for certification are accepted under either Issue 5 or Issue 6 for one year from publication. After that, ISED says, applications are accepted only under Issue 6 and equipment manufactured, imported, distributed, leased, offered for sale, or sold in Canada must comply with Issue 6. Published July 30, 2026, that ends July 30, 2027.
The part that catches manufacturers out
Here is the distinction worth writing down. Your certification does not lapse and your IC number does not change. But ISED's position is that when the transition expires, "the product's test report must be updated to demonstrate compliance of the product in question with the latest version of the standard." In many cases that is a modest exercise — ISED itself says the change can be as simple as adding a page to the report explaining why the amendments do not affect the product's compliance. The obligation is to have done it, and to be able to show it.
Where does the updated report live? Not with ISED. It is kept on file by the manufacturer or importer for as long as the product is manufactured, imported, distributed, leased, offered for sale, or sold in Canada, and it must be made available to ISED on request during that time. That is a record-keeping duty with no filing deadline attached to it, which is precisely why it gets missed: nothing bounces, no certification body chases you, and the first time anyone asks may be years later.
New listings on an existing family are not covered
The relief above is expressly limited to products already certified and listed in the Radio Equipment List. ISED's note is explicit that if you add a new product version to an existing family through a Class I Permissive Change application, or seek certification for an identical product through a Multiple Listing, you must still show compliance with the latest published version of the standard — either by a declaration of compliance where no new requirement affects the product, or by a supplementary test report addressing the requirements that have not been evaluated before.
In other words, the moment you touch the file, you are in the current issue. A permissive change filed in August 2027 against an Issue 5 report is not a continuation of an old application; it is a new demonstration under Issue 6.
One small labelling point, since it comes up constantly
Another of the July-updated entries settles a recurring question: is the "IC:" prefix on the certification number still correct now that the department is called ISED, not Industry Canada? It is. ISED confirms that per RSS-Gen the correct prefix remains "IC:", and that "IC ID:" is also acceptable. Do not relabel a product to "ISED:" on the strength of the name change. The rest of the Issue 6 labelling picture — the QR-code option, the relief for very small devices, the electronic-labelling annex — is in our labelling update.
What to do
Between now and July 2027, the work is an inventory exercise rather than a legal one:
- List the IC numbers you still ship into Canada. The duty attaches to products being manufactured, imported, distributed, leased, offered for sale or sold — not to everything you have ever certified. Products you have discontinued in Canada do not need the exercise.
- Ask your test lab, per certification, what Issue 6 changes. For most files the answer will be a delta memo appended to the existing report; for some, a retest of a specific measurement.
- Decide which issue current projects file under. Applications are accepted under either issue until July 30, 2027, but a campaign run against Issue 5 late in the window inherits a report you will have to update almost immediately.
- Keep the updated reports where you can find them. The obligation runs for the life of the product in the Canadian market, which is longer than most document-retention schedules assume.
- Check that your Canadian Representative appointment is still live. If ISED comes asking — for a compliance question or a post-certification audit sample — the representative named in your file is who they contact.
That last point is the one that touches this service. Under RSP-100, an applicant without a Canadian address must identify in writing a representative in Canada capable of responding to enquiries and providing post-certification audit samples at no charge to ISED. That requirement did not change in July, and it does not expire when the certificate issues — it runs with the listing. If the person named on a certification from 2019 has left the company you engaged, or the firm no longer exists, the file is out of date; see how long a Canadian Representative must be appointed and changing your Canadian Representative.
Do I need to re-certify my existing products under RSS-Gen Issue 6?
No. For Category I equipment already certified and listed in the Radio Equipment List, ISED says there is no need to update the certification submission or the REL listing, provided the equipment complies with the latest edition of the applicable standards.
So nothing has to happen before July 30, 2027?
Not quite. When the transition period expires, the product's test report must be updated to demonstrate compliance with the current issue, and the updated report must be kept on file by the manufacturer or importer and made available to ISED on request for as long as the product is on the Canadian market.
Does the updated test report get filed with ISED or my certification body?
No. It is kept on file by the manufacturer or importer. Nothing is submitted unless ISED asks for it.
What if I add a variant to an existing certified family after the transition ends?
A Class I Permissive Change or a Multiple Listing application must show compliance with the latest published version of the standard — by a declaration of compliance if no new requirement affects the product, or by a supplementary test report if one does.
Is the certification number prefix still "IC:" rather than "ISED:"?
Yes. ISED confirmed in July 2026 that per RSS-Gen the correct prefix is still "IC:", and that "IC ID:" is also acceptable.
Does any of this change the Canadian Representative requirement?
No. The requirement comes from RSP-100 and is unchanged. It does, however, run for as long as the certification is live — which is the same period over which you must be able to produce an updated test report.
If you are working through a Canadian certification and need a representative appointed, the Canadian Representative service is a flat US$499 per certification for a ten-year term, or US$999 per year for unlimited certifications; see pricing. For the process end to end, see the ISED certification process overview.