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ISED vs FCC: which radio authorisation?

Guide, ISED vs FCC

For a radio product crossing the North American border, the United States and Canada feel like one market with two paperwork stacks. The FCC and ISED Canada share a common engineering heritage and a mutual recognition arrangement that lets a single laboratory report serve both. Yet the authorisations are separate filings, the identifiers differ, the exposure rules carry their own report formats, and Canada adds a bilingual labelling layer. This guide puts the two regimes side by side: a decision table first, then each axis explained, and finally a clear answer to the question every project hits, which authorisation do you actually need.

The fastest way to scope a dual programme is to read the two regimes on the same row. The table below maps each axis; the sections that follow explain the rows that matter most.

AxisFCC (United States)ISED (Canada)
AuthorityFederal Communications CommissionInnovation, Science and Economic Development Canada
Radio rulebook47 CFR Part 15, 22, 24, 27, 90RSS-Gen, RSS-247, RSS-130/132/133/139, RSS-210
Non-radio EMCPart 15 Subpart B (Class A / B)ICES-003 (Class A / B)
RF exposureOET Bulletin 65, KDB 447498 (SAR 1 g)RSS-102 (aligned SAR, own procedures)
Self-declaration pathSDoC for unintentional radiatorsNone for radio; ICES-003 declared
Third-party pathCertification via a TCBCertification via an ISED-recognised CB
IdentifierFCC ID (Grantee Code + Product Code)IC: Company Code + Product Code
Public databaseEquipment Authorization System (EAS)Radio Equipment List (REL)
MRA recognitionAccepts ISED-accredited lab reportsAccepts FCC-accredited lab reports
Foreign-party requirementUS Agent for Service of ProcessCanadian Representative (Category I)
Post-grant changeClass II Permissive ChangeEquivalent filing with original CB
Label languageEnglishFrench and English (bilingual)

None of these rows lets you merge the two grants. The MRA shares laboratory data, not certificates. A product needs both a live FCC authorisation and a live ISED authorisation to ship into both countries.

The Federal Communications Commission writes its technical requirements directly into Title 47 of the Code of Federal Regulations. There is no delegation to an external standards body for the limits themselves: 47 CFR Part 15 carries the unlicensed and unintentional-radiator rules, while Parts 22, 24 and 27 carry the licensed cellular bands. The methodology references IEEE-published standards, ANSI C63.4 for digital devices and ANSI C63.10 for unlicensed radios. See the FCC pillar for the full scope.

Innovation, Science and Economic Development Canada succeeded Industry Canada in 2015, retaining the historic "IC" prefix on identifiers. ISED structures its requirements into two normative families: RSS (Radio Standards Specifications) for intentional emitters and ICES (Interference-Causing Equipment Standards) for unintentional emitters. RSS-Gen is the umbrella standard for administrative, labelling and report-format rules; band-specific RSS standards sit beneath it. Full detail is in the ISED Canada guide.

Both regimes share the same goal, keeping equipment from disturbing the spectrum, but a US engineer reading a CFR section number will not find a one-to-one Canadian clause. The mapping is functional, not textual: Part 15 Subpart C corresponds to RSS-247, Part 15 Subpart B corresponds to ICES-003, OET 65 corresponds to RSS-102. The standards numbers, the report templates and the marking text all differ.

Equipment authorisation: SDoC and Certification

Section titled “Equipment authorisation: SDoC and Certification”

The single largest structural difference is the self-declaration option.

Under 47 CFR Part 2 Subpart J the FCC offers two paths:

  • SDoC (Supplier's Declaration of Conformity): a self-declaration the responsible party signs after testing, used mainly for unintentional radiators under Part 15 Subpart B. No federal identifier is issued and no third party reviews the dossier.
  • Certification: a third-party procedure where a TCB reviews the test report and issues an FCC ID. This is mandatory for intentional radiators (Wi-Fi, Bluetooth, cellular and similar transmitters).

The mechanics of the Grantee Code, FCC ID structure and TCB review are covered in FCC ID, Grantee Code and TCB.

ISED has no SDoC equivalent for radio apparatus. Every intentional emitter, licensed (Category I) or licence-exempt (Category II), goes through an ISED-recognised Certification Body. Category I yields a Technical Acceptance Certificate; Category II yields a Declaration of Conformity produced by the CB. Both result in an IC identifier and a REL entry.

The non-radio digital portion is the exception: ICES-003 compliance is declared by the manufacturer rather than CB-certified, mirroring the FCC SDoC logic for the unintentional-radiator side.

Device typeFCC routeISED route
Digital device, no radioSDoC (Part 15 Subpart B)ICES-003 declaration
Wi-Fi / BLE moduleCertification, FCC ID via TCBCertification, IC via CB (Cat. II)
Cellular deviceCertification, FCC ID via TCBCertification, IC via CB (Cat. I)

The asymmetry matters for budgeting: a purely digital product can self-declare on both sides, but the moment a transmitter is on board, the FCC SDoC option disappears and both regimes require third-party review.

An FCC ID joins two parts: the Grantee Code (the first three to five characters, unique to the company, assigned through the Equipment Authorization System) and the Equipment Product Code (chosen by the grantee). The full ID appears on the device label or as an e-label and is searchable in the EAS.

An ISED identifier reads "IC: Company Number + Product Code". The Company Number is five characters for newly assigned codes (for example 20001); some legacy codes are shorter and may carry a trailing letter (for example 21A). It is allocated once per manufacturer; the Product Code is defined by the manufacturer and must be unique within the Company Number. The format and history predate the 2015 ISED rename, hence the retained "IC" prefix.

The FCC delegates routine grants to accredited Telecommunication Certification Bodies; the agency itself no longer issues most grants. ISED delegates to recognised Certification Bodies. Many North American organisations (CETECOM, UL, TUV SUD, Element, Bureau Veritas and others) hold both accreditations, so a single firm can file both dossiers from one engagement. The two grants remain distinct legal acts even when the same organisation issues them.

RF exposure is where the two regimes look most alike and trip up the most projects on detail.

AspectFCCISED
Reference documentOET Bulletin 65, KDB 447498RSS-102
SAR limit (head/trunk)1.6 W/kg over 1 gbroadly aligned, 1.6 W/kg over 1 g
MPE limitsdistance-based, per banddistance-based, per band
Exemption tablesKDB-based SAR exemptionsRSS-102 SAR exemption tables
Report formatFCC report templateRSS-102 template, distinct metadata

The limits are practically the same, but the procedures, exemption thresholds and report formats differ. The common production path is a single measurement campaign on a shared phantom, then post-processing into two reports, one for the FCC TCB and one for the ISED CB. Both rest on the ICNIRP and IEEE C95.1 lineage, which is why the underlying physics is shared. See SAR procedures for the measurement mechanics.

The Canada-US Mutual Recognition Arrangement

Section titled “The Canada-US Mutual Recognition Arrangement”

The MRA is what makes a dual programme economical. Its scope and its limits both matter.

What the MRA does:

  • A laboratory accredited by the FCC (through NIST NVLAP or A2LA) can produce a test report a recognised ISED CB will accept, and the reverse holds for an ISED-accredited laboratory feeding an FCC TCB.
  • A single report can reference both rule sets, FCC Part XX and the matching RSS, with the corresponding limits stated for each.
  • Radio emissions and RF exposure measurements are reused rather than repeated.

What the MRA does not do:

  • It does not merge the certificates. Two dossiers are filed, one to a TCB and one to a CB, even when the same firm holds both roles.
  • It does not waive band differences. The test plan must cover the union of bands operated in both countries; Canadian and US cellular band plans are close but not identical.
  • It does not replace the REL entry or the FCC EAS grant. Each authority checks its own database.

In practice the marginal cost of adding ISED to an existing FCC programme is modest: the heavy measurements are shared, and the extra work is a cover letter, the ICES-003 report, label and bilingual manual adaptation, and the CB review queue. Budget a few weeks of incremental calendar rather than a second full campaign. For a broader trans-Atlantic view see EU-US dual certification and CE vs FCC EMC.

Both regimes require the identifier on the product and a user notice in the manual, but the wording and language obligations diverge.

The FCC ID must appear on the device label or as an e-label compliant with Section 2.935. The user manual carries the Part 15 interference statement in English.

The IC identifier follows the "IC:" prefix on a physical label or an e-label compliant with RSS-Gen Section 5.5. The decisive Canadian difference is language: the RSS-Gen and RSS-247 statements must appear in both French and English for products distributed in Canada, in line with federal bilingualism and the Quebec Charter of the French Language. A monolingual English manual is a frequent cause of customs blockage.

For a product sold in both markets the FCC ID and the IC identifier may share one label, provided each is clearly separated and legible. The notices themselves cannot be merged into a single sentence: the FCC and ISED wordings differ, and the Canadian text must be bilingual.

Step by step: running a dual ISED + FCC programme

Section titled “Step by step: running a dual ISED + FCC programme”
  1. Scope the bands. List every operated band in both countries and map each to its FCC Part and its RSS standard. Note the band-plan gaps.
  2. Select an MRA-capable laboratory. Confirm the lab is accredited on at least one side and recognised under the MRA so its report serves both.
  3. Build one test plan. Cover the union of bands, the RF exposure campaign, and the non-radio emissions (Part 15 Subpart B and ICES-003).
  4. Run the campaign once. Radio emissions, RF exposure (OET 65 and RSS-102), unintentional emissions.
  5. Choose the body or bodies. Pick a firm holding both a TCB accreditation and an ISED CB recognition to file both dossiers from one engagement, or two separate bodies.
  6. File the FCC dossier. TCB review, FCC ID grant, EAS publication.
  7. File the ISED dossier. CB review, IC identifier, Company Code and Product Code, REL listing.
  8. Produce the combined label and bilingual manual. FCC ID plus IC identifier, English plus French notices.
  9. Maintain both grants. A change affecting RF characteristics triggers an FCC Class II Permissive Change and the equivalent ISED filing with the original CB.

For realistic durations see Certification timeline and for budgeting see Certification costs.

PitfallConsequenceAvoid by
Assuming an FCC ID covers CanadaNo REL entry, customs blockageFiling a separate ISED dossier
Treating the MRA as a single certificateMissing one grantFiling two dossiers, sharing only test data
Omitting the ICES-003 reportIncomplete ISED dossierIncluding both RSS and ICES reports
Monolingual English manual for CanadaCustoms blockage, recall riskBilingual French and English notices
Confusing RSS-247 and RSS-210CB return, partial retestMapping Wi-Fi/BLE to RSS-247
Forgetting the Canadian Representative (Cat. I)Suspended procedureDesignating a representative before filing
Testing only US bandsRetest for Canadian-only bandsCovering the union of band plans upfront
Undeclared post-grant changeWithdrawal, possible recallFiling Class II PC and the ISED equivalent

The short answer: if you ship the product into both countries, you need both, and the MRA makes the second one cheap. Use this logic:

  • US market only: FCC authorisation alone. SDoC if the device is a non-radio digital product, Certification with an FCC ID if it transmits.
  • Canadian market only: ISED authorisation alone. ICES-003 declaration for the digital portion, CB certification with an IC identifier if it transmits.
  • Both markets (the common case): plan a single MRA-based test campaign, then file both dossiers. The FCC ID and the IC identifier are separate, the EAS and REL entries are separate, and the label and manual carry both regimes and both languages.

There is no scenario in which one authorisation substitutes for the other. The MRA shares engineering effort, not legal authorisation. Scope both from the start and the marginal cost of the second is measured in weeks, not in a duplicated programme.

Sources & references

  1. 47 CFR Part 15: Radio frequency devices , eCFR www.ecfr.gov/current/title-47/chapter-I/subchapter-A/part-15
  2. 47 CFR Part 2, Subpart J: Equipment Authorization Procedures , eCFR www.ecfr.gov/current/title-47/chapter-I/subchapter-A/part-2/subpart-J
  3. FCC Equipment Authorization , FCC www.fcc.gov/engineering-technology/laboratory-division/general/equipment-authorization
  4. RSS-Gen: general requirements for compliance of radio apparatus , ISED Canada ised-isde.canada.ca/site/spectrum-management-telecommunications/en/spectrum-allocation/rss-gen-general-requirements-compliance-radio-apparatus
  5. RSS-102: RF exposure compliance of radiocommunication apparatus , ISED Canada ised-isde.canada.ca/site/spectrum-management-telecommunications/en/spectrum-allocation/rss-102-radio-frequency-rf-exposure-compliance-radiocommunication-apparatus
  6. Radio Equipment List (REL): official search portal , ISED Canada sms-sgs.ic.gc.ca/equipmentSearch/searchRadioEquipments?execution=e1s1
  7. Canada-US MRA on telecommunications conformity assessment , ISED Canada ised-isde.canada.ca/site/spectrum-management-telecommunications/en/certification-standards/recognition-arrangements-and-foreign-test-facilities