SRRC Publishes Radio Equipment Filing Guidance

The Ministry of Industry and Information Technology Radio Authority (MIIT) of China provides updated answers to frequently asked questions regarding radio equipment sales compliance.

Frequently Asked Questions

  • Q: Which equipment require radio equipment sales records in order to maintain compliance when sold in the country?
  • A: According to the provisions of Article 48 of the regulations of the People's Republic of China on Radio Administration, the scope of equipment for sales filing is "equipment containing radio transmitter(s)/using radio transmission and is type approved". Non-radio transmitting equipment and radio transmitting equipment that do not require type approval do not require sales filing/records. Products requiring SRRC type approval but are not yet certified, cannot be manufactured and sold in China.

  • Q: Are short range radio transmitting equipment that received type approval prior to the regulation changes in 2016 required to have sales filings?
  • A: The regulations revised in 2016 stipulate that short-range radio transmission equipment does not need to obtain type approval. According to Articles 44 and 48 of the Regulations, the sale of these equipment does not need to have a sales filing.

  • Q: Does equipment with an embedded transmitter module require sales filing? If so, is the filing for the module or the entire equipment?
  • A: If the equipment embedded or using the radio transmitting module requires type approval, then the equipment shall be have a sales filing before entering the market and the type approval information of the entire equipment shall be submitted, but the type approval information of the radio transmitting module need not be provided.

  • Q: Does the manufacturer of the radio transmission equipment need to handle the sales filing?
  • A: The answer can be classified into three cases:
    1. If the manufacturer sells to end product users, agents, wholesalers, retailers, the manufacturer needs to handle the sales record.
    2. If the manufacturer is only responsible for production and is not responsible for sales, the unit responsible for the sales will handle the sales filing. The unit will have its own business license.
    3. If Company A is commissioned by Company B to produce the equipment (ie, OEM), and Company B is responsible for the sales of the equipment, then Company B handles the sales filing of the radio transmission equipment.

  • Q: Do importers importing type approved products for sale require sales filing?
  • A: Yes, the sales filing is required.

  • Q: How should products be marked to show they have been filed?
  • A: The filing number or QR code can be printed and posted in a prominent position in the physical business place. If it is sold online, the fiiling code or QR code can be marked on the home page of the online store.

  • Q: If there is no physical business place or online sales platform for consumers, only internal sales, how should we show the equipment has been filed?
  • A: The paper or electronic version of the filing number or QR code can simply be saved by the person responsible for handling the sales filing.

  • Q: After modifying the filing record information, will the record filing number or QR code also change?
  • A: No, the record filing number or QR code corresponds to the sales entity.

  • Q: What is considered a complete filing record?
  • A: A record is considered completed after the sales entity submits the equipment information on the sales filing information platform.

  • Q: Who is responsible for the different physical stores of the same company?
  • A: No, the record filing number or QR code corresponds to the sales entity.

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