Notice 2020 - DRS0007
April 22, 2020
Updated September 15, 2020 (Timelines added to Section B)
Certification Requirements for Products Employing Time-Averaged Specific Absorption Rate (TAS) Protocol
Products employing time averaging technology used for dynamic management of power levels to control Specific Absorption Rate (SAR) over a specific time period, such as QUALCOMM’s Smart TransmitTM, require pre-approval from ISED. ISED will only consider the acceptance and subsequent listing of products on the Radio Equipment List (REL) provided the following requirements have been met.
A. Consultation with ISED prior to seeking equipment certification for new and emerging technologies
When there are no standardized test procedures explicitly defined for new and emerging technologies, ISED shall be consulted to determine the necessary test methodologies for demonstrating compliance with applicable Canadian requirements (e.g. Canadian RF exposure limits).
To minimize delay in obtaining Canadian regulatory approval, applicants and other responsible parties (e.g. recognized test laboratories, certification bodies, product integrators etc.) should contact the Department as early as possible via the general inquiry web page.
B. Pre-approval of SAR time averaging protocols
Due to the lack of standardized test methods and protocols, ISED will be assessing all applications for product certification involving Time-averaged SAR (TAS) on a case-by-case basis. No product will be listed on the Radio Equipment List (REL) until ISED has validated and approved the TAS protocol.
ISED approval will be granted following a satisfactory review of the protocol documentation, and, when deemed necessary, via a physical evaluation.
When is ISED pre-approval required?
1. TAS protocols
Any TAS protocol shall be pre-approved by ISED.
Any module integrating an ISED approved TAS protocol requires pre-approval by ISED to validate host product integration.
3. Final products
Any final product that integrates an ISED approved TAS protocol requires pre-approval by ISED to validate that the final product took into account the integration considerations stipulated by the TAS protocol developer as well as the requirements set forth in this document.
Note: When the final product is a host integrating a certified module incorporating an ISED approved TAS protocol, ISED pre-approval is not required. However, the C4PC requirements detailed in section 10.4 and 11.4 of RSP-100, including any other requirements set forth in applicable standards, shall be met.
TAS pre-approval packages shall be submitted to ISED via the following email address: email@example.com. It is recommended to add “TAS pre-approval package” in the subject line of the email.
TAS protocol approval is a lengthy process which takes several weeks and in some cases months, especially, when a physical evaluation is warranted. Applicants and other responsible parties (e.g. manufacturers, product integrators, recognized test laboratories/certification bodies) should contact ISED as early as possible.
For modules or final products implementing an ISED approved TAS protocol, the TAS pre-approval package shall be sent to ISED at least 10 business days prior to the desired certification date.
Following a successful review of the TAS pre-approval package, ISED will provide an approval letter to the applicant. The applicant shall provide the approval letter to the Certification Body (CB) for the purpose of certification. The CB shall include the approval letter as part of the technical brief submitted to ISED for the product to be listed on the REL.
C. Time-averaging period
To demonstrate compliance with the SAR limits specified in Health Canada’s Safety Code 6 and ISED’s RSS-102, a time averaging period of 360 seconds shall be used; compliance shall be demonstrated in any 360 second period (rolling window). All products certified for the Canadian market shall implement a time-averaging period of 360 seconds at the chip set level.
D. Averaging methodology
As per Health Canada’s Technical Guide for Safety Code 6, the arithmetic mean shall be used when averaging SAR to demonstrate compliance with the Canadian radio frequency (RF) exposure limits. Averaging methods employing any types of weighting factors are not accepted.
E. Laboratory accreditation
All testing performed to demonstrate compliance of a radio apparatus with the requirements set forth in RSS-102, including its referenced and accepted normative standards and test procedures, shall be carried out by an ISED recognized testing laboratory.
It is critical that all device specific evaluation parameters used for compliance evaluations are assessed by a recognized test laboratory including, but not limited to, the following;
✔ Factors and methods used to determine applicable exposure conditions and operational modes
✔ Proximity or other sensors used for power reduction
✔ Output power
✔ Dynamic antenna tuning
✔ SAR evaluations
✔ Time-averaging transmitter (Tx) factor assessment
✔ TAS protocol validation
For proprietary test procedures and validation protocols that have been accepted by ISED, the recognized test laboratory shall demonstrate that they have been approved by the TAS protocol developer to assess their technology. An approval letter from the TAS protocol developer shall be provided as part of the technical brief submission. A TAS protocol developer’s in-house test laboratory is not required to submit an approval letter.
F. Product certification requirements
Manufacturers, importers, distributors and vendors have a legal obligation to ensure that Category I radio apparatus introduced in the Canadian marketplace have been certified and comply with applicable Canadian technical standards.
As per the requirements set forth in Section 4 (3) of the Radiocommunication Act, “No person shall manufacture, import, distribute, lease, offer for sale or sell any radio apparatus, interference-causing equipment or radio-sensitive equipment for which technical standards have been established under paragraph 6(1)(a), unless the apparatus or equipment complies with those standards.”
As per the requirements set forth in section 2.6.1 of RSS-Gen Issue 5, “No person shall import, distribute, lease, offer for sale, or sell Category I radio apparatus in Canada unless they are listed on ISED's REL”.
Equipment in the Canadian marketplace shall continue to meet those standards during their entire life-cycle.
G. Future Considerations
ISED is currently analyzing how time averaging can be implemented to manage compliance with other RF exposure requirements, such as power density above 6 GHz.
If you have any questions or require additional guidance, please contact ISED via the following web page: General Inquiry form
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