In Chile’s evolving telecommunications landscape, compliance does not end after a device is first introduced to the market. Manufacturers and importers are responsible for maintaining conformity under the Declaration of Conformity (DoC) model established by Resolution Exenta Nº 737 (2025). When a device undergoes technical or administrative changes, a Type Approval Replacement — more accurately, an updated DoC and QR‑linked webpage — ensures continued compliance and uninterrupted market access.
What Is a Type Approval Replacement?
A Type Approval Replacement refers to the process of updating a product’s Declaration of Conformity and related documentation when a technical or regulatory change occurs.
Under the new framework, SUBTEL does not review or approve these updates.
Instead, the manufacturer or importer is responsible for re‑issuing the DoC, maintaining updated records, and ensuring the QR‑linked verification page reflects the latest information.
When a Type Approval Replacement Is Required
A Type Approval Replacement is necessary whenever a product’s original characteristics change in a way that affects its compliance.
Typical scenarios include:
• Firmware or hardware modifications that alter radio performance or functionality.
• Frequency band additions or adjustments under Resolution Exenta Nº 1985 (2017).
• Changes to product branding or model identifiers.
• Labeling updates reflecting new requirements introduced by Resolution Exenta Nº 737 (2025).
• Administrative updates such as a new local representative or manufacturer address.
How the DoC‑Based Replacement Process Works
1. **Review Changes.**
Identify and document all differences between the previous and updated versions of the product.
Conduct testing if new hardware or firmware affects transmission characteristics.
2. **Prepare Updated Documentation.**
Revise test reports and technical files as needed to support the new declaration.
3. Issue a New Declaration of Conformity.
The manufacturer or importer must sign a new DoC stating that the modified product continues to meet SUBTEL’s regulatory
requirements.
This document is retained internally and not submitted to SUBTEL.
4. **Update the Verification Webpage.**
Modify the QR‑linked page to include the latest technical and administrative information (model number, representative contact, and date of update).
5. **Maintain Record Retention.**
Keep the previous DoC and supporting evidence for audit purposes to demonstrate a continuous compliance chain for each device.
Responsibilities of Manufacturers and Importers
Under the DoC system, the responsibility for updating and maintaining records lies entirely with the manufacturer or importer.
Foreign manufacturers must coordinate with their Chilean representative to ensure that all technical and administrative information remains accurate and accessible through the QR verification page.
If SUBTEL requests evidence of compliance or audit documentation, the responsible party must be able to provide it promptly.
Practical Tips for Smooth Replacements
- Maintain version control.
- Clearly label technical files and DoCs to differentiate between product revisions.
- Coordinate internally.
- Ensure engineering and compliance teams communicate when changes are planned or implemened.
- Update QR labels early.
- Avoid shipping devices with outdated QR links by reviewing each batch before distribution.
- Keep previous records.
- Maintain copies of old DoCs and test reports to show traceability if requested by SUBTEL.
- Confirm representative information.
- If the local representative changes, update the webpage immediately to reflect the new details.
Why Type Approval Replacement Matters
Keeping device information current is essential for legal distribution in Chile.
Outdated documentation or QR pages can lead to import delays or market withdrawals.
By maintaining accurate and up‑to‑date Declarations of Conformity, manufacturers and importers demonstrate ongoing compliance and reduce the risk of audit penalties.
This approach also aligns with global best practices for self‑declaration and traceability.
Preparing for the 2026 Enforcement
The mandatory QR and webpage requirements take effect on February 22, 2026.
All updates and replacements completed afterthat date must follow the Declaration of Conformity model.
Manufacturers and importers should begin implementing internal
procedures now to handle technical changes efficiently and maintain consistent labeling and documentation across their product lines.
Conclusion
The Type Approval Replacement process under Chile’s Declaration of Conformity system ensures that all wireless and telecommunication devices remain compliant as technology and regulations evolve.
By updating Declarations of Conformity, refreshing QR verification pages, and maintaining clear records, manufacturers and importers can preserve their legal market standing and support transparent consumer information in accordance with Resolution Exenta Nº 737 (2025) and Resolution Exenta Nº 1985 (2017).
