Dear Valued Customers and Friends, hope this announcement finds you well.
We’re writing here as a follow up of SDPPI Technical Guidance event that was held on February 6th 2019. This seminar-like event that took place at Lorin Hotel Sentul, Bogor, West Java, was mainly concerning abut new Telecommunication and Informatics Ministry Regulation Number 16 year 2018 technical guidance and socialization, as well as about how this new regulation affects on the current certification process.
And as usual, there are several updates we obtained from the event that was officially opened by SDPPI director himself, Mr. Ir. MOCHAMAD HADIYANA, M. Eng, as explained below.
1. Application of New Regulation and When Did It Start To Be Effective
New Telecommunication and Informatics Ministry Regulation Number 16 year 2018 has been officially applied on December 31st 2018 and started to be effective right on that day. So, there is no grace period of this new regulation application.
Do this regulation affect on the product that has been certified before the application day? No. This regulation is applied onward, for the product that has the certificate’s issued after the the enforcement date of new regulation (December 31st 2018).
So, for the product that has been certified before new regulation’s applied, they are not affected, which means these products still follow the provisions of previous regulation number 18th Year 2014 about Telecommunication Tool and Devices Certification. As a result, they don’t need to follow the new labeling requirements on new regulation number 16th Year 2018, including adding QR Code and Warning Sign on the packaging, as well as reporting photos of label, QR Code, and Warning Sign.
However, if products that have been certified before the effective date of new regulation are re-certified again, after this re-certification process they need to follow new regulation. This is because new certificate from re-certification process is issued after the issuance date of new Regulation Number 16 Year 2018.
2. Label, QR Code, and Warning Sign Confirmation
From the first place, new labeling requirement has triggered so many questions. And on yesterday’s SDPPI Technical Guidance Event , most of these questions have been answered. We arranged these labeling requirements detail in form of Q&A for simpler understanding
Is there any specific requirement for label, QR Code, and Warning Sign size?
[Answer] No, there is no specific requirement about label, QR Code, and Warning Sign size. They all just need to be in size that can be easily viewed by bare eyes, not too small and not too big. Specifically for QR code, it needs to be easily scanned.
For pre-installed device which will be imported with the host product such as immobilizer, car key, or car audio that will be imported with the car, where manufacturer can attach the label, QR code, and Warning Sign?
[Answer] For pre-installed device, if it’s possible to attach label on the device, then label needs to be attach on the device. But, if due to the small size of the device (for example for car key), if it’s not possible to attach label directly on the device, it can be attach on user manual, either on device’s user manual (for example car immobilizer or car key manual, if any) or on host product’s manual (for example car manual). And because there is no packaging of pre-installed device, so QR code and Warning sign can be attached on User Manual as well.
Regarding QR Code, can manufacturer get AI file or clearer QR code picture from SDPPI website (because somehow, scanning QR code from the certificate can result blurred images at some points)?
[Answer] In SDPPI Technical Guidance Event, it’s found out that SDPPI plans to add “QR Code” menu that will be accessible within the system by logging in into applicant’s user account. From this menu, applicant will be able to download the QR Code file, so the file can appear clearer and easy to print compared to scanned QR code from the certificate.
Regarding the Warning Sign, does it have to be attached on the packaging of SRD product, or non-SRD product?
[Answer] It’s been confirmed that Warning Sign should be attached on the packaging of non-SRD product. Then, how if the product doesn’t have packaging? If so, we can attach the warning sign on the manual.
Still about Warning Sign, how to decide if a product is classified as SRD or non-SRD?
[Answer] Parameter of SRD and Non-SRD classification is on the regulation reference. In Indonesia, SRD is specifically regulated by Communication Ministry Regulation Number 35 Year 2015 (PERMEN Kominfo Nomor 35 Tahun 2015). If the regulation reference written on the certificate is this regulation, then the device is classified as SRD.
But, if there’s another regulation besides “PERMEN Kominfo Nomor 35 Tahun 2015” on regulation reference (for example the device also has BT or WLAN), it means that attaching warning sign becomes mandatory. You can check the regulation reference on top side of the certificate as shown below.
Are some technologies such as Bluetooth, WLAN, NFC, or Low Power classified as SRD, remembering that they have similar characteristics?
[Answer] No. Bluetooth, WLAN, NFC, or Low Power is not classified as SRD because they have their own regulation reference, not “PERMEN Kominfo Nomor 35 Tahun 2015”. Bluetooth refers to “PERDIRJEN NO 9/DIRJEN/2005”, WLAN 2.4 and 5 GHz refers to “PERMENKOMINFO NO 28 TAHUN 2015”, NFC refers to “PERMENKOMINFO NO 16 TAHUN 2016”, and Low Power refers to “PERDIRJEN NO 214/DIRJEN/2005”.
About Label, QR Code, and Warning Sign report, how long is the time period between certificate issuance and maximum time of reporting them by uploading the photos through SDPPI website?
[Answer] On article 18th of Telecommunication and Informatics Ministry Regulation Number 16 year 2018, it’s stated that certificate holder needs to upload photos of Label, QR Code, and Warning Sign on SDPPI website (by logging in into applicant’s user account).
Then, on Chapter IX of the regulation about Sanction, Article 58 (page 23) Paragraph 4 and 5 state that if applicant doesn’t upload the photos of Label, Warning Sign, and QR code within 30 working days after certificate issuance, there will be 1st notification letter from SDPPI.
After 1st Notification Letter, there will be 14 working days grace period to upload the label. If within that period applicant is still not uploading the photos of label, QR code, and Warning Sign, SDPPI will issue 2nd notification letter, and there will be more 14 working days of grace period.
If within this 2nd grace period photos are still not uploaded, there will be last (3rd) notification letter, which means the grace period is over. Applicant will be blacklisted and not able to apply new certification for the next 2 years.
Below is the timeline of the label, QR Code, and Warning Sign upload period.
Can Label, QR Code, and Warning Sign are uploaded in form of draft or format, instead of real photos?
[Answer] No. Label, QR Code, and Warning Sign should be uploaded in form of real photo of them attached on the product, packaging, or user manual. Each photo (Label photo, QR code Photo, and Warning Sign Photo) that will be uploaded needs to contain 2 columns, consisting of close up photo and full photo of the product or packaging where Label, QR Code, and Warning Sign are attached. Below is the example of the label photo that needs to be uploaded. Same format is also applicable to QR code and Warning sign.
How if within the Label, QR Code, and Warning Sign reporting period, photos are not ready yet because the packaging is still not ready too?
[Answer] In this situation, manufacturer can make 1 packaging for reporting purpose only, and then attach the Label, QR Code, and Warning Sign on this packaging. But, please be noted by doing this way, the packaging, Label, QR Code, and Warning Sign format should be same with real/actual package, Label, QR Code, and Warning Sign.
Can manufacturers, importers, or distributors attach label in Indonesian Warehouse after passing the customs (not attach label in foreign factory right after production)?
[Answer] To answer this, we need to identify the kind of devices that will be imported. On Telecommunication and Informatics Ministry Regulation Number 16 year 2018, it’s stated on article 35 (Page 16 of the regulation) that surveillance and control can be conducted in 2 places: in border (customs), and post-border (after passing customs).
So, for product that will be checked in border, it needs to be attached with Label, QR Code, and Warning Sign already.
Below is the list of product that will be checked in-border (in customs).
|1.||8443.31.31||Machine Combination of Color printer, copier, and faximile Combination machine|
|2.||8443.31.39||Machine Combination of Non-Color printer, copier, and faximile Combination machine|
While for product that will be check in post border (product that’s not classified as in table above), it can be attached with Label, QR Code, and Warning Sign after passing customs or in the warehouse, as long as the product is still not entering to the market yet.
Test Report Validity Time
In the past, test report validity time is 3 years, regardless it is local lab test report or International Lab test report. But, in the new policy, there is no validity time of test report anymore. Both RF and EMC test reports are valid forever and can be used to apply as long as there is no changes on the device.
That’s all the updates we got from previous SDPPI Technical Guidance Event that was held in Bogor, West Java. Indeed, updates are mainly about labeling. While for other updates on this new regulation, you can check it in our previous blog post in this link, including the link to PDF file of new Ministry Regulation Number 16 year 2018 about Operational Provisions of Telecommunication Device and Tools Certification. And if you still have other question regarding the new regulation, please be free to let us know.