ISED vs FCC: which radio authorisation?
For a radio product crossing the North American border, the United States and Canada share engineering habits and a mutual recognition arrangement, but they remain two legal systems with two grants, two identifiers and two databases. Canada also changed its rule book recently: RSS-Gen issue 6 was published on July 30, 2026 and amended on September 15, 2026, RSS-247 issue 4 became mandatory on January 24, 2026, and RSS-102 issue 6 has been mandatory since December 15, 2024. This guide reads RSP-100, RSS-Gen, RSS-102 and ICES-003 against 47 CFR Parts 1, 2 and 15, row by row, and ends with the claims those texts contradict.
Decision table: ISED vs FCC at a glance
Section titled “Decision table: ISED vs FCC at a glance”| Axis | FCC (United States) | ISED (Canada) |
|---|---|---|
| Authority | Federal Communications Commission | Innovation, Science and Economic Development Canada |
| Procedure text | 47 CFR Part 2 Subpart J | RSP-100 issue 12, RSS-Gen issue 6 |
| Radio rules | 47 CFR Part 15 Subpart C (unlicensed), Parts 22, 24, 27 and others (licensed) | RSS-Gen plus the specific RSS (RSS-247, RSS-248, RSS-210, RSS-130 to RSS-139) |
| Non-radio digital part | Part 15 Subpart B (Class A / B) | ICES-003 issue 7 with ICES-Gen issue 2, only when RSS-Gen section 4.6 requires it |
| RF exposure | 47 CFR 1.1307, 1.1310, 2.1091, 2.1093; KDB 447498 | RSS-102 issue 6 and its companion procedures |
| Self-declaration | SDoC (2.906), mostly unintentional radiators | Supplier's Declaration of Conformity for Category II radio and ICES equipment |
| Third-party route | Certification (2.907) by a TCB | Certification of Category I by a recognised CB, or a TAC from the ISED Certification and Engineering Bureau |
| Test laboratory | Accredited and FCC-recognised for Certification (2.948(a)) | ISED-recognised for Category I (RSS-Gen section 3.8.1), not required for Category II |
| Identifier | FCC ID: Grantee Code + product code (2.926) | IC: CN (company number) + UPN (RSS-Gen section 9.4.4.1) |
| Public database | Equipment Authorization System (EAS) | Radio Equipment List (REL), Category I only |
| Foreign-party requirement | US agent for service of process for every Certification applicant (2.911(d)(7)) | Canadian representative when the applicant address is not in Canada (RSP-100 section 4.1) |
| Post-grant changes | Class I, II, III permissive changes (2.1043) | C1PC, C2PC, C3PC, C4PC (RSP-100 section 10), filed with a CB or ISED |
| Manual language | The Part 15 statements are written in English in 47 CFR | Notices in both English and French (RSS-Gen section 9.3.1, RSP-100 section 7) |
None of these rows merges the two grants. The MRA shares the recognition of laboratories and certification bodies, not certificates.
Authorities and the legal architecture
Section titled “Authorities and the legal architecture”FCC: rules written into the CFR
Section titled “FCC: rules written into the CFR”The FCC writes its technical limits directly into Title 47 of the Code of Federal Regulations. The procedures (SDoC, Certification, labelling, permissive changes) are in 47 CFR Part 2 Subpart J; Part 15 carries the unlicensed and unintentional-radiator rules; Parts 22, 24 and 27 carry the main licensed cellular services. The measurement methods are the ANSI standards the rules reference, ANSI C63.4 for unintentional radiators and ANSI C63.10 for unlicensed transmitters. See the FCC pillar for the full scope.
ISED: RSP, RSS and ICES
Section titled “ISED: RSP, RSS and ICES”ISED is the department formerly named Industry Canada; certification numbers still carry the "IC:" prefix, which RSS-Gen section 9.4.4.1 says indicates an ISED certification number but is not part of it. The procedure lives in RSP-100 issue 12 (August 2019), which covers the certification of Category I equipment. The technical rules come in two families: RSS (Radio Standards Specifications) for radio apparatus, with RSS-Gen as the general standard, and ICES (Interference-Causing Equipment Standards) for equipment other than radio apparatus. Where RSS-Gen and a specific RSS differ, the specific RSS prevails (RSS-Gen section 3.3). Full detail is in the ISED Canada guide.
Mapping the rule parts
Section titled “Mapping the rule parts”The mapping is functional, not textual. Band edges and limits must be checked in each text.
| Technology | FCC rule part | ISED standard |
|---|---|---|
| Wi-Fi 2.4 GHz, Bluetooth, DTS and frequency hopping in 902-928 and 2400-2483.5 MHz | 15.247 | RSS-247 issue 4 (Category I, licence-exempt) |
| 5 GHz RLAN | 15.407 (U-NII) | RSS-247 issue 4 (5150-5350 and 5470-5895 MHz) |
| 6 GHz RLAN | 15.407 (U-NII) | RSS-248 (5925-7125 MHz) |
| Other licence-exempt transmitters | Part 15 Subpart C | RSS-210 (Category I) or RSS-310 (Category II) |
| Cellular 824-849 / 869-894 MHz | Part 22 Subpart H | RSS-132 |
| PCS 1850-1915 / 1930-1995 MHz | Part 24 Subpart E | RSS-133 |
| AWS 1710-1780 / 2110-2200 MHz | Part 27 | RSS-139 |
| 600 and 700 MHz bands | Part 27 | RSS-130 (617-652, 663-698, 698-756, 777-787 MHz) |
| Digital part of a non-radio product | Part 15 Subpart B | ICES-003 issue 7 |
| RF exposure | 1.1307, 1.1310, 2.1091, 2.1093 | RSS-102 issue 6 |
Equipment authorisation: both sides have two routes
Section titled “Equipment authorisation: both sides have two routes”FCC: SDoC and Certification
Section titled “FCC: SDoC and Certification”Under 47 CFR Part 2 Subpart J, the rule part decides the route:
- SDoC (2.906): the responsible party, located in the United States, tests the product and keeps the records; nothing is filed unless the FCC asks for a sample or data (2.945). Most unintentional radiators may use SDoC or Certification (15.101).
- Certification (2.907): a grant issued by a TCB on the test data submitted. Intentional radiators need Certification (15.201(b)). All applications are submitted to a TCB (2.911(a)), and the testing laboratory must be accredited and recognised by the FCC (2.948(a)).
The Grantee Code, FCC ID structure and TCB review are covered in FCC ID, Grantee Code and TCB.
ISED: Category I and Category II
Section titled “ISED: Category I and Category II”RSS-Gen issue 6, section 3.4, splits radio apparatus by whether certification is required, which is a separate question from licensing (section 3.5):
- Category I (section 3.4.1): needs a TAC from the ISED Certification and Engineering Bureau or a certificate from a recognised CB, under RSP-100. The test report may not be dated more than 12 months before the application, the testing laboratory must be recognised by ISED (section 3.8.1), and the model must be on the REL before it is manufactured, imported, distributed, leased, offered for sale or sold in Canada (an approved deferred listing allows manufacture, import and distribution, not sale).
- Category II (section 3.4.2): exempt from certification, no TAC and no CB certificate, but the apparatus must comply, and the test report is kept for as long as the model is marketed and supplied to ISED on request. ISED describes this as a Supplier's Declaration of Conformity, with no listing requirement.
"Licence-exempt" does not mean Category II. Wi-Fi and Bluetooth under RSS-247 are licence-exempt and Category I. ICES equipment (the non-radio side) also follows a Supplier's Declaration of Conformity; under ICES-Gen issue 2 the label "CAN ICES (B) / NMB (B)" is itself the declaration. A radio apparatus does not need a separate ICES-003 verification when its digital subassemblies only serve the radio, and does not need the ICES label in any case (RSS-Gen section 4.6).
Side by side
Section titled “Side by side”| Device type | FCC route | ISED route |
|---|---|---|
| Digital device, no radio | SDoC or Certification (15.101) | ICES-003, Supplier's Declaration of Conformity, ICES label |
| Wi-Fi or Bluetooth product | Certification, FCC ID via a TCB | Category I: certification via a CB, IC number, REL listing |
| Cellular device | Certification, FCC ID via a TCB | Category I: certification via a CB, IC number, REL listing |
| Category II radio (RSS-310 devices) | Depends on the Part 15 rule | No certification, report kept, no listing |
| Host integrating certified modules only | Depends on the host and module grants | No separate host certification if all intentional emissions come from certified modules (RSP-100 section 8), except handheld or wearable hosts unless they contain a single module with SAR exempt or below 0.4 W/kg (section 8.2) |
Identifiers and the certification body
Section titled “Identifiers and the certification body”FCC ID
Section titled “FCC ID”An FCC ID joins the Grantee Code assigned by the FCC (three characters for older codes, five since 2013) and a product code chosen by the grantee, of 14 characters at most (2.926). It appears on the device after the words "FCC ID" (2.925), or electronically under 2.935.
ISED certification number
Section titled “ISED certification number”RSS-Gen issue 6, section 9.4.4.1, fixes the format IC: XXXXX-YYYYYYYYYYY: a CN of five numeric characters assigned by ISED (older CNs: up to five digits followed by a letter, such as 21A or 15589J), then a UPN assigned by the applicant, up to eleven characters, A-Z and 0-9 only. The label also carries the HVIN; the PMN may go on the packaging or in the product literature instead. The PMN, HVIN and certification number shown on the product must match the REL.
The certifying body
Section titled “The certifying body”The FCC routes all applications through Telecommunication Certification Bodies (2.911(a)), and recognises TCBs outside the United States only when designated under an MRA (2.960(d)). ISED certifies through recognised CBs that have every applicable standard in their scope (RSS-Gen section 3.7), and ISED says that certification is done by a domestic recognised CB, a foreign CB recognised under an MRA, or in rare instances the Certification and Engineering Bureau. One organisation can hold both roles, but the FCC grant and the ISED certificate stay distinct acts.
RF exposure: 47 CFR 1.1310 vs RSS-102 issue 6
Section titled “RF exposure: 47 CFR 1.1310 vs RSS-102 issue 6”| Parameter | FCC | ISED |
|---|---|---|
| Basis | 47 CFR 1.1310 | Health Canada Safety Code 6, adopted by RSS-102 issue 6 (section 5.1) |
| Whole-body SAR, general public | 0.08 W/kg | 0.08 W/kg |
| Localised SAR, general public | 1.6 W/kg over 1 g | 1.6 W/kg over 1 g (head, neck and trunk) |
| Extremities, general public | 4 W/kg over 10 g; hands, wrists, feet, ankles and pinnae | 4 W/kg over 10 g; "localized limbs" |
| Averaging time, general public | Up to 30 minutes (1.1310(c)) | 6 minutes (RSS-102 table 3) |
| SAR or field evaluation threshold | Portable device: within 20 cm of the body (2.1093(b)) | SAR at 20 cm or less, field reference level above 20 cm |
| SAR exemption | 1 mW whatever the distance, or the Pth formula (0.5 to 40 cm, 0.3 to 6 GHz), or the ERP table (1.1307(b)(3)) | Table 11 of fixed power levels by frequency and distance, for example 3 mW at 2450 MHz and 5 mm or less |
| Procedures | FCC KDB publications, including KDB 447498 | RSS-102, then the IEC and IEEE standards it references, then accepted procedures such as FCC KDBs (section 2.2) |
The limits look identical on paper, but the exemption logic and averaging differ, so one measurement campaign usually produces two exposure write-ups. RSS-102 section 4.4 requires the RF exposure technical brief cover sheet (annex A), or a signed declaration (annex B) when the device meets the exemption limits. See SAR procedures for the measurement standards.
The Canada-US mutual recognition arrangement
Section titled “The Canada-US mutual recognition arrangement”Canada lists the APEC TEL MRA among the arrangements it has signed or endorsed. ISED describes MRAs as letting the parties "mutually recognize the competence of each other's testing laboratories and certification bodies and subsequently, mutually accept the conformity assessment results (test reports and certification)".
What it allows in practice:
- one laboratory, recognised by both authorities, can test for both files;
- a foreign CB recognised under an MRA can certify for ISED, and the FCC can recognise TCBs outside the United States designated under an MRA (2.960(d));
- RSS-102 accepts FCC KDB procedures as a third-priority test method.
What it does not do:
- merge the grants: the FCC grant and the ISED certificate are separate applications with separate identifiers;
- remove the Canadian file contents: RSS-Gen section 8.2 requires the report to list every RSS with its edition, and the ISED company number and CABID of the recognised laboratory;
- replace the REL listing: a Category I model cannot be sold in Canada until it is listed.
On the cost side, ISED charges a base fee of CAD 750 per application to register a CB-certified radio product and list it on the REL, under TRC-49 issue 9; the amounts are adjusted each year to the consumer price index, and the CB sets its own fees on top. For a broader view see EU-US dual certification, CE vs FCC EMC and Certification costs.
Labelling, language and user notices
Section titled “Labelling, language and user notices”| Item | FCC | ISED |
|---|---|---|
| Identifier on the unit | "FCC ID" + Grantee Code + product code (2.925) | "IC:" + CN-UPN, plus the HVIN (RSS-Gen section 9.4.4.1) |
| Compliance statement | 15.19(a) statement on SDoC and certified Part 15 devices | Licence-exempt notice of RSS-Gen section 9.3.2.1, English and French, in the manual or on the device |
| Very small devices | Statement in the manual and on the packaging or a removable label when 4-point text is impracticable and there is no display (15.19(a)(5)) | Label in the manual and on the packaging without approval at 2.5 cm or less; above that, only with written approval from the Bureau (section 9.4.3) |
| E-label | Devices with a display, or that only work with a device that has one; no more than three steps from the device setting menu (2.935) | Annex B: display, audio message or mandatory connected device; no more than three steps from the product main menu; physical label on the packaging at import, distribution and sale |
| QR code | No QR code provision in 2.935 | Allowed on the product if the code contains the label itself, not a link (section 9.4.2) |
| Language | Statements given in English in 47 CFR | All notices in English and French (RSS-Gen section 9.3.1); a written declaration is accepted at certification if only one language exists then (RSP-100 section 7) |
One label can carry both identifiers. The notices cannot be merged into one sentence: the texts differ, and the Canadian ones must be bilingual.
Modifications after the grant: Class I-III vs C1PC-C4PC
Section titled “Modifications after the grant: Class I-III vs C1PC-C4PC”The two regimes do not have the same number of classes, and Canada does not tie the filing to the original CB. RSP-100 section 10: the certificate holder "shall inform the certification body (CB) or ISED of any changes that may affect compliance".
| Change | FCC (47 CFR 2.1043) | ISED (RSP-100 section 10) |
|---|---|---|
| No degradation of reported characteristics | Class I, no filing | C1PC, no notice unless the HVIN or PMN changes |
| Hardware change that affects RF characteristics, still compliant | Class II, filing with test results, not marketed before acknowledgement | C2PC, notice required; any PMN or HVIN change also falls here; new bands by hardware change not permitted |
| Firmware or software change affecting RF | Class III for software defined radios (frequency range, modulation, maximum power), only if no Class II change was made | C3PC, notice required with a new and unique FVIN; also used to enable bands by firmware |
| Certified module in a new host that changes emissions or exposure | No dedicated class in 2.1043 | C4PC, notice required with the HMN and the exposure evaluation in the new host |
| Changes to frequency-determining circuitry, basic modulator or power rating | New grant, except Class III software changes (2.1043(a)) | A modified apparatus can be a new model no longer covered by the original certificate (RSS-Gen section 4.2) |
Every ISED service application must also comply with the latest issue of the applicable standards; if no new test is needed, a statement of compliance with the latest issue is filed instead (RSP-100 section 11). The Class II permissive change guide compares the classes with the RED and the CRA.
Dates that matter in 2019 to 2027
Section titled “Dates that matter in 2019 to 2027”| Date | Text | Effect |
|---|---|---|
| March 15, 2019 | ISED regulatory process | ISED recognition required for Category I testing laboratories |
| August 2019 | RSP-100 issue 12 | Current certification procedure, C1PC to C4PC |
| February 6, 2023 | FCC 22-84 | US agent for service of process required for every Certification applicant |
| December 15, 2023 | RSS-102 issue 6 | Published; issue 5 accepted for 12 months |
| February 23, 2024 | ICES-Gen issue 2 | Generic "CAN ICES (A/B) / NMB (A/B)" label |
| December 15, 2024 | RSS-102 issue 6 | Mandatory |
| July 24, 2025 | RSS-247 issue 4 | Published, six-month transition |
| January 24, 2026 | RSS-247 issue 4 | Mandatory |
| July 30, 2026 | RSS-Gen issue 6 | Published; issue 5 accepted for one year (section 3.1) |
| September 15, 2026 | RSS-Gen issue 6, Amendment 1 | Section 7.5 only (cable-locating equipment at 101.4 kHz) |
| July 30, 2027 | RSS-Gen issue 6 | End of the transition: issue 6 only for new applications and for products still marketed |
Step by step: running a dual ISED + FCC programme
Section titled “Step by step: running a dual ISED + FCC programme”- Scope the rules. Map every operated band to its FCC rule part and its RSS, using the table above; decide whether ICES-003 applies (RSS-Gen section 4.6) and whether the product is a module or a host (RSP-100 section 8).
- Pick the laboratory. For Certification it must be FCC-recognised (2.948(a)); for Category I it must be ISED-recognised (RSS-Gen section 3.8.1). Check both listings.
- Test once where the texts allow it. Cover the union of bands, the radio limits of each text, and the RF exposure evaluation for both regimes.
- Prepare the representatives. A US agent for service of process (2.911(d)(7)) and, for a non-Canadian applicant, a Canadian representative named in RSP-100 form A (section 4.1).
- File the FCC application with a TCB; the grant appears in the EAS.
- File the ISED application with a recognised CB (or the Bureau): cover letter, test reports with form B, the checklist documents of form C, form D for a module (RSP-100 section 4.2). The CB sends the file to ISED for REL listing.
- Label and document. FCC ID and IC number, HVIN, the 15.19 statement, and the RSS-Gen notices in English and French.
- Maintain both. Classify each change under 2.1043 and under RSP-100 section 10, and file with a TCB and with a CB or ISED as required.
For realistic durations see Certification timeline.
Claims the texts contradict
Section titled “Claims the texts contradict”| Common claim (including earlier versions of this page) | What the text says |
|---|---|
| "ISED has no self-declaration for radio; every intentional emitter goes through a CB" | Category II radio apparatus are exempt from certification (RSS-Gen section 3.4.2); ISED calls their scheme a Supplier's Declaration of Conformity. |
| "Category I yields a TAC; Category II yields a Declaration of Conformity produced by the CB" | Category I gets a CB certificate or, from the Bureau, a TAC (section 3.4.1). Category II has no CB and no certificate (section 3.4.2). |
| "The ISED change is filed with the original CB" | RSP-100 section 10: the holder informs "the CB or ISED". |
| "Canada has one equivalent of the Class II permissive change" | Four classes, C1PC to C4PC, with different notice rules; C3PC covers firmware changes and C4PC new hosts (RSP-100 sections 10.1 to 10.4). |
| "The Canadian representative is for Category I only" | RSP-100 section 4.1 applies to every certification applicant whose address is not in Canada; Category II is not certified at all. |
| "The US agent is for foreign applicants" | 2.911(d)(7) requires every applicant to designate a US agent; a US applicant may designate itself. |
| "IC identifier: Company Code + Product Code" | RSS-Gen section 9.4.4.1: CN of five digits (older ones up to five digits plus a letter) and a UPN of up to eleven characters, plus the HVIN on the label. |
| "Every radio product also needs an ICES-003 report" | Not when the digital subassemblies only serve the radio (RSS-Gen section 4.6); the radio apparatus never needs the ICES label. |
| "RSS-102 and the FCC rest on the same ICNIRP and IEEE C95.1 lineage, with practically the same limits" | RSS-102 issue 6 adopts Health Canada Safety Code 6. The 1 g and 10 g SAR values match 47 CFR 1.1310(c), but the averaging time (6 vs 30 minutes) and exemption method differ. |
| "OET Bulletin 65 is the FCC counterpart of RSS-102" | The limits are in 47 CFR 1.1310 and the exemptions in 1.1307(b)(3); device evaluation is in 2.1091 and 2.1093. |
| "Adding ISED to an FCC programme takes a few weeks" | No ISED or FCC text sets a duration. What the texts set: a report not older than 12 months at application, an ISED-recognised laboratory, and REL listing before sale. |
| "A monolingual manual is tolerated" | Notices in English and French (RSS-Gen section 9.3.1); a one-language file at certification needs a written declaration that both will be present at sale (RSP-100 section 7). |
Which one do you need?
Section titled “Which one do you need?”- US market only: FCC authorisation alone. SDoC or Certification for an unintentional radiator according to 15.101, Certification with an FCC ID if it is an intentional radiator.
- Canadian market only: ISED alone. Category I certification and REL listing for most transmitters; Supplier's Declaration of Conformity for Category II radio and for ICES-003 equipment.
- Both markets: one test plan where the texts allow it, two applications, two identifiers, one label with both, and bilingual notices.
There is no scenario in which one authorisation substitutes for the other. The MRA shares the recognition of the bodies doing the work, not the legal authorisation.
Further reading
Section titled “Further reading”- FCC ID, Grantee Code and TCB: equipment authorization
- ISED Canada: radio certification and REL listing
- Change management: FCC Class II permissive change, ISED and RED
- CE vs FCC: EMC comparison for electronics
- EU-US dual certification
- SAR procedures: IEC 62209 and EN 50360
- FCC pillar
Sources and references
Section titled “Sources and references”Sources & references
- 47 CFR Part 15: Radio frequency devices, eCFR www.ecfr.gov/current/title-47/chapter-I/subchapter-A/part-15
- 47 CFR Part 2, Subpart J: Equipment Authorization Procedures (2.906 SDoC, 2.907 Certification, 2.911 US agent, 2.948 laboratories), eCFR www.ecfr.gov/current/title-47/chapter-I/subchapter-A/part-2/subpart-J
- 47 CFR 2.1043: Changes in certificated equipment (Class I, II and III permissive changes), eCFR www.ecfr.gov/current/title-47/chapter-I/subchapter-A/part-2/section-2.1043
- 47 CFR 2.935: Electronic labeling of radiofrequency devices, eCFR www.ecfr.gov/current/title-47/chapter-I/subchapter-A/part-2/section-2.935
- 47 CFR 15.19: Labeling requirements, eCFR www.ecfr.gov/current/title-47/chapter-I/subchapter-A/part-15/subpart-A/section-15.19
- 47 CFR 1.1307: Actions that may have a significant environmental effect (RF exposure exemptions, (b)(3)), eCFR www.ecfr.gov/current/title-47/chapter-I/subchapter-A/part-1/subpart-I/section-1.1307
- 47 CFR 1.1310: Radiofrequency radiation exposure limits, eCFR www.ecfr.gov/current/title-47/chapter-I/subchapter-A/part-1/subpart-I/section-1.1310
- 47 CFR 2.1093: Radiofrequency radiation exposure evaluation, portable devices, eCFR www.ecfr.gov/current/title-47/chapter-I/subchapter-A/part-2/section-2.1093
- FCC Equipment Authorization, FCC www.fcc.gov/engineering-technology/laboratory-division/general/equipment-authorization
- RSS-Gen, issue 6 (July 30, 2026, Amendment 1 September 15, 2026): General Requirements for Compliance of Radio Apparatus, ISED Canada ised-isde.canada.ca/site/spectrum-management-telecommunications/en/devices-and-equipment/radio-equipment-standards/radio-standards-specifications-rss/rss-gen-general-requirements-compliance-radio-apparatus
- RSP-100, issue 12 (August 2019): Certification of Radio Apparatus and Broadcasting Equipment, ISED Canada ised-isde.canada.ca/site/spectrum-management-telecommunications/en/devices-and-equipment/radio-standards-procedures-rsp/rsp-100-certification-radio-apparatus-and-broadcasting-equipment
- RSS-102, issue 6 (December 15, 2023): RF Exposure Compliance of Radiocommunication Apparatus (All Frequency Bands), ISED Canada ised-isde.canada.ca/site/spectrum-management-telecommunications/en/devices-and-equipment/radio-equipment-standards/radio-standards-specifications-rss/rss-102-radio-frequency-rf-exposure-compliance-radiocommunication-apparatus-all-frequency-bands
- ISED Radio Standards Specifications index (RSS-247, RSS-248, cellular RSS), ISED Canada ised-isde.canada.ca/site/spectrum-management-telecommunications/en/devices-and-equipment/radio-equipment-standards/radio-standards-specifications-rss
- ICES-003, issue 7 (October 15, 2020): Information Technology Equipment (including Digital Apparatus), ISED Canada ised-isde.canada.ca/site/spectrum-management-telecommunications/en/devices-and-equipment/interference-causing-equipment-standards-ices/ices-003-information-technology-equipment-including-digital-apparatus
- Telecommunications Equipment Regulatory Process (certification, SDoC, MRAs, CB market surveillance), ISED Canada ised-isde.canada.ca/site/mutual-recognition-agreements/en/telecommunications-equipment-regulatory-process
- TRC-49, issue 9 (July 2023): Telecommunications and Radio Equipment Service Fees of the Certification and Engineering Bureau, ISED Canada ised-isde.canada.ca/site/spectrum-management-telecommunications/en/devices-and-equipment/telecom-regulation-circulars-trc/trc-49-telecommunications-and-radio-equipment-service-fees-certification-and-engineering-bureau
- ISED Certification and Engineering Bureau (Radio Equipment List, recognised CBs and laboratories), ISED Canada ised-isde.canada.ca/site/certification-engineering-bureau/en
Frequently asked questions
- Does an FCC ID give me the right to sell in Canada?
- No. An FCC grant covers the United States only. A Category I radio apparatus sold in Canada needs its own ISED certification (a certificate from a recognised CB, or a TAC from the ISED Certification and Engineering Bureau) and a Radio Equipment List (REL) entry: RSS-Gen issue 6, section 3.4.1, forbids manufacturing, importing, distributing, leasing, offering for sale or selling it in Canada before it is listed. The two regimes can share test data, not grants.
- Can one test campaign cover both ISED and FCC?
- For the measurements, often yes. Canada and the United States recognise each other's testing laboratories and certification bodies under the APEC TEL MRA, and RSS-102 issue 6 even lists FCC KDB procedures as accepted test methods after its own and the IEC and IEEE standards. But the Canadian report must address each RSS and its edition (RSS-Gen section 8.2), the laboratory must be recognised by ISED for Category I (section 3.8.1), and two applications are still filed.
- What is the equivalent of the FCC TCB in Canada?
- An ISED-recognised certification body (CB), with the applicable RSS standards in its scope of recognition (RSS-Gen section 3.7). ISED also says that certification can, in rare instances, be done by its own Certification and Engineering Bureau, which issues a technical acceptance certificate (TAC). After certifying, the CB sends the file, test reports, Canadian representative details and listing fee to the Bureau, which lists the model on the REL.
- Is RSS-102 the same as the FCC RF exposure rules?
- The general-public SAR limits match: 1.6 W/kg over 1 g and 4 W/kg over 10 g in both 47 CFR 1.1310(c) and RSS-102 issue 6 table 3. The rest differs: RSS-102 adopts Health Canada Safety Code 6 with a 6-minute averaging time where the FCC allows 30 minutes, the SAR exemption is a Canadian power table (table 11) rather than the 1 mW and formula tests of 47 CFR 1.1307(b)(3), and the FCC treats the pinnae as extremities.
- Does the FCC accept SDoC while ISED always requires a CB?
- No, both regimes have a self-declaration route. The FCC uses SDoC (2.906) for most unintentional radiators and Certification (2.907) for intentional radiators (15.201(b)). ISED certifies Category I radio apparatus through a CB or the Bureau, while Category II apparatus are exempt from certification (RSS-Gen section 3.4.2) and follow a Supplier's Declaration of Conformity, as does ICES-003 equipment. Wi-Fi and Bluetooth under RSS-247 are Category I.
- Do I label with both the FCC ID and the IC number?
- For a product sold in both markets, yes, since each regime requires its own identifier: "FCC ID" plus the Grantee Code and product code (2.925, 2.926), and "IC:" plus the five-digit company number and a unique product number of up to eleven characters, with the HVIN (RSS-Gen section 9.4.4.1). The notices differ too: the 15.19 statement on the US side, and the RSS-Gen notices in both English and French in the manual on the Canadian side (section 9.3.1).
- Which databases prove the authorisations?
- The FCC Equipment Authorization System holds the FCC grant. ISED publishes the Radio Equipment List (REL) for certified Category I apparatus. Category II apparatus have no listing at all: ISED says there is no requirement to list them with the department, and the test report is kept by the responsible party and supplied on request.
- Who files an ISED modification, and how does it map to the FCC classes?
- RSP-100 issue 12, section 10: the certificate holder informs "the certification body (CB) or ISED" of any change that may affect compliance, so it does not have to be the original CB. Canada has four classes: C1PC (no notice unless the HVIN or PMN changes), C2PC (hardware changes affecting RF, notice), C3PC (firmware changes affecting RF, new FVIN) and C4PC (certified module in a new host that changes emissions or RF exposure, with the HMN). The FCC has three classes under 47 CFR 2.1043.