EXTENDMAX - On Feb 08, 2023, Vietnam MIC has released draft circular on the new list of wireless and ICT products under MIC ICT Type Approval and Self-assessment DoC scope. The formal version of this circular shall replace the Circular No. 02/2022/TT-BTTTT dated May 16, 2022 and take effect from July 01, 2023.
Update: formal version of this draft, the MIC Circular 04/2023/TT-BTTTT, has been released
1. Highlighted features of the new circular of Vietnam MIC:
1.1. MIC has updated new national technical standards (QCVN) to the list
(1) QCVN 18:2022/BTTTT (National technical regulation on electromagnetic compatibility for radio communication equipment) replaces QCVN 18:2014/BTTTT
(2) QCVN 130:2022/BTTTT (National technical regulation on electromagnetic compatibility of wireless audio equipment in the frequency range 25 MHz to 2000 MHz)
(3) QCVN 131:2022/BTTTT (National technical regulation on NB-IoT devices, LTE Cat M)
(4) QCVN 132:2022/BTTTT (National technical regulation on electrical safety for telecommunications and information technology terminal equipment)
1.2. MIC has clarified the RF standards applicable for 5G NR phones
The Ministry of Information and Communications clarified the scope of application of QCVN 127:2021/BTTTT and QCVN 129:2021/BTTTT to mobile phones and 5G NR terminals. Smartphone products must be able to operate in the 5G NR stand-alone (5G SA) and non-stand-alone 5G (NSA) bands, will be under mandatory scope of both standards simultaneously.
1.3. Update HS codes of goods according to Circular No. 31/2022/TT-BTC
The list of products and goods of group 2 has been updated with HS codes and descriptions of goods according to the contents of Decision No. 2125/QD-BTTTT dated November 21, 2022 of the Ministry of Information and Communications on the adjustment of some HS codes on the List of potentially unsafe products. In this draft version, new HS codes (or changed HS codes) are included in the list for convenience in searching and applying.
1.4. Some other small adjustments to the list of products and goods of group 2
- Amend and supplement product and goods description for radio identification equipment (RFID) mentioned in section 2.8 Appendix I (excluding equipment mentioned in item 4.2 Appendix II), and description description of products and goods for equipment in Section 4.1, Appendix II (consistent with applicable regulations).
- Short-range device, including NFC, operating in the bands 13.553-13.567 MHz; 26.957-27,283 MHz; 40.66-40.7 MHz; 5725-5850 MHz, 24.00-24.25 GHz is moved from Appendix 1 (under TAC and SDoC at the same time) to Appendix 2 (only need SDoC).
- Additional notes applicable to QCVN 47:2015/BTTTT; QCVN 132: 2022/BTTTT.
- Changed electrical safety standards applicable to DECT phones from QCVN 22:2010/BTTTT & QCVN 22:2021/BTTTT to apply QCVN 132:2022/BTTTT.
- The list of products of group 2 adds the E-UTRA narrowband IoT terminal at section 1.1.16 (applying the newly issued QCVN 131:2022/BTTTT), and the personal FM radio device is removed at section 2.10 (equipment not imported for many years).
1.5. Taking effect date of the draft circular on the list of group 2 products and goods
The draft circular to replace Circular No. 02/2022/TT-BTTTT is expected to officially take effect from July 1, 2023.
2. ExtendMax's recommendation regarding the new draft Circular:
a) Regarding implementation of the QCVN 132:2022/BTTTT
- Particularly for DECT phones, QCVN 132:2022/BTTTT is listed in Appendix 1 and marked with a (***) remark, this means that QCVN 132:2022/BTTTT is the applicable standard for Type Approval certification scheme. Therefore, DECT phones that have been certified for conformity according to QCVN 22:2010/BTTTT and/or QCVN 22:2021/BTTTT will have to undergo re-certification procedures according to QCVN 132:2022/BTTTT to continue being imported to Vietnam after July 1, 2023.
- For other products such as laptops, desktop computers, TVs, tablets, Set-top-boxes... QCVN 132:2022/BTTTT is confirmed as the standard under self-assessment of declaration of conformity (SDoC) issued by enterprises (not the applicable standard for certification of conformity). Therefore, the application of QCVN 132:2022/BTTTT does not affect the certificates of conformity issued before January 1, 2024 for products within the scope of application of QCVN 132:2022/BTTTT.
- The MIC temporary accept test report issued by oversea and local ISO/IEC 17025 accredited test laboratories according to IEC 62368-1:2018, with corresponding technical requirements, for conformity assessment according to the QCVN 132:2022/BTTTT. It means the IEC 62368-1:2018 must listed all applicable test cases of the QCVN 132:2022/BTTTT still in order to be accepted by the VNTA. Accordingly, applicants and importers must submit ISO/IEC 17025 certificate of test lab which is still valid, together with Type Approval and/or Declaration of Conformity application.
b) Recommendations on the application of QCVN 131:2022/BTTTT and QCVN 18:2022/BTTTT for NB-IoT
Currently, domestic laboratories lack the conditions to test QCVN 47:2015/BTTTT and QCVN 18:2014/BTTTT for NB-IoT products. Therefore, it is expected that testing QCVN 131:2022/BTTTT and QCVN 18:2022/BTTTT in domestic laboratories will also face difficulties. Especially when testing in MRA laboratories, the cost can be up to hundreds of millions of dong for a standard. We hope that the Ministry of Information and Communications will allow businesses to use foreign test results according to ETSI standards to facilitate manufacturers and importers.
c) Recommendations on the application of QCVN 127:2021/BTTTT and QCVN 129:2021/BTTTT
Because domestic testing laboratories are still not qualified to test QCVN 127:2021/BTTTT and QCVN 129:2021/BTTTT for 5G NR phones and terminals, it is expected that the Ministry of Information and Communications will continue to allow using test reports issued by domestic and foreign laboratories certified with ISO/IEC 17025 for ICT conformity certification process.
In the past period, importers faced many difficulties in getting 5G NR phones certified mainly because foreign test results according to ETSI EN were exempted from some test cases under CE rules, but these test cases are still required by the VNTA to certify conformity according to QCVN 127:2021/BTTTT and QCVN 129:2029/BTTTT. This is a requirement that has arisen in the past period, not a new requirement, but it is the requirement that many manufacturers or importing companies find it most difficult to meet due to the very high cost of 5G NR testing. In order to a smooth certification of conformity process, manufacturers and importing companies should actively test the full range of ETSI criteria, including those exempted from CE RED regulations.
d) Regarding other wireless product operate in frequency bands higher than 40GHz
Beside the QCVN 127:2021/BTTTT and QCVN 129:2021/BTTTT, MIC will also allows test report issued by ISO/IEC 17025 test laboratory for RF standards for products having operating frequency over 40GHz such as QCVN 123:2021/BTTTT, QCVN 124:2021/BTTTT. This will be specified by a MIC guidance letter which shall be issued on around Jun 15, 2023 and similar like the MIC letter No. 2361/BTTTT-KHCN.
e) Other confusion within the Circular 02/2022/TT-BTTTT
→ MIC states that maritime radar is exempt from "Product Quality Inspection" for imported products but organizations or individuals still have to make self-assessment Declaration of Conformity before use. However, Pursuant to Decree 132/2008/ND-CP (amended and supplemented by the Decree 74/2018/ND-CP) SDoC is a part of the "Product Quality Inspection" process. MIC has not yet released guidance for applying for SDoC for maritime radar without applying for PQIR.
f) Other MIC QCVN technical regulations released recently
Other MIC technical regulations which draft version has been released recently like QCVN 117:2023/BTTTT and QCVN 55:2023/BTTTT shall be included in list of product under TAC and SDoC 2024~2025 period.
Download the Draft Circular from MIC website: https://mic.gov.vn/pages/duthaovanban/danhsachduthaovanban.aspx
English version: updated later
Contact information for ICT Type Approval services and consulting
EXTENDMAX VIETNAM COMPANY LIMITED
Hotline: +84 915 836 555 | Hanoi: +84 24 6666 3066
Email: consultant@extendmax.vn | phuong.tran@extendmax.vn
HO: ExtendMax Villa, C01-L18 An Vuong, Duong Noi urban area, Duong Noi ward, Ha Dong district, Hanoi City, Vietnam
Test laboratory: BT02-21, An Hung urban area, To Huu street, La Khe ward, Ha Dong district, Hanoi City, Vietnam
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