Richard, the word Manual does not have an "s" like the word Labels. I would
disagree with their requirement for multiple manuals as there is no s.
Contact ISED as Charlie suggested.
Jim Bacher, WB8VSU
[email protected]
JBRC Consulting LLC
On September 21, 2025 11:50:46 PM Richard Georgerian
<[email protected]> wrote:
Greetings all,
Our company is currently in the process of getting the ISED certification
for a USB connected product that uses the radio frequency 13.56MHz to read
credentials. The product has three marketing names. In short, the only
difference is the firmware, model name and part number. The printed circuit
board, trace layout, components used, bill of materials, enclosure, and
mechanical parts are identical. The TCB for ISED has advised us that the
rules for manuals have changed recently. It has changed now such that each
model name is to have its own separate manual. And subsequently, not to
list the other models in the same manual. In the past, we have had multiple
model names of the same product family in one manual, as long as the
information and regulatory verbiage for each model is separate from the
other models, so that there won’t be any confusion between the models.
I did request from the TCB if there was a rule in a standard that can be
cited for the manual requirement. Their response is that there is nothing
in writing in a standard that details a separate manual for each model name.
The product will have one IC ID for the three model names, as the models
are considered part of a family.
The TCB sent a screenshot from a TCB workshop with the guidelines for
manuals. Item 9 is red lined below to show the requirement that the TCB is
using to justify the one manual for each version of the product. Our
company’s interpretation of the statement is, having one manual with all
three model names identified and that each model is to have its own product
label to show the model name and part number. Embedded in the part number
is the firmware version. I did try to indicate that these are guidelines,
not mandatory or “shall” requirements
TCBC workshop presentation
The TCB sent a response to my interpretation of why we can have one manual –
“The reviewer receives training from IC about the user manual requirements.
There is no standard that can be provided for this requirement.
So if client wants to get more details, it is better to discuss with IC
directly.”
To keep things moving with ISED, we have undertaken the task of creating
three separate manuals. And in parallel to contact ISED directly for a
clarification on manuals for products in the same family.
I have confirmed with the TCB for the FCC, that one manual is acceptable
for the three model names.
It would be helpful if someone in the group that already has an ISED
contact information regarding such guidelines that they can send the
information. Also, it would be helpful if the group can confirm such a
requirement from ISED regarding manuals.
I look forward to any assistance or advice from the group. In the interim,
I will be searching on the ISED website for the contact information and
subsequently, assistance in this matter.
Thank-you all in advance,
…Richard Georgerian
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