Typical 'gold-plating' of a requirement, which we also suffer from in
UK, less now than earlier. If they wanted one manual for each version,
they would have written 'Provide individual manuals...'. Note in their
wording that 'manual' is singular, but 'labels' is plural.
On 2025-09-22 04:50, Richard Georgerian 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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