Radio electronic means using WiFi and/or BLE technologies as well as different frequency ranges should get the following approvals:
- EAC Declaration /Certificate of Conformity
- Radio Frequency Center Conclusion
- FSS Notification
- FAC Declaration of Conformity
Taking into account that we deal with specific approvals such as FSS and RFC we should follow an established procedure and the consequence of getting all required certificates is essential.
Let’s go step by step:
1. FSS Notification
All devices that have encryption facilities and included in the list of products (2/19) subject to mandatory certification by the Federal Security Office of the Russian Federation (FSS) should get an FSS Notification. FSS Notification does not require samples for local testing, however, this is the first approval that should be obtained by the manufacturer. The reason is that other approvals such as RFC, for example, require samples for testing but in order to ship them and release from the customs, we need to submit FSS Notification. Thus, when the scope of the order includes an FSS Notification as well as RFC or EAC CoC, FSS Notification is the first approval that should be obtained.
The rules and requirements of getting FSS Notification are rather strict and this is why many manufacturers are afraid of it. However, WorldWideBridge have 11 years of experience in it having closed a great number of projects, so we will be delighted to assist you and accompany through the way that might seem difficult but in fact, it will be simple with us.
In order to make an application to FSS we should submit the following documents:
- Technical description of the device (can be in English)
- Draft of Notification (provided by us and approved by you)
- Legalized PoA (all requirements and templates are provided upon launching a project)
The general lead time of getting FSS is up to 15 working days once an application is done. Application is done when the draft is approved and the hard copy of the legalized PoA are provided. The lead time should be taken into account since it cannot be changed. The process for other approvals such as RFC or EAC CoC cannot be moved forward till FSS Notification is registered.
2. Radio Frequency Conclusion (RFC)
We have successfully gained FSS Notification.
The second step will be to proceed with RFC.
RFC is about frequency ranges which should be approved by the Radio Frequency Center of the Russian Federation.
Upon sending us an inquiry, we carefully study it and determine whether RFC is required or not. Some of the frequency ranges are allowed to be used in Russia without any licensing. Some of the ranges should be approved which means that RFC is required. Some of the ranges cannot be used at all in Russia and we inform you about it asking to adjust the ranges if you want to export such a device into Russia.
RFC is the most complex and time consuming approval but we cannot start with it since it requires samples that should be sent only once an FSS Notification is issued as stated above. Thus, the first step is to get FSS Notification if applicable and now we can move forward with RFC.
An application for RFC consists of the following steps:
- Temporary import permission (valid for 6 months)
- Samples delivery once Temporary Import Permission is obtained
- Testing
- RFC Conclusion (either positive if tests are conducted successfully or negative if not)
- Getting an Extract form the Register of radio electronic means
As far as you can see, the first step that cannot be ignored is getting a Temporary Import permission.
Before getting it, samples cannot be sent to Russia, otherwise they are returned back to the sender.
Once the Permit is received (10 working days), we can move with samples delivery.
Please, note that samples should be delivered and send back after testing to the sender within 6 months since the Temporary Import permission has a validity of 6 months.
Once samples are received, we are able to move forward with testing. General lead time for testing is 30 working days. Manufacturers should be ready for such a period since it is established by the authority.
Once testing is done and test report is prepared, we get a RF Conclusion.
Then the device is registered within 7 days in the Register of radio electronic means.
3. FAC Declaration of Conformity
Radio electronic devices tend to have WiFi or/and BLE technologies which means that they an access to the public networks.
Such devices should get FAC DoC
which is registered by the Ministry of Digital Affairs of the Russian Federation.
This approval can be issued either with local testing or without it. Thus, if you prefer to send a sample for local testing to apply for FAC, please, follow the requirement of getting first FSS Notification first. RFC and FAC DoC processes are not joint and thus can be held in parallel. However, if you prefer to avoid local testing, it is possible and in this case, we can move forward with FAC DoC and FSS+RFC in parallel all together.
4. EAC DoC/CoC
Radio electronic devices are usually subject to TR CU 040 (LVD) or/and 020 (EMC).
EAC certification
exists in two forms which are Declaration of Conformity and Certificate of Conformity.
When a device is subject to DoC, it means that we can avoid local testing and issue it based on EU test reports that should be translated into Russian (1d scheme of certification). In this case there is no need to send a sample and EAC can be launched in parallel with FSS/RFC and FAC.
However, if you want to issue DoC based on local testing (3d scheme) than we will need samples which can be sent once FSS is obtained. RFC and EAC are not connected so we should keep the requirements only for FSS.
If a device is subject not to DoC but to CoC, local testing is one of the main requirements and cannot be avoided. It means that we should stick to the rule and requirement of getting FSS Notification first to be able to import a sample for local testing according to EAC.
The most important thing that should be taken into mind is that we cannot reuse the sample for FAC DoC or RFC. When we register CoC after local testing and site audit among a rather big set of documents we should attach a customs clearance declaration confirming the date when the samples are delivered. This date should be not earlier than the date of our application.
We will not be able to reuse RFC sample for FAC DoC samples if the processes for these approvals are launched earlier and the samples are sent earlier than EAC is launched.
Thus, we should get a separate sample for EAC certification.
Moreover, the testing mode for EAC and RFC are different.
We require 1 radiated sample for RFC and 1 commercial sample for EAC.
Thus, manufacturers should be ready to send several samples to Russia for testing when it comes to projects which have a scope of RFC, FAC, EAC.
WWBridge have a solid experience with all mentioned approvals.
We have closed a great number of projects for European and Asian manufacturers and will be pleased to assist you as well.
Please, feel free to apply to us with any questions you may have regarding these approvals. You can send your inquiry through [email protected]/