Richard:

 

Thank you for the information and follow up.

 

Best Regards and Be Safe

Bansi Patel

BRP Consultants

 <mailto:[email protected]> [email protected]

M:  <tel:909-260-9403> 909-260-9403

IEEE PSES Emeritus (2025-2027)

IEEE PSES, Board of Governors-at Large (2025-2027)

IEEE PSES San Diego Chapter Chair 2019-2025

IEEE San Diego Section ExCom, Member At Large 2024-2025 

Please plan to attend the Face-to-Face events:

SPCE 2025, (Nov 11-12, 2025), Portland, Oregon, USA

 <https://2025.ieee-spce.org/> https://2025.ieee-spce.org/

ISPCE 2026 (May 12-14, 2026), Burlington Area,  Massachusetts, USA

 <https://2026.psessymposium.org/> https://2026.psessymposium.org/

 

From: Richard Georgerian <[email protected]> 
Sent: Monday, December 8, 2025 9:08 AM
To: [email protected]
Subject: [PSES] Industry Canada product manual requirements.

 

Greetings all,

 

This is an update to my initial inquiry.

 

The response from the Canadian Certification and Engineering Bureau regarding 
that each model is to have its own manual or can multiple models be in one 
manual. 

 

As long as the models are nearly identical regarding enclosures, printed 
circuit board designs, assembly, etc. the model names can be in one user 
manual. Firmware need not be identical. Otherwise, there is a presumption that 
the models are different enough to warrant their own manual.

 

Thank-you,

 

…RichardG

 

From: Richard Georgerian <[email protected] 
<mailto:[email protected]> > 
Sent: Monday, September 22, 2025 7:45 PM
To: [email protected] <mailto:[email protected]> 
Subject: Re: [PSES] Industry Canada product manual requirements.

 

Greetings all,

 

Thank-you to everyone with their thoughts, analysis, and Industry Canada 
contact information. I have sent an inquiry to Industry Canada, awaiting their 
response. I’ll let everyone know of their response.

 

Thank-you,

 

…Richard Georgerian

 

From: Jim Bacher, WB8VSU <[email protected] <mailto:[email protected]> > 
Sent: Monday, September 22, 2025 6:17 AM
To: [email protected] <mailto:[email protected]> 
Subject: Re: [PSES] Industry Canada product manual requirements.

 

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] <mailto:[email protected]> 

JBRC Consulting LLC 

 

On September 21, 2025 11:50:46 PM Richard Georgerian <[email protected] 
<mailto:[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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