Real-world scenario: A Taiwanese company makes dual-band WiFi routers and plans to sell them domestically in both Vietnam and Malaysia in 2027. They ask: can one certification dossier cover both markets?
The short answer is no. Vietnam and Malaysia run two fully independent certification systems with no mutual recognition. In Vietnam, radio equipment must go through type certification and a declaration of conformity under the Ministry of Information and Communications’ mandatory lists. In Malaysia, communications and multimedia equipment needs Type Approval (Compliance Approval) issued by SIRIM QAS, acting as the certifying agency designated by the Malaysian Communications and Multimedia Commission (MCMC). The decisive difference is not the technical standards — both sides reference comparable international norms — but who may file, where testing happens, and how certification ties into import clearance.
This article reflects the legal position as of 18 October 2026. The Malaysia section is presented at framework level; have Malaysian local counsel verify details before committing.
Vietnam: type certification plus declaration of conformity
Circular 02/2024/TT-BTTTT lists the products with potential safety risks under the Ministry of Information and Communications. The list has two tiers:
- Mandatory type certification AND declaration of conformity: radio transmitters and transceivers operating from 9 kHz to 400 GHz; short-range radio devices (including 2.4 GHz broadband data equipment with EIRP from 60 mW to 200 mW, 5 GHz radio access equipment with EIRP of 60 mW or more, wireless audio devices, RFID, UWB and others). The dual-band WiFi router in our scenario falls squarely in this tier.
- Mandatory declaration of conformity: IT equipment such as desktop PCs, laptops and tablets, plus certain broadcasting equipment.
The procedures sit in Circular 30/2011/TT-BTTTT and Circular 10/2020/TT-BTTTT. Two distinct concepts: type certification is a third-party body confirming the product meets the applicable national technical regulation (QCVN); declaration of conformity is the manufacturer or trader declaring conformity itself after self-assessment or hired assessment. For imports, testing must be done by a laboratory designated or recognised by the Ministry. The Telecommunications Authority is the national focal point, coordinating with provincial Departments of Information and Communications.
One detail importers often miss: type certification is the precondition for the declaration dossier, and both must be completed before the product reaches the market. Goods sitting in a warehouse without complete paperwork still count as a violation when inspectors check.
Malaysia: SIRIM Type Approval linked to customs clearance
In Malaysia, SIRIM QAS International is the MCMC-designated certifying agency for communications, multimedia and hybrid equipment. Under the Communications and Multimedia Act 1998 and the Communications and Multimedia (Technical Standards) Regulations 2000, regulated communications equipment may not be used, sold, offered for sale or kept for sale unless certified — a mandatory pre-market requirement, like Vietnam, but enforced through a different mechanism.
Three differences that decide the project plan:
First, who files. A Malaysian Type Approval application must be filed by a company registered in Malaysia — a foreign manufacturer cannot apply directly and must go through a local representative or importer. In Vietnam, by contrast, the importer or manufacturer follows the certification and declaration procedures directly.
Second, test evidence. The Malaysian dossier requires RF test reports from an ISO/IEC 17025-accredited laboratory, a brand authorisation letter from the trademark owner, and product technical documentation. Test reports should not be stale relative to the filing date.
Third, certification gates the border. SIRIM is also designated by the Royal Malaysian Customs Department (RMCD) to support issuance of the Certificate of Approval (CoA) / import permit for communications equipment. The certificate is therefore not only a sales condition but a customs condition — a consignment of communications equipment without a CoA can be held at the port. Separately, Malaysia runs its own SIRIM ST electrical-safety certification for electrical and electronic products; companies must map which regime each product falls under rather than assuming a telecom approval covers electrical safety.
Quick comparison matrix
| Criterion | Vietnam | Malaysia |
|---|---|---|
| Regulator | Ministry of Information and Communications (Telecommunications Authority) | MCMC; SIRIM QAS as designated certifying agency |
| Legal basis | Circular 02/2024/TT-BTTTT (lists); Circulars 30/2011, 10/2020 (procedures) | Communications and Multimedia Act 1998; Technical Standards Regulations 2000 |
| Form | Third-party type certification + self declaration of conformity | Type Approval / Compliance Approval |
| Eligible applicant | Importer/manufacturer under the regulations | Must be a Malaysia-registered company |
| Testing | Ministry-designated/recognised labs | ISO/IEC 17025-accredited labs |
| Import link | Market-circulation condition | Market-circulation AND customs-clearance condition (CoA) |
| Marking | Conformity mark as regulated | SIRIM/MCMC certification mark (self-labelling programme SLP available) |
A practical dual-market timeline
Rather than going sequentially, run two parallel tracks from the moment the hardware design is frozen:
Vietnam track (months 1–2): identify the applicable QCVN for each model (a dual-band router needs the regulations for 2.4 GHz and 5 GHz radio access equipment); send samples to a designated lab; obtain the type certificate; prepare the declaration dossier. Note: each hardware model or version may need its own file — changing the antenna or RF module is a change that must be re-assessed.
Malaysia track (months 1–3): contract a Malaysian importer or representative to hold the application; prepare RF reports from an ISO/IEC 17025 lab (some test results may be reusable if the lab meets recognition requirements); file through SIRIM’s online platform; after Type Approval, register serial/IMEI numbers and arrange the CoA for each import consignment.
The most common bottleneck on the Malaysia side is not technical but commercial: finding and contracting a qualified local partner to hold the application — start this before the product is even finished. On the Vietnam side, the usual bottleneck is testing slots at designated labs during year-end peak season.
Pre-distribution checklist
- List every model to be sold and flag any with radio functions (including built-in Bluetooth, WiFi, NFC).
- Cross-check each model against Circular 02/2024/TT-BTTTT (Vietnam) and the MCMC mandatory-certification equipment list (Malaysia).
- Identify the applicable QCVN for Vietnam and the applicable technical specifications for Malaysia — never assume one standard set covers both.
- Lock in test labs: a designated lab in Vietnam; an accepted ISO/IEC 17025 lab for Malaysia.
- Sign the Malaysian application holder; clarify who maintains and renews the certificate.
- Plan per-consignment CoA for Malaysia and the declaration dossier for Vietnam.
- Design packaging and labels with space for the conformity mark (Vietnam) and the certification mark (Malaysia) — reprinting packaging after mass production costs far more.
A note on Malaysian law
The Malaysia content here is framework-level only. The current mandatory equipment list, certificate validity and renewal conditions, penalties, and the boundary between telecom certification (MCMC) and electrical-safety certification (SIRIM ST) for each specific product line should be confirmed by Malaysian local counsel before signing commercial commitments.
Electronics companies preparing certification dossiers for Vietnam, or mapping a multi-market Southeast Asia compliance timeline, can speak with our legal team for a review of the applicable QCVN list and the right procedure per product model.
Frequently asked questions
1. We only sell online, not through stores. Is certification still required?
Yes. Both Vietnam and Malaysia regulate “placing on the market” — e-commerce, own websites and physical stores are treated identically. Imports into Malaysia additionally need a CoA for customs clearance regardless of sales channel.
2. We already have CE or FCC certification. Does that exempt us in Vietnam or Malaysia?
No. International test reports may be referenced or partially accepted depending on each side’s rules, but Vietnam’s type certificate and Malaysia’s Type Approval must still be obtained separately. Do not promise delivery schedules based on CE timing and only then start researching local procedures.
3. Does switching the WiFi module supplier trigger re-certification?
Very likely. The RF module determines the radio characteristics — a module change is generally treated as a design change affecting conformity. Re-assess with the certification body before mass-producing with the new module, in both markets.
4. Can our overseas parent company file the Malaysian Type Approval itself?
No. The application must be held by a Malaysia-registered company. The parent needs a local representative, importer or subsidiary as the certificate holder, with a clear agreement on who maintains and renews the certificate.
5. A product has both WiFi and a 220V mains connection — how many Malaysian certifications?
Potentially two: telecom Type Approval (MCMC/SIRIM) for the radio function and SIRIM ST electrical-safety certification for the mains part. Map each regime independently — passing one does not automatically cover the other.
6. How long is a Vietnamese type certificate valid?
It depends on the conformity-assessment method applied to each product group (under Circular 28/2012/TT-BKHCN and its amendments/replacements). Check the validity stated on each certificate and start the re-assessment/renewal process before expiry to avoid disrupting the flow of goods.
This article has been quality-reviewed by the FLAW AI Legal Council