Vietnam MIC Stipulates New List of Products under Their Approval Scope
Summary of the New Circular
1. MIC has updated new national technical standards (QCVN) to the list including:
(1) QCVN 22:2021/BTTTT (for safety of ICT product, enforced for DECT phone only at this moment)
(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 applies to products having an HS code with product descriptions to match the code.3. Type approval certificates with either one of QCVN 65:2021/BTTTT and QCVN 65:2013/BTTTT are allowed for 5GHz ISM devices for importation clearance from July 1, 2022.4. 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, and SHF.5. Several products have been completely removed from the mandatory list, including river-use VHF, and Inmarsat F77 due to less importation. Recommendations on the current Circular.1) Since both QCVN 65:2013/BTTTT and QCVN 65:2021/BTTTT are still applicable, organizations and individuals can choose to apply for Type Approval with either version. However, for new applications, the client should apply for the new version QCVN 65:2021/BTTTT for longer validity Type Approval certificates. For products that are going to be end-of-life before July 1, 2023, organizations and individuals can still use existing Type Approval certificates listing QCVN 65:2013/BTTTT and will not need to re-apply for QCVN 65:2021/BTTTT if such certificate will not expire before July 1, 2023.2) At this moment, Vietnamese laboratories do not have 5G equipment yet, so they may not able to test and get MIC accreditation for QCVN 127:2021/BTTTT and QCVN 129:2021/BTTTT until middle of 2023. To solve this problem, Vietnam MIC will allow the use of test reports issued by ISO/IEC 17025 test laboratories for the certification process. Test reports from ISO 17025 accredited test labs that show the test standards are the same as QCVN 127:2021/BTTTT and QCVN 129:2021/BTTTT should be provided.
3) Besides the QCVN 127:2021/BTTTT and QCVN 129:2021/BTTTT, MIC will also allow test reports issued by ISO/IEC 17025 test laboratories for RF standards for products having operating frequencies over 40GHz, such as QCVN 123:2021/BTTTT, QCVN 124:2021/BTTTT.
4) Vehicle radars with 76~77GHz operating frequency band and other bands which is over 40GHz: Since the QCVN 124:2021/BTTTT only covers Vehicle radars 76 ~ 77 GHz within its scope, if the radar can be operated at a frequency range lager than 76 ~ 77 GHz (eg: 76 ~ 81 GHz), then the applicable regulation below applies:
– Vehicle radar 76 ~ 77 GHz needs to comply with QCVN 124:2021/BTTTT and EMC QCVN 18:2014/BTTTT.-Vehicle radar having operating frequencies higher than 40GHz but not including 76 ~ 77 GHz, need to comply with QCVN 18:2014/BTTTT (and QCVN 123:2021/BTTTT if it covers one or more of the 61.0 GHz ~ 61.5 GHz, 122 GHz ~ 123 GHz, 244 GHz ~ 246 GHz bands).
– If the vehicle radar operating frequency range is including, but larger than 76 ~ 77GHz (eg: 76 ~ 81 GHz), and not including either one of the 61.0 ~ 61.5 GHz, 122 ~ 123 GHz, 244 ~ 246 GHz bands, then it must comply to QCVN 124:2021/BTTTT, QCVN 18:2014/BTTTT only.
5) There are still confusing points within the Circular 02/2022/TT-BTTTT, such as:
– Item 2.8 of Appendix I specifies that it applies to RFID including 9kHz ~ 25MHz RFID (no exception for 13.56MHz RFID), but item 4.2 of Appendix II also specifies that it applies to 13.56MHz RFID. This means two items cover the same product, but the certification scheme is different. If the RFID 13.56 MHz is considered to be under the scope of Item 2.8 of Appendix I, it will need both Type Approval and SDoC. But if it is considered to be under the scope of item 4.2 of Appendix II, it will need SDoC only (no need Type Approval). This issue also occurs with item 2.2 of Appendix 1 and item 4.1 of Appendix II (4.1 is a part of 2.2).
Clarification from MIC /VTNA on these issues has been requested.
– Item 4.1 of Annex II applies to products having the frequency range of 40GHz ~ 246GHz, but applicable QCVN is listing 13.56MHz and 27MHz bands, also. Because Item 2 of Article 1 specifies, “This Circular applies only to products and goods having HS code and descriptions specified in List of products and goods in Group 2”, it leads to understand that Item 4.1 of Annex II applies to products having listed HS code and operates in 40GHz ~ 246GHz only. It means products operating in 13.56MHz and 27MHz bands are not under the applicable scope of Item 4.1 unless MIC issues another document to make this clearer.
– MIC states that maritime radar is exempt from “Product Quality Inspection” for imported products but organizations or individuals still have to make self-assessment Declarations of Conformity before use. However, pursuant to Decree 132/2008/ND-CP (amended and supplemented by Decree 74/2018/ND-CP) SDoC is part of the “Product Quality Inspection” process. MIC has not yet released guidance for applying for SDoC for maritime radar without applying for PQIR.
For more information about these upcoming changes to Vietnam regulatory requirements, or questions about any other global regulatory standards requirements, please contact Testing Partners at (862) 243-2677.
