EXTENDMAX – Although the standards QCVN 127:2021/BTTTT and QCVN 129:2021/BTTTT for mobile phones and mobile communication terminals 5G SA, 5G NSA have been issued since 2021, the Vietnam Ministry of Information and Communications also has issued 2361/BTTTT-KHCN dated June 17, 2022 to "remove difficulties and obstacles and create conditions for organizations and individuals to carry out regulation conformity certification and egulation conformity announcement", many manufacturer and importers still face difficulties when applying for certificate of conformity (ICT type approval) for 5G mobile phones and 5G mobile communication terminals. So why do businesses still have problems with 5G phone conformity certification? Have the manufacturers and importing companies strictly followed the requirements and instructions of the Vietnam MIC on 5G phone conformity certification? What is the solution to get type approval certificate and proceed declaration of conformity for 5G mobile phones? Let's study the causes and solutions recommended by ExtendMax through the article below.
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National technical regulation QCVN 117:2020/BTTTT for 2G/3G/4G LTE mobile communication terminals is a relatively easy standard to apply and implement because the main content is the requirement of "technical characteristics", there is only a small requirement on "state management" that mobile phones manufactured or exported into Vietnam after July 1, 2021 are required to use 4G technology (can be integrate more 2G or 3G, but 4G is mandatory technology). In addition, there are many testing laboratories in Vietnam designated by the Ministry of Information and Communications to test 4G phones according to QCVN 117:2020/BTTTT and QCVN 86:2019/BTTTT, so the type approval application for 4G smartphones is quite convenient. Manufacturers and importer do not face any difficulty in importing, certifying and announcing conformity for 4G phones.
Unlike the QCVN 117:2020/BTTTT, the standards applicable to 5G mobile phones including QCVN 127:2021/BTTTT and QCVN 129:2021/BTTTT have many requirements on "state management" which include including the mandatory 5G bands that the phone must support, including the bands which are not common in other countries. Combined with the fact that testing laboratories in Vietnam at this time (December 2020) have neither been designated by Vietnam MIC nor accredited to test 5G NR mobile phones and terminals according to QCVN 127:2021/BTTTT (5G SA), QCVN 129:2021/BTTTT (5G NSA), QCVN 18:2014/BTTTT (EMC). So, many manufacturers and importers have not obtained ICT type approval certificate for 5G phones yet. Although the Vietnam MIC has also issued Official Dispatch No. 2361/BTTTT-KHCN dated June 17, 2022 to remove difficulties and obstacles and create conditions for organizations and individuals to carry out regulation conformity certification and egulation conformity announcement"
In practice, although the type approval certification of 5G mobile phones according to the new standards has been mandatory since July 1, 2022, during the period of July and August 2022 there was almost no manufacturer or importer has obtained type approval certificate for their 5G phones or 5G NR terminals, despite the huge import demand. From September to December 2022, there are a few more type approval certificate for 5G phones have beenn issued by the conformity certification organization, the Telecom Metrology and Quality Center (under the VNTA), but the number is still limited and application verification process takes longer time than usual. There are a number of manufacturers and importing companies that have to cut back on the list of products expected to be exported or imported to Vietnam due to problems in the certification process. So what are the causes? From ExtendMax's point of view, the main reasons are as follows:
1) Reasons related to the legal basis for conformity certification
Pursuant to Document No. 2361/BTTTT-KHCN dated June 17, 2022 of the Vietnam MIC, organizations and individuals are allowed to use test report issued by foreign laboratories or manufacturers "for type regulation conformity certification and regulation conformity announcement according to National Technical Regulation" which are QCVN 127:2021/BTTTT and QCVN 129:2021/BTTTT. There are different interpretations of this point, such as:
The first way to understand the basis for certification of conformity
Evaluation according to foreign test results for requirements on "technical characteristics", combined with requirements on "state management" of national technical regulations QCVN 127:2021/BTTTT and QCVN 129:2021/BTTTT to certify 5G NR phones.
In this case, the certification of conformity will be quite convenient because all manufacturers have satisfactory test results according to European CE standards (equivalent to QCVN 127:2021/BTTTT and QCVN 129:2021/BTTTT). If there are difficulties, it is only related to the requirements of "state management", namely the bands that the phone is required to support.
The second way to understand the basis for certification of conformity
Using foreign test results according to test methods of European CE standards, taking test results of each criterion to compare and evaluate conformity according to the limits of each criterion of the National Technical Regulation QCVN 127:2021/BTTTT and QCVN 129:2021/BTTTT.
When understood in this way, the certification of conformity will not be favorable for the following common reasons:
According to the CE standard with the 3PP test method, many test cases are exempt from testing when another relevant test case has been tested. Meanwhile, the corresponding contents have not been mentioned in QCVN 127:2021/BTTTT and QCVN 129:2021/BTTTT. The additional testing of those test cases may cost up to $20,000 ~ $30,000 for each product model.
Many CE test results with 3PP test method only evaluate "Pass" or "Fail", so there will be no detailed test results of each test case to compare with the limit in QCVN 127:2021/BTTTT and QCVN 129:2021/BTTTT.
2) Reasons related to conformity assessment method
Conformity assessment method according to European CE standards
For the implementation of regulations according to European standards, manufacturers follow the principle of "self-declaration" and are responsible for conformity. In case the market surveilance agency has evidence that the product does not meet the announced requirements, the manufacturer will be fined with huge amount (many times more than the fine of Vietnam). However, this approach reduces the requirements for product conformity assessment, the test results can be presented in any way, or in the form of the laboratory without problems.
Current certification body conformity assessment method
Because 5G phones are required to be type approved at a certification body designated by the Vietnam Ministry of Information and Communications, currently the Telecom Metrology and Quality Center (under the VNTA), the certification body will be the organisation who is responsible for the assessment of conformity for products (type approval), so the certification of conformity is verified very carefully, in detail. Therefore, foreign test results are often requested by some officers, in their personal opinion, to add additional contents to clarify the basis for evaluation. Meanwhile, these contents may not be included in the foreign test results because the test execution has started at the product R&D stage, before mass production, or for information security reasons. Common contents that foreign test results often do not meet include:
- Missing actual EUT, DUT photos front view, back view, and over view
- There is no photo of the label with the country of origin, model name of the EUT, DUT
- There is a slight difference between the test applicant and the manufacturer (e.g. a subsidiary of a manufacturer)
- The name of the laboratory on the test results is slightly different from the name listed on ISO/IEC 17025 certificate
- And some other differences in conformity assessment methods
3) Reasons related to the GCF certificate
MIC guidance No. 2361/BTTTT-KHCN dated June 17, 2022 of the Vietnam MIC has instructions on "testing report / testing results with test method validated by the Global Certification Forum (GCF). So what does this content mean? There are now multiple interpretations of the content of this guide, including:
Does the test lab must have GCF certificate?
Because the content contains instructions on "test method", it lead to understanding that the laboratory must have a certificate of GCF (Global Certification Forum) for test method for 5G NR phones, similar to that such as ISO 17025 or IEC 17025 certificate for testing laboratory. If understood this way, there are many laboratories in Taiwan or China that already have GCF certificates for tests on 5G phones, importers or manufacturers just need to go to those testing labs to have the phone tested there.
Products must have GCF certificate?
Since ISO 17025 or IEC 17025 is already a certificate of "test method" for the laboratory, the above guidance can be understood in the second way: the product must be tested with the tests approved by the GCF, it means the product must have GCF certificate for itself. Currently, not all 5G phones or 5G terminals are eligible to apply for a "GCF Certificate of Product" because the GCF certification cost is very high. When understood in this way, the certification of conformity for 5G phones will not be convenient and incur many costs.
4. Solution for 5G phone conformity certification?
With many years of experience in consulting market access requirements and type approval certification for mobile phone for the leading manufacturers and leading brands such as oppo, realme, OnePlus, Nokia... we can support you with all market access requirements and import procedures including:
→ Assess the CE test report required for Type approval application for 5G NR mobile phone, recomend modification and supplement if required
→ Evaluate the technical specification of the product, determine whether the products meets MIC requirements on operational conditions (frequency, Tx power) and allowed to be imported to Vietnam or not.
→ Evaluate documents, certificates of quality management system ISO 9001, determine the most suitable and lowest cost Type Approval certification system
→ Consulting and supporting the initial import procedures for customs clearance such as registration for performance testing, product quality inspection registration process for imported barcode scanner.
→ Acting as local representative for applicant in carrying out testing, certification, and conformity announcement procedures for mobile phone
→ Apply for ICT CODE for the importer, register importer's ICT mark or apply for ICT Mark modification upon request.
→ In case businesses need to import in small quantities, or receive goods without payment from parent companies or foreign partners, ExtendMax is capable and qualified to provide good import solutions. Or simply we provide Importer of Record IOR service to solve your worries and problems.
5. Contact information for market access requirements consulting
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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6. Preview of ICT Type Approval certificate for 5G smartphone
7. Preview of ICT Type Approval certificate for 5G tablet
