Hello all,
My employer manufactures automotive electronics sub-assemblies (ESA) with
an integrated Bluetooth transmitter. Recently, one of our customers has
requested we go through the necessary regulatory steps to make our product
compliant with Chinese Import/Export regulations. There are two situations
where I am looking for feedback.

In both situations the "product/ESA" would be provided only to an OEM for
fitment into an automobile and never available for the consumer to
purchase. (Not directly placed on the market)

In the first situation the "product/ESA" is fitted into an automobile
manufactured outside of China. The entire vehicle is then imported into
China. It is my understanding/interpretation that in this instance only the
Bluetooth transmitter needs approval. The reasoning being that the device
would be included in the vehicle when it goes through the proper test
process. The question being is it possible for representatives of the
manufacturer to be present during testing to make sure the product is in
the correct mode?

So, is anyone familiar with this process for Bluetooth transmitters? What
types of tests and test modes would the product need to support in
comparison to EN 300 328. As of this moment, the product needs quite a bit
of hand-holding or the use of expensive test equipment in order to jump
through all of the modes required for EN 300 328. Unfortunately, the
Bluetooth SIG site outlines only the process for type approval; we'd like
to avoid Type approval if possible given our volumes relative to the cost
involved.

The second situation involves importation of the "product/ESA" into China
for fitment into an automobile being manufactured in China. It is my fear
that Type approval (including factory inspections,etc) is needed in this
instance. Is this true for automotive products?

I'm not looking for an "end all" answer just thought it might serve for a
good discussion.

Jeremy Bos, NCE, P.E.
Johnson Controls Interiors

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