danhsachduthaovanban

 Dear sir or madam, 

 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:

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.

 Dear Sir/Madam,

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 2.6.2.7 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:

•  Currently, none of the country has mandated performance testing IEC 61960-3 requirement.
•  Long performance testing time required to full IEC 61960-3. > 3 months.
•  Limited battery local lab to perform the testing.

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.

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.