What are the three procedural patterns?

Almost every regime is one of three. Supplier declaration, where the manufacturer tests, compiles a file and declares conformity on its own responsibility, as under the EU Radio Equipment Directive or the US SDoC route. Certification by a recognised third party, where an accredited body reviews the file and issues the approval, as with an FCC Telecommunication Certification Body. And national type approval, where the regulator itself grants the approval, usually with a local filing entity and sometimes with testing that must happen in the country. Knowing which pattern a market uses tells you the shape of the work before you read a single technical requirement.

Do test reports transfer between countries?

Reports transfer much more readily than certificates. The IECEE CB Scheme lets one accredited safety test report be reused across the member countries that accept it, which removes the safety testing step in each market rather than the approval itself. Mutual recognition agreements do something similar for conformity assessment between specific partners. What almost never transfers is the approval: each market still issues its own certificate, its own identifier and its own marking, on the strength of a report it accepts.

What is the requirement first-time exporters most often miss?

A local representative. Across the regional guides on this site, 21 of the schemes covered require the filing to be made by an entity resident in the country: an importer, a distributor, or a dedicated representative. Several regulators will not accept a dossier from a foreign manufacturer at all. It is not a formality either, because the representative usually holds the certificate, carries the documentary responsibility toward the authority, and can be difficult to change later. Choosing one is a commercial decision made under regulatory pressure, which is a bad combination, and it is worth doing before it becomes urgent.

In what order should markets be tackled?

Start with the market whose regime is strictest on the parameters hardest to change, because those decisions are frozen into the design. Frequency plan and transmit power come first, since they may force different hardware or a regional firmware variant. Then take the markets that accept transferable reports, so one test campaign feeds several filings. Leave for last the regimes needing in-country testing and a local entity, which have the longest lead times and depend on the technical file being stable. Sequencing this way means the expensive tests happen once.

Radio type approval worldwide: how it works

Author Hugues Orgitello Last updated 29 August 2026 ~4 min read

Guide, understanding regional approval

A radio product is not approved once. It is approved once per market, by an authority that does not have to accept anyone else's decision. The result looks like dozens of unrelated schemes, and this site documents them one country at a time. Underneath, there are only three procedural patterns and one requirement that catches almost everybody. This page is the map before the detail.

Why approval is national

Radio spectrum is a national resource, allocated by each state. The ITU Radio Regulations divide the world into three regions and set a framework, but within it every administration decides what its bands are for.

Two countries can assign the same frequencies to different services, permit different transmit powers, or reserve part of a band for defence. A regulator therefore cannot accept a foreign approval wholesale, because that approval was granted against a different plan.

The consequence catches people out: a product that is entirely legal in one market can be illegal in another with no change to the hardware. The radio has not changed. What it is being judged against has.

Three patterns, not dozens

Almost every regime is a variation on three procedures.

Supplier declaration. The manufacturer tests, compiles a technical file, and declares conformity on its own responsibility. No authority grants anything in advance. The EU Radio Equipment Directive works this way, as does the US SDoC route for equipment that qualifies for it.

Certification by a recognised body. An accredited third party reviews the file and issues the approval. The FCC's Telecommunication Certification Body scheme is the clearest example: the FCC does not itself examine most applications.

National type approval. The regulator grants the approval directly, usually requiring a filing entity resident in the country, and sometimes requiring that testing happen there.

Knowing which pattern a market uses tells you the shape and cost of the work before reading a single technical requirement. The regional guides on this site are each an instance of one of these three.

What crosses borders

Reports travel. Approvals do not.

The IECEE CB Scheme lets one accredited safety test report be reused in the member countries that accept it. As the CB Scheme guide puts it, the CB package collapses the safety testing step everywhere it is accepted, while each country still runs its own approval on top. Mutual recognition agreements do something comparable for conformity assessment between specific partners.

What almost never transfers is the approval itself. Each market issues its own certificate, its own identifier, and its own marking. A CB report can spare you repeating a test; it does not spare you the filing.

So the useful question about a new market is not "does it accept CE?" It is: which of my existing reports can be reused, and what must be redone?

The requirement most exporters miss

A local representative.

Of the schemes documented in the regional guides here, 21 require the filing to be made by an entity resident in the country: an importer, a distributor, or a dedicated representative. Several regulators will not accept a dossier from a foreign manufacturer at all. The wording recurs almost verbatim across the guides: without a local representative, the file is not accepted, or registration does not complete and goods do not clear customs.

It is not a formality, for three reasons:

The representative frequently holds the certificate, which means it is not straightforwardly yours.
It carries documentary responsibility toward the authority.
Changing it later is difficult, sometimes requiring the approval to be redone.

That makes it a commercial decision taken under regulatory time pressure, which is a poor combination. It is worth settling before it becomes urgent.

Frequency plans, and the variants they force

The band a product uses may be unlicensed in one market, licensed in another, and unavailable in a third. Sub-GHz is the usual casualty, because the short-range device allocations differ: a design built for one region's band cannot simply be shipped into another's.

Two workable answers, and one that is not:

A regional hardware variant, which multiplies certifications but is unambiguous.
One SKU with a regulatory domain table, selecting the permitted band and power at start-up. Several guides here describe this pattern for exactly that reason.
Shipping one configuration everywhere and hoping, which is how products get detained at customs.

A sensible order of attack

Decide the frequency plan first. It is the parameter hardest to change later, and it may force hardware or firmware variants that everything else depends on.
Do the declaration-based markets early. They need no external body, so they can proceed in parallel with design maturity.
Then the markets that accept transferable reports, so one test campaign feeds several filings.
Leave in-country testing and local-entity regimes for last. They have the longest lead times and need a stable technical file.

Sequenced this way, the expensive tests happen once.

Key takeaways

Approval is national because spectrum is national. The same hardware can be legal in one market and not in another.
Three patterns cover almost everything: supplier declaration, recognised-body certification, national type approval.
Reports travel, approvals do not. A CB report removes a test, not a filing.
21 of the schemes documented here need a local representative, who often holds the certificate and is hard to change.
Sequence by what is hardest to change. Frequency plan first, in-country testing last.

Frequently asked questions

Why does every country have its own radio approval scheme?: Because radio spectrum is a national resource and each state allocates it itself. Two countries can assign the same band to different services, permit different power levels, or reserve part of a band for the military. A regulator therefore cannot accept a foreign approval wholesale, because the foreign approval was granted against a different frequency plan. This is also why a product legal in one market can be illegal in another with no change to the hardware: the radio has not changed, the plan it is being judged against has.
What are the three procedural patterns?: Almost every regime is one of three. Supplier declaration, where the manufacturer tests, compiles a file and declares conformity on its own responsibility, as under the EU Radio Equipment Directive or the US SDoC route. Certification by a recognised third party, where an accredited body reviews the file and issues the approval, as with an FCC Telecommunication Certification Body. And national type approval, where the regulator itself grants the approval, usually with a local filing entity and sometimes with testing that must happen in the country. Knowing which pattern a market uses tells you the shape of the work before you read a single technical requirement.
Do test reports transfer between countries?: Reports transfer much more readily than certificates. The IECEE CB Scheme lets one accredited safety test report be reused across the member countries that accept it, which removes the safety testing step in each market rather than the approval itself. Mutual recognition agreements do something similar for conformity assessment between specific partners. What almost never transfers is the approval: each market still issues its own certificate, its own identifier and its own marking, on the strength of a report it accepts.
What is the requirement first-time exporters most often miss?: A local representative. Across the regional guides on this site, 21 of the schemes covered require the filing to be made by an entity resident in the country: an importer, a distributor, or a dedicated representative. Several regulators will not accept a dossier from a foreign manufacturer at all. It is not a formality either, because the representative usually holds the certificate, carries the documentary responsibility toward the authority, and can be difficult to change later. Choosing one is a commercial decision made under regulatory pressure, which is a bad combination, and it is worth doing before it becomes urgent.
In what order should markets be tackled?: Start with the market whose regime is strictest on the parameters hardest to change, because those decisions are frozen into the design. Frequency plan and transmit power come first, since they may force different hardware or a regional firmware variant. Then take the markets that accept transferable reports, so one test campaign feeds several filings. Leave for last the regimes needing in-country testing and a local entity, which have the longest lead times and depend on the technical file being stable. Sequencing this way means the expensive tests happen once.