New Requirements for EMC Certification in Taiwan

Grace Lin, Michael J. Alvarado, and Han-Chang Hsieh

A new system for cerfifying products in Taiwan is replacing the type approval system. More paperwork is in store.

On July 28, 1999, the Ministry of Economic Affairs (MOEA) of the Republic of China promulgated the Measures Governing Registration of Product Certification (RPC). RPC covers both electromagnetic compatibility (EMC) and safety requirements. For EMC, RPC is scheduled to replace type approval (TA). Between January 1, 2000, and December 31, 2002, EMC-regulated products can be certified under either TA or RPC. Beginning January 1, 2003, however, RPC will be the only route to EMC compliance approval.1

The concept behind RPC is inherited from the conformity assessment procedures in the annex of the 93/465/EEC Directive.2 Under RPC, conformity assessment is divided into seven modules (see Table I) related to the design and production phases of products (see Figure 1). The authority—currently the Bureau of Standards, Metrology, and Inspection (BSMI) of MOEA—determines the applicable module or modules for each product category. These modules and a “List of the Products Subject to Measures Governing Registration of Product Certification” can be found on the BSMI Web site (http://www.bsmi.gov.tw).

Approval Process

The RPC approval procedure is shown in Figure 2. Under RPC, the applicant must be a manufacturing facility, not a marketing company. After receiving the application, BSMI reviews the administration requirements by using the “Notes for Attachment to Application for Registration of Product Certification” form. If the application meets administration requirements, BSMI assigns an application number (which becomes the certification number) and collects the application fee. The application is then forwarded to the technical department for review. If questions arise during technical review or if BSMI requests a test sample, the applicant is notified by a letter as shown in Figure 3. The applicant must respond within one month, or the application will be rejected. An example of a rejection letter is shown in Figure 4.

After the application passes technical review and meets the requirements, the registration number is assigned. A copy of the RPC certificate is shown in Figure 5. This certificate must be renewed every three years. The coding of the certification number is defined in the sidebar.

Figure 3. Example of a request letter from BSMI.	Figure 4. Example of a rejection letter from BSMI.

Application Package

An application package includes the following documentation, depending on the required modules.

Application Forms.

The following forms must accompany the application. These forms are printed in both Chinese and English.

• Application for the registration of product certification (see Figure 6).
• Note for attachment to application for registration of product certification (see Figure 7). This is a checklist for the application.
• Affidavit for the registration of product certification (see Figure 8).
• The following forms are required for the product categorized to the specified modules:
• Declaration of internal-control module for Module I (see Figure 9).
• Declaration of conformity-to-type module for Module II and for Module III (see Figure 10).

If the applicant is an agent of a factory located in a foreign country, a letter of authorization must be submitted with the application (see Figure 11).

Figure 5. An RPC certificate.	Figure 6. Application for the registration of product certification.

Application Fees. The primary application fee is NT$5000 ($152). For a series application, the fee is NT$3000 ($91). A fee of NT$300 ($9) is charged for reissuing a certificate. The fee must be paid in Taiwan dollars in the form of a bank check or in funds that can be wired to the BSMI account (account number: 0045 141 005727-5).

Factory Registration Document. A factory registration certificate and a profit-seeking-enterprise registration certificate must be submitted with the application. A foreign factory must present the factory certification documents issued either by its government or by a Taiwan-certified organization in that country. Conformity Assessment Documents. The required conformity assessment documents depend on the applicable modules, as shown in Table II.

Technical Document. If the technical document is submitted in a language other than Chinese, the competent inspection authority could request that the applicant provide a Chinese translation. The applicant must also certify that the translation is technically identical to the original.

User’s Manual. All user’s manuals must be written in Chinese except for those for information technology equipment (ITE) Class A devices. For Class A devices, ITE manuals can be in English. However, for Class A ITE equipment, a warning label in Chinese (see Figure 12) must be included in the user’s manual as well as on the product. For a large system, the user’s manual can include information for interface cards, peripherals, and components. Separate user’s manuals must be submitted for these items if they are omitted from the system manual.

Figure 7. Checklist of notes for attachment to the application for registration of product certification.	Figure 8. Affidavit to accompany the application for registration of product certification.

Circuit Block Diagram. A system block diagram should include the basic information necessary for a BSMI engineer to understand the product. The wording can be in either Chinese or English. If the block diagram is larger than the specified ISO A4 size, it should be folded so that it meets the size requirement. However, to date, BSMI has not rejected any application received on 8.5 x 11-in. paper.

EMC Modifications and Emission Source. BSMI requires a list of a product’s clock frequencies. Modifications implemented during compliance testing must also be listed in the application. Any EMC component not soldered onto the printed circuit board or molded onto cables is treated as a modification and must be so listed in the application. Such components include—but are not limited to—ferrites on the wires or cables and power-line filters.

Figure 9. Declaration of internal-control module for Module I.	Figure 10. Declaration of conformity-to-type module for Modules II and III.

Product Catalog and Photographs. Photographs must be 4 x 6 in. or larger and in color. Digital photographs can be printed from a color laser printer or from an ink-jet printer with lamination.

Type-Test Report. A test report is required for all products except those that fall under Module I. A copy of the test report can be obtained either from a BSMI-designated laboratory or from a U.S. conformity assessment body under the C-Taipei mutual recognition agreement. A list of qualified laboratories can be found either on the BSMI Web site or at the National Institute of Standards and Technology site (http://www.nist.gov).

Proof of Ownership. The company or agent stamp on the application is sufficient proof of ownership. Proof of ownership is required to facilitate resolving disputes between BSMI and applicants or between applicants and manufacturers.

Model Number. The application must clearly specify the model numbers and model names. For a series filing, all models must be clearly identified. The Taiwan customs department checks the models against their computer records. If a product’s model identification fails to match the computer record, the product will be rejected.

Label. The applicant must specify the label size, format, and location. How the label is to be affixed to the product must also be specified. Although the certification mark has no size restriction, the mark (logo), which must be a single color, should be clear and distinguishable. For small products, the mark can be on the carton or package. The BSMI certification mark and registration number must be affixed to the product before being exported to Taiwan. The three acceptable formats are shown in Figure 13.

Submitting an Application

The application must be submitted to the BSMI branchoffice associated with the location of the applicant or agent. The branch, rather than the main office, maintains the application file and related documentation.

Figure 11. An applicant who is an agent of a factory located outside of Taiwan must submit a letter of authorization like this with the application to BSMI.

Approval Time Frame. The average approval time for a primary filing is about four weeks. An additional two weeks may be required if BSMI requests a product sample. This time schedule does not include any lag time from the applicant. The approval time for a series filing is about two weeks.

Test Standards. Most of the specified test standards are Chinese National Standards (CNS), which can be ordered from BSMI. If no CNS standard is available at the time of testing, an international standard is acceptable. For electrical and electronic products, IEC standards should then be used. CNS test standards must be the latest versions officially made public or announced (released). BSMI announces the effective date of updated versions. Typically, the effective date is one year after the announcement. Certificates issued under the previous version of a standard are acceptable through the original validity date.

Series Product Filing. The series product filing is the method to use when seeking approval for a product family. The original certificate holder must submit the application. The series application can be included in the primary filing or can be filed separately after the primary application is granted. If filed separately, the original certificate must be submitted with the application. A new certificate is issued after the application is granted.

For compliance testing, the primary product must have all tests performed according to the test standard. For a series product, only variations that could affect a test result must be tested. If applications for a series and a primary product are filed at the same time, the series application must include test data for both. If the application for the series product is filed after the primary application is granted, a copy of the test report from the primary application must accompany the series application (in addition to the test report for the series product).

Associated Fees. In addition to the application fee, an annual administration fee of NT$5000 ($152) is required for each approved model, including series models. The annual fee takes effect the day the registration is issued. For the first year after the registration is approved, the competent inspection authority must notify the applicant of a due date for the fee. From the second year on, the fee must be paid before its anniversary date.

Inspection and handling fees are collected to pay for sample-taking inspections and follow-up actions for nonconforming products that have failed an inspection or follow-up action. Fees must be collected at the production site as follows:

• A fee (in accordance with the fee schedule set by the competent inspection authority) for commissioned inspections or tests.
• A handling fee of NT$7000 ($212) per day/per person at the factory for follow-up actions.

Figure 12. ITE Class A warning label.

Certificate Renewal. The certificate is valid for three years. The applicant (manufacturer) is required to renew the certificate every three years, based on the date of the primary application. Three months before the deadline, an applicant must submit the documents to be renewed. The registration number remains the same. The EMC technical department of BSMI, currently the Sixth Department, decides whether retesting is necessary for renewal. The application for renewal is treated as a new application, and the NT$5000 ($152) application fee applies.

For products obtaining certification based on the safety requirement (and before EMC enforcement), the certificate is valid for one year after the EMC enforcement is granted or three years after the safety certificate is issued, whichever period ends earlier.

Figure 13. Acceptable formats for the BSMI certification mark.

Transfer from Type Approval. To transfer from a TA certificate to an RPC certificate, applicants should submit an application for RPC three months before the January 1, 2003, deadline. The TA certificate can be substituted for a test report to obtain RPC approval. In addition to the test report, applicants must submit all documentation required for obtaining an RPC certificate.

BSMI Contacts. For administrative questions, including those pertaining to EMC regulations, contact the Third Department of BSMI at 4, Section 1, Chinan Road, Taipei, Taiwan; Tel.: +886 2 23431700. For all questions regarding applications, contact the Sixth Department of BSMI; Tel.: +886 2 26474243. U.S. applicants can also contact the MOEA office in Washington, DC; Tel.: 202/686-6400; Fax: 202/363-6294. The MOEA office can forward concerns to the appropriate BSMI department for a reply.

Conclusion

RPC has both advantages and disadvantages compared to type approval. For RPC, no lot-by-lot inspection is required, which eliminates two or three days needed for each shipment under TA. For imported products, an agent or manufacturer submits a copy of the certificate to the customs department with the products labeled appropriately. Under TA, there is a charge for each shipment. Under RPC, the charge is a flat rate of NT$5000 ($152) per year (which is the annual fee) plus NT$5000 ($152) for application renewal every three years. Under RPC, the cost is reduced for large quantities.

RPC, however, requires more paperwork for the application itself. The TA application form consisted of only a single page. Under RPC, the application contains a minimum of three pages. At the time of writing, applicants cannot check the status of an approval on the BSMI Web site. For large companies that subcontract to several manufacturers or factories, RPC requires each factory to apply for a certificate before placing a product on the market. In other words, if 10 factories manufacture the same product, the product will have 10 certificate numbers and registration numbers. This system creates a significant burden for a marketing company, which must obtain approval for each factory. Operational procedures must be established at each factory that ensure that products are labeled properly.

Effective immediately, all applications for lighting devices must be filed under RPC. For ITE equipment, safety approval is not yet required. BSMI is open to public comment regarding its EMC administration system. Address concerns to BSMI, Third Department, 4, Section 1, Chinan Road, Taipei, Taiwan.

Acknowledgments

The authors wish to thank Bing-Yuan Liou and Keh-Chiang Choa of BSMI for their support of this article. Special thanks to Ming-Der Wu, director of the Third Department of BSMI, and Roland W. Gubisch of Intertek Testing Services for reviewing this article.

References

1. Grace Lin and Han-Chang Hsieh, “EMC in Taiwan,” in (Washington, DC: IEEE EMC Society, 2000), 651¯656.

2. 93/465/EEC Directive, “Council Decision Concerning the Modules for the Various Phases of the Conformity Assessment Procedures and the Rules for the Affixing and Use of the CE Conformity Marking, which are Intended to be Used in the Technical Harmonization Directives,” European Commission, Brussels, 1993.

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