Notice 2020-DRS0022

December 7, 2020

Updated October 21, 2021

Guidance for SAR data re-use on depopulated variants from a reference model


This notice advises that ISED may permit SAR data re-use or test reduction for depopulated variant model(s) based on SAR test data from a reference model and highlights the requirements to do so.


To initiate this process, the applicant shall submit an inquiry to obtain pre-approval from ISED prior to submitting depopulated variant model(s) for certification. Such a request shall be sent to ISED Certification and Engineering Bureau at the following email address:



  1. The reference model should be certified in Canada.

  2. In all situations, the applicant shall fully test the reference model to ascertain compliance with all applicable requirements set forth in applicable Radio Specifications Standard(s) (RSS).

  3. Compliance data shall not be re-used for the certification of a variant model if the test report submitted to demonstrate the compliance of the reference model is more than 1 year old and/or if more stringent requirements (e.g. change in limit, change in measurement procedure) have come into force after the certification of the reference model.

  4. The reference model’s certification number shall be clearly identified in the variant model’s technical brief.

  5. The acceptance of data re-use will be dependent on spot checks being performed for conducted power and SAR.

  6. Simultaneous transmission shall be considered when demonstrating overall compliance.

  7. For standalone transmission, the following conditions shall be met:

    1. The conducted power of the variant model(s) shall be within the manufacturer’s tune-up tolerance. If tune-up tolerance(s) are exceeded, ISED shall be consulted.

    2. If the worst-case reported SAR value in the reference model’s original RF technical brief is less than or equal to 75% of the applicable SAR limits (1.2 W/kg for head/body configuration, or 3 W/kg for extremity configuration), spot checks must be performed on each depopulated variant for:

      1. The worst-case of each configuration identified by the reference model. Spot checks shall be performed separately for the worst-case head, body and extremity SAR whenever applicable. For example, if both head SAR and body SAR are listed in REL, at least two spot check measurements are to be done, one for head and one for body.

      2. Where the worst-case SAR value for the spot check is above 30% of the associated worst-case SAR in the reference model’s SAR report, additional testing shall be performed (following the guidance provided in 7.c.i).

    3. If the worst-case reported SAR value in the original RF technical brief of the reference model is above 75% of applicable SAR limits, spot checks must be performed on:

      1. The worst-case test configurations identified for the reference model for each antenna, each frequency band, and each technology.

      2. If any of the worst-case SAR values for the spot checks are above 30% of the SAR values in the original SAR report for the reference model, full testing is required.

  8. Where depopulated variant models share identical hardware but have different firmware than the reference model:

    1. All data and reports being used for certification of the depopulated variant model must be in accordance with RSS-102, its pertinent Supplementary procedures (SPR) and procedures accepted by reference.

    2. Spot checks on the variant model must be carried out if the reference model has any SAR values >75% of applicable SAR limits. The spot checks would consist of the worst-case of each configuration on the variant model.

    3. If the variant model has any unique RF power settings or features that provide enhanced/augmented capabilities that may alter RF characteristics (for any band or technology) compared to the reference model, then the variant model shall be tested in full for that band.

  9. All reports need to:

    1. Identify the models tested.

    2. Identify the differences in the models (making it clear if it is hardware only, software only or both hardware and software).

    3. Include only data for the bands / modes / features supported by the variant model (s) in order to clearly identify the highest RF exposure values for Canada; or identify the data for the bands/modes/features that are not supported by the variant model if included in the RF exposure briefs.

  10. With regards to controlled use devices, the SAR limits for controlled environment shall apply.


ISED notes that the use of SAR data re-use or test reduction for depopulated variant model(s) for certification purposes does not in any way prevent ISED from employing enforcement measures with regard to non-compliant readings reached outside of the test reduction methodology for the purposes of compliance with the Safety Code 6 limits specified in RSS-102.

Notwithstanding the above conditions, ISED may request full testing of variant models if deemed necessary.

For reporting purposes, the final reported SAR value(s) of a variant model shall be the worst-case value(s) from either the reference model or from the spot-check testing.

Should you have any questions, please use our General Inquiry form.