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MIC draft Circular 2022/TT-BTTTT - New list of products under MIC Type Approval and DoC scope

  24/02/2022

EXTENDMAX - Vietnam MIC has released draft Circular xx/2022/TT-BTTTT to replaced the Circular 11/2020/TT-BTTTT and Circular 01/2021/TT-BTTTT stipulating the new list of products under MIC Type Approval and Self-assessment DoC scope which shall take effect from July 01, 2022.

 

Highlighted features of the draft Circular xx/2022/TT-BTTTT of Vietnam MIC:

1. MIC has updated new national technical standards (QCVN) to the list including:

(1) QCVN 22:2021/BTTTT (for safety of ICT product)

(2) QCVN 65:2021/BTTTT (RF for WLAN 5GHz)

(3) QCVN 123:2020/BTTTT (RF for 40GHz ~ 246GHz SRD)

(4) QCVN 124:2021/BTTTT (RF for 76GHz ~ 77GHz vehicle radar)

(5) QCVN 127:2021/BTTTT (RF for 5G NR SA mobile terminal)

(6) QCVN 129:2021/BTTTT (RF for 5G NR NSA mobile terminal)

2. MIC confirms that the list is applied for products having HS code and product descriptions which match it only. However, if there is product which is not under the list, but under the scope of MIC QCVNs, organizations and individuals shall have to comply with according QCVNs and take responsibility for safety of the products by themselves.

3. QCVN 65:2021/BTTTT is accepted to replace QCVN 65:2013/BTTTT for importation clearance from July 01, 2022. But Type Approval certificate issued for QCVN 65:2011/BTTTT is still valid for importation until Jun 30, 2023. It means MIC runs QCVN 65:2021/BTTTT and QCVN 65:2013/BTTTT at the same time till July 01, 2023.

4. A large number of products have been moved from Annex 1 - List of products under TA and DOC list to Annex II - List of products under DoC only including 76~77GHz radar, generic SRD working in certain frequency bands, RFID 13.56MHz, walkie-talkie, and SHF.

5. Several products has been completely removed from the mandatory list such as river-use VHF, Inmarsat F77..due to lack of usage in pratice.

The new Circular xx/2021/TT-BTTTT shall be formally issued around March ~ April 2022 and take effect from July 01, 2022.

 

ExtendMax's comments:

1) Since Vietnam MIC runs QCVN 65:2013/BTTTT and QCVN 65:2021/BTTTT, organizations and individuals can apply for Type Approval certificate from May 2022 and use such TAC for customs clearance from July 01, 2022 for new models. For products which are going to be end-of-life before July 01, 2023, organizations and individuals can still use TAC according to QCVN 65:2021 and not need to apply for QCVN 65:2021/BTTTT.

2) Pursuant to Clause 2 of Article 4, If there is product which is not under the list, but under the scope of MIC QCVNs, organizations and individuals shall have to comply with according QCVNs and take responsibility for safety of the products by themselves. It leads to understanding that eventhough Type Approval cert is not required for customs clearance for the products which is out of the list, but if it is fallen under application scope of a QCVN, organizations and individual must apply for TAC still to ensure the compliance.

3) 5G NR mobile phones and terminal devices which has been certified under QCVN 47:2015/BTTTT for 5G NR now need to apply for QCVN 127:2021/BTTTT (RF for 5G NR SA mobile terminal) and/or QCVN 129:2021/BTTTT (RF for 5G NR NSA mobile terminal)

4) At this moment, Vietnamese laboratories does not have 5G callbox or spectrum analyzer for RF frequency over 40GHz yet so it could be a problem to apply for in-country test for the QCVN 123:2021/BTTTT, QCVN 124:2021/BTTTT, QCVN 127:2021/BTTTT and QCVN 129:2021/BTTTT. There is a chance that MIC will allows CE test report issued by ISO / IEC 17025 labs for these standards. But this will lead to another problem with QCVN 127:2021/BTTTT and QCVN 129:2021/BTTTT as VNTA is strict at TA application using CE report currently.

5) There is still confusion within the draft Circular, such as:

► Item 4 of Annex II describes that it is applied for products having frequency range of 40GHz ~ 246GHz, but applicable QCVNs are listing for 13.56MHz and 27MHz bands also.

► MIC states that maritime radar is exempt from "Product Quality Inspection" for imported products but orgnizations 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.

► Because 918.4 ~ 923MHz range is out of application scope of QCVN 73:2013/BTTTT, it is confused to identify which item on the list which UHF RFID 918.4 ~ 923MHz (which is not usued for traffic toll collection system) belongs to.

 

Download the Circular xx/2022/TT-BTTTT from MIC website: download link

Download English version of Circular xx/2022/TT-BTTTT translated by ExtendMax: download link

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