Dear sir or madam,
Please see attached letter.
In the draft measure, the standard QCVN 101:2020 will replace QCVN 101:2016, effective 1 July 2021. The industry has concerns about implementation of the standard. In the previous circular 11, there is a note for both Annex I (TA+SDoA) and Annex II (SDoA only) products that says only article 2.6 of QCVN101 is applied. But in the proposed replacement circular, this note is removed. This indicates that QCVN101 will be applied in its entirety. Furthermore, unlike other battery standards, QCVN101 includes performance requirements. These implementation features create the following impacts on industry:
Firstly, PCS extend their thanks to MIC for allowing industry the opportunity to provide comment on the new 2.4GHz standard QCVN 54:2020/BTTTT.
It has been noted that MIC’s new draft Circular 11/2020/TT-BTTTT does not include information regarding the validity of any existing Type Approval certificates obtained under the previous Vietnamese standard. Therefore, PCS are currently unclear as to whether any certification update effort will be required by manufacturers from 1st July 2021, once the new 2.4GHz standard is implemented.
PCS would like to respectfully urge MIC to permit manufacturers to retain validity of their existing Vietnamese Approval certificates until the point of renewal. Similar to MIC’s implementation strategy relating to the WWAN QCVN 117:2020 standard update, as stated in the Circular 43/2020/TT-BTTTT, permitting manufacturers to update to the standard at the point of renewal.
Many thanks in advance for your consideration.
Product Compliance Specialists, Ltd.
Dear Sir/Mdm, With regarding to MIC’s new draft Circular 11/2020/TT-BTTTT, we noticed it does not include information regarding the validity of any existing Type Approval certificates obtained under the previous Vietnamese standard. Zebra would like to propose to MIC to permit manufacturers to maintain validity of the existing Vietnamese Approval certificates until the point of renewal. Similar to MIC’s implementation strategy relating to the WWAN QCVN 117:2020 standard update, as stated in the Circular 43/2020/TT-BTTTT permitting manufacturers to update to the standard at the point of renewal. Thank you and appreciates your kind consideration.
With regard to this draft Circular 11/2020/TT-BTTTT, it draws our attention on the specific clause (see below) where it removed the exclusion of section 2.6 mandatory Lithium battery testing to QCVN101:2016/BTTTT. The original Circular stated as below:
(*) For this standard, the device shall not be subjected to Type Approval certification but only applied for Declaration of Conformity certification as devices listed in Annex II of this Circular. QCVN 101:2016/BTTTT is only applicable to mobile phone and subject to safety declaration which provided in Article 2.6 of this national technical regulation, transport requirement provided in Article 220.127.116.11 of this national technical regulation is not enforced for mandatory Declaration of Conformity.
With the removal of above exception, it implies that a FULL QCVN101:2020/BTTT testing is required. In another word, compliance to IEC61960-3 is mandatory beside the IEC 62133-2:2017. We have concerns in considering below factors:
With the above factors, we would like the authority to consider keeping the current practice per the original Circular 11/2020/TT-BTTTT. That is keeping the exclusion clause applicable to QCVN 101:2020/BTTTT. This help Vietnam gain competitive in global trade arena. Looking forward you favourite considerations. Thank you.
Dear sir or madam,
We hereby request you to put deep consideration on the decision of adding performance testing on secondary li-ion cell & battery for portable use.
Because as we all know, none of the other countries put such performance testing requirements on such cell & battery. Such amendment, if implements finally, will surely extend the certification period which will delay the input of end devices.
From the other part, cell & battery, whcih is the raw material of many end devices. The extension of mandatory certification will absolutely make it harder to start production of end devices at the same time like in other countries.
Hope your authority can do consider it once again and remove the requirements of performance testing on secondary li-ion cell & battery.
If all manufacturers shall proceed the whole test items including IEC61960-3 on the standard, most of manufacturers don't have an ability and resource based on ISO17025 to do in-house testing with IEC61960-3. And even though it will be tested through 3rd party, it will require huge load and time because of IEC61960-3 testing method. And already many manufacturers including us might have been testing only safety portion with QCVN 101:2020 reports for many products to meet the effective date 2021-07-01. So we are giving appeal to keep the original note.