RF approval Russia: the GKRCh bands and the GRChTs conclusion

RF approval Russia means two decisions taken by two different bodies. The State Commission for Radio Frequencies (GKRCh) decides which classes of device may operate in a band without an individual permit: Wi-Fi at 2.4 and 5 GHz, Bluetooth and short-range devices at the power limits its decisions list. The General Radio Frequency Centre (GRChTs) then issues the conclusion that Russian customs asks for when radio-electronic equipment or a high-frequency device is imported under section 2.16 of the EAEU unified list, or the model is found in the register of equipment that may be imported without one. The list is union-wide. The conclusion is Russian, and it is held by the importer, for one model at a time.

Which devices may transmit in Russia without an individual permit?

A device may transmit in Russia without its own frequency assignment when a GKRCh decision already covers its class. The decisions name the band, the maximum power and the type of use, and a device inside those limits needs nothing more. Wi-Fi at 2.4 GHz and 5 GHz, Bluetooth and the short-range devices in sensors, remotes and tags are the classes an exporter meets most. Anything outside a decision, by band, by power or by antenna gain, needs an individual frequency assignment, a different project with a different applicant.

The check happens at the datasheet, before anything is filed. We compare the declared band edges, the conducted and radiated power and the antenna against the decision for that class. A 5 GHz radio that opens channels permitted in one region and not in Russia is the recurring case: the hardware is fine, the region table in the firmware is the problem, and the fix is a firmware build locked to the Russian channel plan before the sample is described.

The other failure is a product filed with a band that no decision covers at all. It happens with proprietary sub-GHz links and with UWB. The application is then not slow; it is refused, and the device either goes back to engineering for a band change or into the individual assignment route.

What does customs ask for: the GRChTs conclusion or the register?

At the border the question is whether the device is on the list. EEC Board Decision No. 30 of 21 April 2015 "On measures of non-tariff regulation" carries the unified list of goods under non-tariff measures in trade with third countries, and section 2.16 of that list is radio-electronic equipment and high-frequency devices for civil use, including those built into other goods. The Eurasian Economic Commission's Tariff and Non-tariff Customs Regulation Department applies those measures, and Russia notified the decision to the WTO under its import licensing procedures. The list is union-wide. The permissive document is national, so each member state names its own issuing body; Kyrgyzstan, for one, notified an import licence from its Ministry of Economy.

In Russia that document is the GRChTs conclusion, issued for the model and the importer named on it. An RFC conclusion Russia customs will accept names one applicant and one model; a second importer of the same product files again. The alternative is the register of equipment that may be imported without a conclusion. If your model already sits in it, the entry does the work of the conclusion.

The way this goes wrong is a container. The EAC declaration is in the file, the encryption notification is in the register, the broker submits, and customs asks for the import permit for radio equipment Russia requires under section 2.16. Nobody applied, because nobody thought a smart thermostat was radio equipment. It is. Storage charges run while the conclusion is obtained, so we file it with the other permissions, before the vessel is booked.

Module or host: which one goes on the conclusion?

The conclusion describes the finished product as imported, and the radio parameters it carries must match a GKRCh decision. Where a pre-approved module supplies the radio, the module datasheet gives the band, the power and the reference antenna, and those figures go into the application under the host's name and model. The module manufacturer's own conclusion, if one exists, covers modules shipped as modules. It does not cover your appliance with that module inside.

Band, power and antenna are the three fields we check against the decision, and antenna is the one that moves after approval. A cost-down revision that swaps the module's reference antenna for a cheaper PCB trace changes the radiated power the decision limits, and a conclusion that names the old antenna no longer describes the goods in the container. The encryption notification fails the same way after a module swap; the conclusion fails after an antenna swap, and the border is where both surface. Tell us about an antenna change before the purchase order, and the conclusion is updated while the old stock still ships.

How does RF approval differ from FAC, the encryption notification and EAC?

Radio frequency approval Russia grants answers one question: may this device radiate on this band, and may it cross the border as radio equipment. The FAC certificate or declaration answers whether the device may attach to a public communications network, and it is issued in the communications certification system overseen by Roskomnadzor. The encryption notification answers whether its cryptography may be imported, is registered by the FSB and works across the whole union. The EAC declaration under TR CU 020/2011 on electromagnetic compatibility, with TR CU 004/2011 where the voltage is in range, answers whether it is safe; the EAC page for Russia covers the local applicant.

None of these substitutes for another. A Wi-Fi router carries all of them. The three Russian clearances take 4 to 10 weeks obtained in parallel, and the conclusion sits inside that window when the radio parameters are settled at the start. Where it runs long, the cause is the band check above: a channel plan or a power figure that has to be changed and re-declared.

The applicant for the GRChTs conclusion has to be established in Russia: an importer, a subsidiary or an appointed representative. We act as that applicant where the exporter has no local entity, and keep the conclusion separate from the encryption notification, which stays in the manufacturer's name, portable between importers.

The instruments behind RF approval in Russia

The unified list under Decision No. 30 is the same in every member state. The conclusion that satisfies it is issued nationally, so a Russian GRChTs conclusion does not clear the same goods into Kazakhstan or Belarus.