When it comes to global product certification, the smallest inconsistencies can lead to the biggest delays. Many manufacturers assume that FCC or CE test reports, a familiar model name, or a similarity declaration will suffice across borders, but that assumption can be costly. From country-specific test report validity rules to model name mismatches and restrictive labeling requirements, these seemingly minor details have the power to derail approval timelines, trigger retesting, or result in outright rejections. Understanding these often overlooked risks and knowing where missteps typically occur gives manufacturers the foresight to plan effectively, reduce rework, and keep certification projects on track.
Test Report Acceptance Rules Vary by Country
Relying solely on FCC or CE test reports as they were originally issued is a common but risky assumption when pursuing international certifications in certain countries. While many countries leverage these standards, they often impose additional requirements around report validity, recognized labs, or administrative details. These details can be buried in technical regulations and vary widely depending on the product type, approval route, or whether the certification is new or a renewal.
Missing these nuances can lead to last-minute rework, additional testing, or even rejected applications. Knowing which reports are still valid, which labs are approved, and renewal timelines are essential to keeping timelines and budgets intact.
Countries with Notable Test Report Acceptance Requirements
- South Africa –
- NRCS: Safety Test report must be under 3 years old for initial certification, under 5 for renewals.
- SABS: Accepts ILAC-accredited lab EMC reports under 3 years old or testing at SABS lab; UIN must be obtained before testing.
- Indonesia – Lab must be on the SDPPI/DJID approved list; RF and EMC report must be under 3 years old; local testing recommended.
- Malaysia – RF Test report must be under 5 years old.
- Saudi Arabia – SASO: Test reports must be under 3 years old; for safety only the 3rd version of IEC 62368 is accepted
- United Arab Emirates (UAE) – Only accepts IEC 62368 3rd edition
Model Name and Proper Labeling Importance
One of the most overlooked aspects of global certification is the consistency of the model name used across documentation, test reports, and product labeling. Regulatory agencies issue certificates to a specific model name not a part number, SKU, or marketing name. Any mismatch between what’s printed on the device label and what’s shown in the test reports or application documents can delay approvals or even invalidate certifications.
To avoid this, the model name should be locked in early in the development process, appear consistently on FCC and CE test reports, and match the labeling on the final product. Many countries now expect labels to include not just the model name and brand, but also the manufacturer, serial number, and country of origin. With label real estate often limited, manufacturers should proactively plan for both branding and regulatory requirements especially when devices will carry multiple country approvals.
Model Name Similarity Declarations are Not Always Accepted
Similarity declarations are often used to certify product variants that are technically identical to an already-tested model, differing only in minor details like model name or enclosure color. While these declarations can streamline approvals, their acceptance is far from universal. Some countries scrutinize declarations closely or reject them outright especially if the model’s name in the test report doesn’t match exactly.
For a similarity declaration to be considered valid, the products must be functionally and electrically identical. This includes matching RF specifications, output power, power ratings, and internal components. Even with a well-prepared declaration, regulators in several countries require the exact model name to appear on the test report and supporting documentation. To reduce risk, manufacturers should avoid relying on declarations for critical markets and ensure that all certification variants are properly represented in the technical file from the outset.
Some countries are especially cautious when it comes to declarations. Applications using similarity declarations may be rejected in Bolivia, Kuwait, Nicaragua, and Zimbabwe, depending on the clarity and consistency of the supporting documents. Others like India and Chile do not accept similarity declarations under any circumstance. These countries enforce strict compliance with national standards and require that each model undergo individual evaluation and testing.
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