Device labelling under RSS-Gen Issue 6: QR codes, small devices, e-labels

Written by Koby Smutylo, lawyer (Law Society of Ontario, called 2001), ISED Canadian Representative since 2010. Last reviewed 27 August 2026.

Among the changes in RSS-Gen Issue 6 (published July 30, 2026), the labelling provisions are the ones with the most practical effect. Issue 6 adds a QR-code labelling option, allows very small devices to carry the label in the user manual or packaging instead of on the device, and clarifies the electronic-labelling (e-label) requirements in the standard's normative annex. The core obligations remain unchanged: the IC certification number must be displayed for certified equipment, and user-manual notices must appear in both English and French.

What Issue 6 changes on the label

Three changes stand out from the Issue 6 preface.

A QR-code option. The labelling requirements were streamlined to allow QR-code labelling, giving manufacturers a compact way to carry required information on space-constrained products.

Relief for very small devices. Where the device is too small for a compliant label, Issue 6 permits placing the label in the user manual or on the packaging.

Clarified e-labelling. The electronic-labelling requirements, which apply to devices with integral display screens, are now set out in a normative annex and clarified from the Issue 5 treatment.

What has not changed

The certification number, the "IC ID" formed from the applicant's Company Number and product number, must still be displayed for certified (Category I) equipment, and the user manual still must include the notices required by the applicable RSS standard in both English and French. Canadian labelling remains separate from FCC labelling: a US label block does not satisfy ISED requirements, a point we cover in from FCC to ISED. And none of this touches the Canadian Representative requirement, which is about who stands behind the application, not what is printed on the device.

What to check on your next production run

Worth a short review with your compliance team: whether a QR-code or e-label approach now fits products where the physical label has been a squeeze; whether any "label on device" workarounds for small products can be replaced with the manual/packaging placement Issue 6 permits; and that artwork updates keep the certification number and bilingual notices intact. The one-year transition matters here: files under Issue 5 remain acceptable while it runs, so labelling changes can be aligned with your next certification cycle rather than retrofitted. Details are in the labelling section and annexes of the published standard; your certification body has the final word on a compliant label for your specific device.

Can I use a QR code instead of a printed label in Canada now?

RSS-Gen Issue 6 adds a QR-code labelling option as part of its streamlined labelling requirements. Whether it fully replaces printed elements for your device depends on the standard's conditions; confirm the implementation with your certification body.

My device is tiny. Where does the label go?

Issue 6 permits very small devices to carry the label in the user manual or on the packaging instead of on the device itself.

Do the label changes affect products already certified?

No re-labelling obligation arises from the revision itself for existing certified stock, and applications under Issue 5 remain acceptable during the one-year transition. Align label changes with your next certification or production cycle.