GEN-51—Implementation of the requirements for the evaluation of software in software-controlled measuring devices

Category: General
Issue date: YYYY-MM-DD
Effective date: YYYY-MM-DD
Revision number: N/A
Supersedes: N/A

Table of contents

1.0 Purpose

This bulletin outlines how Measurement Canada (MC) will implement new requirements for the evaluation of software as part of the type approval of software-controlled measuring devices pursuant to section 3 of the Weights and Measures Act (WMA) and section 9 of the Electricity and Gas Inspection Act (EGIA). The requirements are entitled: Requirements for the Evaluation of Software in Software-Controlled Measuring Devices.

2.0 Scope

This bulletin applies to all software-controlled measuring devices to be approved for use in trade in Canada.

3.0 References

4.0 Limitations

The Requirements for the Evaluation of Software in Software-Controlled Measuring Devices (hereby referred to as the "Requirements") do not apply to the approval of standalone software applications to be used in trade.

Sections 8.0 and 9.0 of the Requirements apply when software-controlled measuring devices have specific configurations or technical features identified in those sections.

The Requirements apply to the approval of devices with the ability to perform traced updates. Where a device has been approved for traced updates, the legally relevant software in the device can be updated without the need for device reverification or examination under the applicable Act.

5.0 Implementation of the requirements

5.1 New device approvals

Measurement Canada is implementing the Requirements according to the following schedule:

  • As of Month Day, 2026, any software-controlled measuring device submitted for approval under the EGIA must comply with the Requirements. The device must also meet the requirements set out in the applicable device specifications. The new requirements for software evaluation will supersede any previous requirement prescribed in S-EG-05.
  • As of Month Day, 2031, any software-controlled measuring device submitted for approval under the WMA must comply with the Requirements. The device must also meet the requirements set out in the applicable device specifications.
  • A device that is submitted for approval prior to the effective date of the Requirements, but is evaluated or approved after that date, will be evaluated against the requirements in accordance with the timeline specified for the applicable Act (WMA or EGIA).

5.2 Previously approved devices

5.2.1 Devices approved under the Weights and Measures Act

  • As of Month Day, 2031, all software-controlled measuring devices that are modified and resubmitted for evaluation must comply with the Requirements before a new or revised notice of approval (NOA) can be issued.
  • Software-controlled measuring devices that were evaluated and approved by MC prior to the requirements coming into effect will maintain their approval status.

5.2.2 Devices approved under the Electricity and Gas Inspection Act

  • As of Month Day, 2026, all software-controlled measuring devices that are modified and resubmitted for evaluation must comply with the Requirements before a new or revised NOA can be issued.
  • Devices previously approved by MC will maintain their approval status.

5.3 Previously installed devices

  • Devices that are currently installed and used in trade and for which there has been no change to the approval, will not be impacted by the new software requirements.

5.4 Gas analysis devices subject to the moratorium on sealing requirements

  • As of Month Day, 2031, all new software-controlled gas analysis devices (densitometers, relative density meters, calorimeters and gas chromatographs) must be evaluated during type approval for compliance with the Requirements, including sealing provisions.
  • As of Month Day, 2031, all software-controlled gas analysis devices that are resubmitted for evaluation must be evaluated for compliance with the Requirements, including sealing provisions.
  • For software-controlled gas analysis devices that are currently in service, sealing must be done in a manner specified in the device specifications or the notice of approval. (Note: For devices that have been granted temporary permission to be put into service without sealing, consult bulletin G-24)
  • All software-controlled gas analysis devices previously approved by MC will maintain their approval status. (Note: Refer to the document on the moratorium on sealing requirements.)

6.0 Software evaluation methods

The Requirements are based on the International Organization of Legal Metrology's (OIML) guidance document entitled OIML D31: General Requirements for Software-Controlled Measuring Instruments. Measurement Canada has adopted a different approach, in some respects, to evaluate and review software against certain requirements.

  • MC will not evaluate software through source code analysis. Rather, MC will require that approval applicants provide an attestation of source code and software compliance.
  • MC will evaluate software based on functional testing in conjunction with a documentation review. The documentation provided to MC must meet the requirements prescribed in section 10.0 of the Requirements.

Approval applications that do not include the required attestation or that include incomplete documentation will be considered unacceptable for the purposes of type approval.

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