RSP-100 or DC-01? Which One Applies to Your Product

Most people meet RSP-100 and DC-01 in the same week: a test lab mentions a Canadian Representative, a launch date is already committed, and suddenly there are two acronyms and no obvious way to tell which one is yours.

Here is the plain version.

The one-line difference

RSP-100 covers certified radio apparatus: equipment with an intentional transmitter that ISED certifies and issues an IC ID for.

DC-01 covers terminal equipment: gear that connects to a telecommunications network, registered by declaration of conformity rather than certified.

Different processes, different paperwork, and a Canadian Representative requirement that appears in both.

Start with one question

Does your product intentionally transmit radio?

Bluetooth, Zigbee, Wi-Fi, Thread, sub-GHz, a proprietary RF link, cellular. If any of that is inside, you are in RSP-100 territory and you will end up with an IC ID. That covers most of what we see in lighting: Bluetooth mesh drivers, Zigbee controls, wireless occupancy sensors, networked luminaires, RF-commissioned emergency monitors.

If the answer is no, but the product connects to a telecom network, DC-01 is the likely path.

If the answer is no to both (it has digital circuitry but no radio and no network connection), you are probably looking at ICES-003 instead, which works differently again and needs no representative at all. We wrote about that separately, because some firms will happily sell you one anyway.

Where the representative requirement comes in

RSP-100, Section 4.1 is explicit: a Canadian representative is required when the applicant's company address is not within Canada. If your certification lists an address outside Canada, ISED needs a named representative in that file. No representative, no certification. And no certification means no legal sale in Canada.

DC-01, Section 6 carries an equivalent expectation for terminal equipment registered by declaration, with one practical difference worth knowing: DC-01 wants a signed Canadian Representative Letter. RSP-100 does not ask for that document.

That asymmetry is the source of a lot of avoidable cost.

Why you may be quoted twice

Because the two instruments are technically distinct, plenty of providers treat them as two products with two fees: one appointment for the radio, another for the terminal equipment, and the DC-01 letter as a line item on top.

Nothing about the regulation requires that. The same Canadian entity can be named under both, and the letter is a document, not a service tier. When you are quoted, ask whether one appointment covers both instruments and whether the Canadian Representative Letter is included. If the answer is no, ask why. Our own published pricing covers both under a single appointment.

The overlap case

A single product can land in both. A connected luminaire with a Bluetooth module and a network interface can need RSP-100 for the radio and DC-01 for the terminal side at once. Neither substitutes for the other, and being certified under one does not discharge the other.

This is common enough in connected lighting that it is worth checking early, while your test plan is still open. Discovering the second instrument after the first is certified means a second pass at paperwork you have already paid for. Getting that sequencing right is a large part of what our regulatory consulting work involves.

A short checklist

• Identify every radio inside the product, including modules you did not design
• Confirm whether the applicant address on the certification is inside or outside Canada
• Ask your lab, in writing, which instrument each part of the product falls under
• If a representative is required, confirm one appointment covers both and includes the DC-01 letter
• Check whether the digital, non-radio portion pulls in ICES-003 obligations too

If you are already blocked

If your lab has told you a Canadian Representative is required and you need the file to move, that is work we do: both instruments under a single appointment, the signed letter included, prices published, and attestation letters the same business day. You can see the full ISED Canadian Representative service here.

And if you are genuinely unsure which instrument applies, ask before you buy anything. Working that out is a short conversation, not a service.