Postel Certification for Toys and Low-Power Devices

What Is Postel Certification for Toys and Low-Power Devices?

Today’s toys and electronic devices increasingly use wireless technology to perform certain functions. Examples include remote-control toys, RC cars, children’s robots, smart toys, wireless sensors, wireless buttons, IoT devices, Bluetooth devices, and various other devices that use relatively low transmission power.

In the context of Indonesian regulations, the term low power or low-power device does not mean that the product is automatically exempt from Postel/DJID Certification. The certification requirement still needs to be assessed based on the technical characteristics of the device, including the frequency used, transmission power, communication technology, bandwidth, antenna type, and telecommunications function.

The main basis for telecommunications device certification is currently Minister of Communication and Informatics Regulation Number 3 of 2024 concerning Certification of Telecommunications Equipment and/or Telecommunications Devices. This regulation stipulates that devices complying with Technical Standards are evidenced by a Certificate.

Therefore, the term “low power” should be treated as one assessment parameter, rather than as the sole basis for determining that a product does not require certification.

Are Low-Power Toys Required to Have Postel Certification?

Not all toys are required to have Postel/DJID Certification. Toys that do not have radio communication functions and only use electronic components for internal functions, such as lights, sounds, or mechanical movements, need to be distinguished from toys that have radio transmitters or receivers.

For example, a toy car that only uses a battery to operate its motor is different from a remote-control car that communicates with a remote through radio frequency.

When a device uses wireless communication, an assessment needs to be conducted to determine whether the device is classified as telecommunications equipment and/or a telecommunications device that must comply with Technical Standards and obtain a Certificate.

Minister of Communication and Informatics Regulation Number 3 of 2024 defines telecommunications as the transmission, sending, and/or reception of information through wire, optical, radio, or other electromagnetic systems.

Therefore, the presence of a radio transmitter or receiver in a toy becomes one of the important aspects that must be examined.

What Is Meant by a Low-Power Device?

In practice, a low-power device refers to a wireless device that uses relatively low transmission power. One category specifically mentioned in the regulation is the Short Range Device (SRD).

Minister of Communication and Informatics Regulation Number 2 of 2023 concerning the Use of Radio Frequency Spectrum Based on Class License includes several types of devices in the SRD group, including Bluetooth IEEE 802.15.1, NFC, RFID, UWB, LR-WPAN IEEE 802.15.4, Wireless Power Transmission, Intelligent Transport System, and telecommunications equipment and/or devices with transmission power below 10 mW.

This shows that devices with transmission power below 10 mW are indeed included as one category of SRD. However, transmission power below 10 mW should not automatically be interpreted as “not requiring Postel Certification”. The use of spectrum based on class license and certification obligations are aspects that need to be considered separately.

Toys with Transmission Power Below 10 mW

Certain toys may use transmitters with very low transmission power. Examples include remote-control toys, interactive toys, wireless controllers, toy sensors, and children’s devices using short-range communication.

Minister of Communication and Informatics Regulation Number 2 of 2023 explicitly includes devices with transmission power below 10 mW as one part of the SRD group.

However, to determine whether such products require Postel/DJID Certification, an assessment still needs to be conducted on the overall technical characteristics of the device.

Several parameters that need to be examined include:

  1. Operating frequency.
  2. Transmission power.
  3. Bandwidth.
  4. Wireless technology.
  5. Modulation.
  6. Antenna type.
  7. Integrated or external antenna.
  8. Transmitter and receiver functions.
  9. Number of channels or frequency channels.
  10. Country of origin and product type.

Therefore, the <10 mW figure is an important technical parameter, but it is not the only parameter for determining certification requirements.

Bluetooth in Toys and Low-Power Devices

Bluetooth is one of the wireless technologies widely used in toys and low-power devices. Toys may use Bluetooth to connect with smartphones, tablets, controllers, speakers, applications, or other devices.

Under Minister of Communication and Informatics Regulation Number 2 of 2023, Bluetooth IEEE 802.15.1 is included in the SRD group. The same regulation also provides a framework for the use of radio frequency spectrum based on class license for groups such as RLAN, LPWAN, SRD, IMT based on class license, and PMR.

Therefore, products using Bluetooth need to be examined based on the module specifications and Bluetooth implementation in the final product.

For example, the information that needs to be examined may include:

a. Bluetooth Classic or Bluetooth Low Energy.

b. Frequency used.

c. Maximum transmit power.

d. Antenna gain.

e. Antenna type.

f. Bluetooth module or chipset.

g. Module configuration in the final product.

Such information can be used to determine the relevant Technical Standards and certification process.

Low-Power WiFi

In addition to Bluetooth, low-power devices may also use WiFi. Examples include smart toys, sensor devices, IoT devices, toy cameras, controllers, and other electronic products.

WiFi generally uses IEEE 802.11 technology. Under Minister of Communication and Informatics Regulation Number 2 of 2023, RLAN includes IEEE 802.11 or WLAN standards. RLAN can also be used to provide connectivity for Internet of Things or IoT services.

Although a device uses relatively low power, WiFi still needs to be assessed based on frequency, power, bandwidth, channel, antenna, and device configuration.

Therefore, the term “low-power WiFi” cannot be used as the sole basis for concluding that a product is exempt from Postel Certification.

Remote-Control Toys

Remote-control toys are one example of products that require special attention. Products such as RC cars, RC boats, toy aircraft, robots, and other toy vehicles may use radio frequency to communicate between the remote controller and the toy unit.

During the assessment, it is not sufficient to examine only the toy specifications. The remote controller also needs to be examined because it may contain a radio transmitter.

The information that needs to be examined includes:

  1. Transmitter frequency.
  2. Transmission power.
  3. Bandwidth.
  4. Modulation.
  5. Number of channels.
  6. Antenna type.
  7. Communication range.
  8. Chipset or RF module.
  9. Receiver specifications on the toy unit.
  10. Whether the transmitter and receiver use the same or different modules.

The assessment results are then used to determine the applicable technical and certification requirements.

Examples of Low-Power Products That Need Assessment

In addition to toys, various other products use wireless technology with low transmission power. Examples include:

  1. Bluetooth toys.
  2. WiFi toys.
  3. Remote-control cars.
  4. Remote-control robots.
  5. Wireless controllers.
  6. Bluetooth speakers integrated into toys.
  7. Wireless sensors.
  8. Smart toys.
  9. Low-power IoT devices.
  10. Wireless buttons.
  11. Wireless remotes.
  12. RFID devices.
  13. NFC devices.
  14. BLE sensors.
  15. Devices with transmitters below 10 mW.

These are examples of categories that may require assessment. Certification requirements are still determined based on the technical characteristics and provisions applicable to each device.

Documents Required for Low-Power Postel Assessment

Before determining the need for Postel/DJID Certification, the product owner should prepare sufficient technical information. This is important because products with the same name and function may have different requirements when they use different modules, frequencies, or transmission power.

The documents generally required include:

  1. Product photos.
  2. Packaging and label photos.
  3. Product brand.
  4. Type/model.
  5. Country of manufacture.
  6. Product datasheet.
  7. User manual.
  8. Wireless module datasheet.
  9. RF specification.
  10. Operating frequency.
  11. Transmit power.
  12. Bandwidth.
  13. Antenna specification.
  14. Test report, if available.
  15. Block diagram, if available.
  16. Chipset or RF module information.
  17. Information regarding the transmitter and receiver.

For remote-control toys, information regarding the remote controller should also be included because it may function as a radio transmitter that needs to be assessed.

Does a Certified Module Mean That the Product Does Not Need Certification?

Not necessarily.

One aspect that needs to be considered when using a Bluetooth module, WiFi module, or RF module that already has a certificate is how the module is integrated into the final product.

Certification under Minister of Communication and Informatics Regulation Number 3 of 2024 concerns the conformity of the type of telecommunications equipment and/or telecommunications device with Technical Standards. Compliance with Technical Standards takes into account, among other things, the brand, type, and country of manufacture of the device.

Therefore, a certificate held by a module does not automatically mean that the entire product using that module is exempt from assessment.

Changes to the antenna, power, RF configuration, enclosure, firmware, or module implementation may be aspects that need to be examined.

One Certificate for Multiple Low-Power Variants

Minister of Communication and Informatics Regulation Number 3 of 2024 contains specific provisions for certain telecommunications equipment and/or devices having a telecommunications feature with transmission power below 10 mW and only one identical telecommunications feature.

Under certain conditions, one Certificate may apply to more than one variant if the prescribed requirements are fulfilled, including the same brand and device type as well as the same brand and type of the device with the telecommunications feature.

This provision is important for product owners with multiple toy or low-power device variants. However, it does not mean that all products with transmission power below 10 mW can automatically be combined under one Certificate.

Each variant needs to be examined to ensure that it meets the criteria for combining variants as stipulated in the regulation.

Postel Certification Process for Toys and Low-Power Devices

The process can begin with a technical assessment to determine the wireless characteristics of the product. This stage is important so that the product owner does not immediately apply for certification without knowing the applicable standards and required documents.

In general, the process includes:

  1. Identify the brand, type, and country of manufacture.
  2. Examine wireless functions.
  3. Examine frequency.
  4. Examine transmit power.
  5. Examine bandwidth and modulation.
  6. Examine antenna.
  7. Identify the applicable Technical Standards.
  8. Prepare technical documents.
  9. Conduct testing when required.
  10. Submit the DJID/SDPPI Certification application.
  11. Certificate issuance.
  12. Fulfill labeling requirements.

Minister of Communication and Informatics Regulation Number 3 of 2024 stipulates that compliance with Technical Standards is carried out through testing, and devices that comply with the Technical Standards are evidenced by a Certificate.

Postel Certificate Validity Period

Under Minister of Communication and Informatics Regulation Number 3 of 2024, the Certificate does not have a time limit. However, the Certificate holder may manufacture, assemble, or import the device for trade and/or use in Indonesia for a maximum of three years from the date the Certificate is issued.

This provision needs to be considered by importers and brand owners that continuously bring products into Indonesia.

Postel Label on Toys and Low-Power Devices

After obtaining a Certificate, the Certificate holder is required to affix a label to the telecommunications equipment and/or telecommunications device that has received the Certificate.

The label format under Minister of Communication and Informatics Regulation Number 3 of 2024 includes the Certificate number and PLG ID, QR Code, and warning sign according to the applicable provisions.

For small-sized toys, label placement needs to be considered so that it remains clearly readable and complies with the applicable requirements.

Postel Certification Costs for Low-Power Devices

Postel/DJID Certification costs need to be distinguished between the Certificate issuance fee and other costs that may arise during the process of fulfilling technical requirements.

Minister of Communication and Informatics Regulation Number 3 of 2024 states that Certificate issuance is subject to PNBP.

Meanwhile, if the product requires testing, testing costs may depend on the type of device, Technical Standards, laboratory, testing parameters, and product characteristics.

Therefore, cost estimation should preferably be conducted after the product specifications and wireless module are known.

Importance of Assessment Before Import

Assessment before importation is very important for toys and low-power devices because the term “low power” does not automatically mean that a product is exempt from Postel Certification.

By conducting an assessment beforehand, the product owner can determine:

  1. Whether the product is a telecommunications device.
  2. Whether the product uses an authorized frequency.
  3. Whether the transmission power is compliant.
  4. Which Technical Standards must be applied.
  5. Whether testing is required.
  6. Whether the module used can be considered in the certification process for the final product.
  7. Whether several variants can use one Certificate.
  8. Which documents need to be prepared.

An assessment can also help reduce the risk of the product already being in the import process while the required Postel Certification documents are not yet available.

Conclusion

Toys and low-power devices using wireless technology need to be assessed based on their technical characteristics. Low transmission power, including devices with transmission power below 10 mW, is one of the categories mentioned under the SRD group in Minister of Communication and Informatics Regulation Number 2 of 2023.

However, low power does not automatically mean that Postel/DJID Certification is not required. Certification requirements need to be determined based on telecommunications functions, frequency, transmission power, wireless technology, bandwidth, antenna, type, brand, country of manufacture, and the applicable Technical Standards.

For Bluetooth toys, WiFi toys, remote-control toys, wireless sensors, smart toys, and other low-power devices, a technical assessment before importation is an important step to determine certification requirements from the beginning.

Contact Us

Biruni Consulting assists with DJID/SDPPI assessment and certification for toys, low-power devices, and various wireless products that will be imported or marketed in Indonesia.

Our services include:

  • DJID/SDPPI certification requirement assessment.
  • Bluetooth module assessment.
  • RF specification review.
  • Frequency and transmission power analysis.
  • Technical document review.
  • Certification document preparation.
  • Testing coordination where required.
  • DJID/SDPPI Certification assistance.

If you have a toy or low-power device, you can prepare the product photographs, brand, model, datasheet, RF specifications, and wireless module datasheet for an initial assessment of the Postel Certification requirements.

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