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Vietnam MIC: Circular 11/2020/TT-BTTTT – New list of devices subjected to Type Approval and Declaration of Conformity (2020)

MIC Vietnam has official released Circular 11/2020/TT-BTTTT dated May 14, 2020 - Regulations on list of products subjected to MIC Type Approval and Declaration of Conformity (2020)

EXTENDMAX - MIC Vietnam has officially released Circular No. 11/2020/TT-BTTTT to replace Circular No. 05/2019/TT-BTTTT - Regulations on list of products subjected to MIC Type Approval certification and Declaration of Conformity. The new Circular 11/2020/TT-BTTTT shall take effect from July 01, 2020 together with several new National Technical Regulations and Circular 10/2020/TT-BTTTT which are introduced by MIC Vietnam recently.

Highlighted features of the Circular 11/2020/TT-BTTTT:

1. Update newly-introduced National Technical Regulation QCVN 86:2019/BTTTT and QCVN 119:2019/BTTTT to the list. QCVN 86:2019/BTTTT shall replace QCVN 86:2015/BTTTT and QCVN 18:2014/BTTTT as EMC requirement for 2G/3G/4G LTE terminal devices.

2. Adding terminal device, base station, and repeater used in 5th generation of cellular network (5G) to the list. QCVN 47:2015/BTTTT and QCVN 18:2014/BTTTT shall be temporarily used as RF and RF requirements for 5G device until MIC introduce National Technical Regulations specifically composed for 5G devices.

3. Move wireless inductive loop charger, telemetry instrument, MISC and MITS device, radio access in 60 GHz band device, radar used on maritime ships and vessels, and digital immage transmission device from Annex I to Annex II. These devices are going to be under mandatory Declaration of Conformity scheme only.

5. Detailing descriptions and HS Codes for some SRDs to make the list clearer. Active RFID tag (having a power source) is listed under RFID product group, passive RFID tag is still exempted.

6. Detailing RFID reader and RFID tag used for automatic toll collection system (operate in 920 - 923 MHz band, RF power can exceed 500mW ERP) to solve customs clearance for these products which is sometimes happens now.

7. Allow some test items of specific national technical regulations to be exempted due to some reasons:

- Cost related to such test items are high and requiring long testing time (requirement on performance of QCVN 101:2016/TT-BTTTTT for lithium batteries)

- Requirement on the QCVN itself is not very clear or making confusion (item 2.6.2.7 of QCVN 101:2016/TT-BTTTT)

- Local laboratories are not able to test some specific test items yet (requirements on DVB-T of QCVN 63:2013/BTTTT or some national technical regulations applicable for maritime equipment)

8. All the Type Approval certificates and Notification for Acceptance of Conformity which has been issued before July 01, 2020 shall keep its validity continously untill expiry date or new applicable technical regulations enter in effect. 

ExtendMax's opinion and comments:

(1) Product Discription for tablet does not list cellular mobile network interfaces (2G/3G/4G/LTE/5G NR) but pursuant to item 2 of Article 4 of this Circular, Type Approval certification and Declaration of Conformity for these interfaces shall still be required if the tablet PC has such interfaces / functions.

(2) MIC has intented to move wireless sounds from Annex I to Annex II (according to the first darft version of this Circular) but finally wireless sound device is still listed under Annex I. This could be due to frequency management to avoid harlmful interfearances to mobile cellular networks.

(3) At this moment local labs are still not able to test 5G terminal device yet due to lacking of equipment. So MIC may release a temporary guidance for 5G terminal device or local laboratories must purchase such test equipment soon.

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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