Understanding Compliance Responsibilities for Manufacturers, Importers, and Representatives
Chile’s Subsecretaría de Telecomunicaciones (SUBTEL) introduced Resolution 737/2025 to modernize the country’s telecommunications compliance system. This regulation establishes a new QR Code and Spanish-language webpage model for most short-range wireless devices (SRDs), replacing traditional type approvals. A key requirement under this framework is the designation of a Local Representative in Chile, responsible for maintaining compliance and communication with SUBTEL.
Why a Local Representative Is Required
Under SUBTEL Resolution 737/2025, every SRD marketed or imported into Chile must be linked to a local entity that can ensure regulatory accountability. The Local Representative serves as SUBTEL’s primary contact within Chile for all matters related to documentation, device identification, and product traceability. This requirement strengthens oversight by ensuring that technical and compliance data remain accessible to authorities at all times.
Core Responsibilities of the Local Representative
• Maintain the Spanish-language compliance webpage linked through the device’s QR code.
• Ensure that manufacturer, importer, and technical details are accurate and up to date.
• Host or manage access to the Declaration of Conformity (DoC) and downloadable Test Report (Informe de Ensayo).
• Serve as the official contact point for SUBTEL in case of audits, document requests, or consumer inquiries.
• Monitor changes to product specifications and coordinate webpage or document updates accordingly.
• Keep historical compliance records for products sold or distributed in Chile.
Information Required on the Compliance Webpage
• Full legal name, address, and contact details (email and phone) of the representative in Chile.
• Manufacturer name, model number, and device identifiers.
• Technical specifications including operating frequencies, antenna gain, and maximum EIRP.
• Declaration of Conformity (DoC) referencing SUBTEL Resolution 737/2025.
• Downloadable Test Report (Informe de Ensayo) in PDF format.
• Confidentiality management details—if a redacted version is public, the complete report and password must be submitted to SUBTEL at [email protected].
SUBTEL Oversight and Penalties for Non-Compliance
SUBTEL retains full authority to inspect or audit compliance webpages and documentation. If the Local Representative fails to maintain accurate or accessible information, the agency may suspend the sale or import of affected devices. Non-compliance can result in rejection of new applications, fines, or product withdrawal from retail channels. Therefore, ongoing coordination between the manufacturer and the Local Representative is essential for uninterrupted market access.
Best Practices for Manufacturers
• Select a representative in Chile with proven regulatory and technical experience.
• Establish internal review schedules to verify webpage content and documentation accuracy.
• Ensure all QR code links remain functional and direct users to the correct compliance webpage.
• Provide the representative with updated test reports, labeling, and Declaration of Conformity whenever device changes occur.
• Maintain duplicate digital records of all documents shared with SUBTEL.
While SUBTEL Resolution 737/2025 allows a manufacturer to appoint any Chilean legal entity as its local representative — including an importer or distributor — many manufacturers choose to designate an independent third-party representative instead. This approach provides several key advantages:
• Neutrality and confidentiality — Third-party representatives act solely on behalf of the manufacturer for regulatory purposes, avoiding commercial conflicts of interest that can arise when importers or distributors represent competing products.
• Continuity and stability — Business relationships with importers may change over time. Using an independent representative ensures that compliance records, webpages, and QR-linked documentation remain under consistent control even if sales channels shift.
• Centralized document management — Dedicated representatives specialize in maintaining compliance webpages, hosting the Declaration of Conformity (DoC) and Test Report (Informe de Ensayo), and keeping all QR code links active and accurate.
• Faster updates and regulatory alignment — Independent representatives monitor SUBTEL resolutions and compliance developments as part of their core services, enabling manufacturers to respond quickly to regulatory changes.
• Reduced administrative risk — If an importer ceases operations or changes distributors, a third-party representative prevents compliance interruptions and eliminates the need to reassign webpage ownership or QR links.
By appointing an independent, compliance-focused representative, manufacturers retain control of their technical identity and ensure long-term regulatory stability within the Chilean market.
Why Choosing an Independent Third-Party Representative Is Often Preferable
Summary and Key Takeaways
• SUBTEL Resolution 737/2025 introduces a QR and webpage-based compliance model effective February 22, 2026.
• Every manufacturer marketing SRDs in Chile must appoint a Local Representative with a valid Chilean address.
• The representative is responsible for maintaining the compliance webpage, hosting documents, and liaising with SUBTEL.
• Mandatory webpage content includes the Declaration of Conformity and a downloadable Test Report (Informe de Ensayo).
• Continuous coordination between manufacturers and representatives is necessary to prevent compliance interruptions.
