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MIC Guidance No. 2305/BTTTT-KHCN for implementation of Circular 11/2020/TT-BTTTT

Guidance for Circular No. 11/2020/TT-BTTT. ISO / IEC 17025 test report accepted to replace QCVN standards applicable for 5G mobile phone, terminals and maritime radios

EXTENDMAX - On June 23, 2020, Vietnam MIC has released official letter No. 2305/BTTTT-KHCN (2020), guiding implementation of Circular No. 11/2020/TT-BTTT. ISO / IEC 17025 test report accepted to replace QCVN standards applicable for 5G mobile phone, terminals and maritime radios. Most of the contents are repeating guidance letters for former Circular No. 05/2019/TT-BTTTT or predicted in our previous article regarding the issuance of the Circular 11/2020/TT-BTTTT

Key features of the official letter No. 2305/BTTTT-KHCN (2020):

1. MIC allows to use CE reports issued by ISO/IEC 17025 accredited laboratories (both MRA labs and none-MRA labs) for conformity certification and declaration of conformity of mobile terminals using 5th generation of cellular network (5G). This content has been predicted by ExtendMax before by evaluating testing abilities of local laboratories in Vietnam.

2. MIC re-confirms CISPR 32:2015 RLV test report or later version of CISPR 32 (issued by designated local test lab or oversea labs recognized by MIC Vietnam) can replace report according to QCVN 118:2018/BTTTT. 

3. For laptops, notebooks, or tablets imported in small quantity, importer may ask permission from VNTA to use test report issued by oversea ISO/IEC 17025 accredited test laboratory for declaration of conformity of lithium battery to complete Product Quality Inspection Registration (PQIR) and declaration of conformity procedure.

4. MIC continues to allow test item under extreme test conditions can be covered by declaration of conformity on product datasheet or test report issued by oversea ISO/IEC 17025 accredited test laboratory

5. MIC continues to allow test report for DVB-T2 chassis/platform can be used for declaration of conformity for DVB-T2 smart TV.

6. For below listed standards (which are mostly applicable for marine transceiver and transmitter), MIC allows to use test reports issued by manufacturer or oversea ISO / IEC 17025 accredited test laboratories for conformity certification and declaration of conformity:

QCVN 24:2011/BTTTT, QCVN 26:2011/BTTTT, QCVN 28:2011/BTTTT, QCVN 38:2011/BTTTT, QCVN 39:2011/BTTTT, QCVN 50:2011/BTTTT, QCVN 51:2011/BTTTT, QCVN 52:2011/BTTTT, QCVN 53:2017/BTTTT, QCVN 57:2018/BTTTT, QCVN 58:2011/BTTTT, QCVN 59:2011/BTTTT, QCVN 60:2011/BTTTT, QCVN 61:2011/BTTTT, QCVN 62:2011/BTTTT, QCVN 67:2013/BTTTT, QCVN 68:2013/BTTTT, QCVN 107:2016/BTTTT, QCVN 108:2016/BTTTT and QCVN 116:2017/BTTTT

ExtendMax's comments and opinions:

- Pursuant to Circular 10/2011/TT-BTTTT, Self-assessment DoC must be based on the test report which organization or individual is "test applicant" (test report holder). Even incase the importer importing a small quantity of smart phones or tablets or laptops and allows to use oversea report according to IEC 62133 issued by ISO/IEC 17025 test lab for declaration of conformity, it is not possible to ask the shipper to provide test report under their name. So importing a small quantity of smart phones or tablets or laptops is still not possible because of samples requirements for testing and conditions of reports using to make SDoC.

- Similar to above case, when importers using CE reports for importation of 5G mobile terminals or 5G phone, importer shall also need support from manufacturer to provide SDoC signed by them because technically CE reports shall be issued under name of oversea manufacturer.

Please find the letter No. No. 2305/BTTTT-KHCN together with English translation (below)

Contact information for ICT Type Approval and PQIR services

EXTENDMAX VIETNAM COMPANY LIMITED

Hotline: 0915 836 555 | Hanoi: 024 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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Tran Thanh Phuong
I am Tran Thanh Phuong, a jurist specializing in Product Quality Law, Cyber Information Security Law, Customs Law, Foreign Trade Management Law, and Commercial Law. I am a consultant trusted by the world's leading technology corporations in the field of consulting on legal regulations and market access requirements for importing information technology products into Vietnam
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        EXTENDMAX VIETNAM COMPANY LIMITED

        Tax Code: 0106943741

        Email: consultant@extendmax.vn

        Hot line: +84 915 836 555 | Hanoi: +84 24 6666 3066

        Consulting CCP License: +84 915 836 555

        Reg. Add:P903, 9F, Tower A, Sky City Tower Complex, 88 Lang Ha street, Lang Ha ward, Dong Da district, Hanoi city, Vietnam

        HO: ExtendMax Villa, C01-L18 An Vuong, Duong Noi ward, Ha Dong, Hanoi, Vietnam

        Test Lab: BT02-21, An Hung urban area, To Huu street, La Khe ward, Ha Dong, Hanoi, Vietnam