Confidential Test Reports: How to Protect Your OEM Manufacturer and Design Secrets (Resolution 737)

Short answer: yes — you can comply with Resolution 737 without publicly revealing sensitive information about your product. The regulation itself (closing paragraph, as amended by Resolution 2.219) allows the freely downloadable version of the test report to omit or redact confidential information —your OEM manufacturer's identity, hardware design secrets or other commercial details— while the full version is protected by a password, reported to SUBTEL in advance at certificaciones@subtel.gob.cl.

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What an OEM manufacturer is (and why its identity is sensitive information)

OEM stands for Original Equipment Manufacturer. It is the company that makes a product which another company sells under its own brand. This is the model behind most private-label electronics sold in Chile: an importer or an established brand commissions the product from a factory (usually in Asia), adapts it, and sells it as its own.

Related concepts that are often confused:

Term	What it means
OEM	Manufactures the product that someone else sells under their brand
ODM (Original Design Manufacturer)	Designs and manufactures; the client only adds the brand
White label / private label	The commercial model: selling under your brand a product made by a third party

For anyone selling under their own brand, the OEM's identity is a commercial asset. Revealing it has real costs:

• Competitors can go straight to the same factory and replicate your catalog.
• Wholesale customers may try to buy direct, bypassing your margin.
• The commercial relationship itself may be protected by confidentiality agreements with the manufacturer.

The problem: Resolution 737 requires you to publish your test report

Since February 22, 2026, every short-range device sold in Chile must carry a QR code linking to a compliance page with the device's commercial and technical information. Among those requirements, literal p demands:

A hyperlink allowing the device's Test Report to be downloaded.

And here lies the conflict for private labels: the test report is the laboratory's document, and it usually identifies the real manufacturer in multiple places:

• The applicant and manufacturer on the cover page and identification tables
• The factory address
• The module's FCC ID or IC ID — identifiers whose filings are public: one search leads to the manufacturer

In other words: complying by publishing the test report as-is means, for a private label, publishing who your supplier is.

Not just the manufacturer: what else can be confidential

The OEM's identity is the most frequent case, but the regulation's confidentiality clause is generic: it protects any confidential information, not one specific category. And a test report can expose far more than a name:

• Internal photographs of the device (boards, chips, component layout)
• Block diagrams and schematics, when the report includes them
• Operational description of the product (how it works internally)
• Antenna design and RF implementation details
• Component lists or references to specific modules and suppliers

For a product with real engineering investment, that material is a trade secret: it describes how the device is built at a level of detail no manufacturer would publish voluntarily. Other regulators recognize the same — the FCC in the United States allows requesting permanent confidentiality precisely over schematics, block diagrams and operational descriptions in its filings.

Resolution 737 covers both fronts: confidential information in the test report (this mechanism) and confidential technical characteristics on the compliance page itself, which may be placed behind a password (the other mechanism in the same clause, covered below).

The solution is written into the regulation itself

Resolution 737 anticipated this scenario. Its closing paragraph (after literal p), in the text in force as amended by Resolution 2.219, states that if the Test Report contains confidential information, the freely downloadable version may omit or redact it, with a password required to access the confidential version — and the password must be reported in advance to SUBTEL by email to certificaciones@subtel.gob.cl.

The clause contains two independent mechanisms:

1. Confidential technical characteristics: technical fields on the compliance page may be placed behind a password.
2. Confidential test report: the report is published in two versions — a freely downloadable one with confidential information omitted or redacted, and a complete version protected by a password.

Resolution 2.219 (Article One, numeral 11) made this mechanism more flexible: where the original text only allowed "censored parts", the current text allows omitting or redacting — confidential information can be cleanly removed from the public document, not just covered with black boxes.

How it works in practice

Properly implemented, the mechanism has four steps:

1. Identify what is confidential (and what is not)

Redaction must be surgical. General criteria:

Typically redactable	Must stay visible
OEM identity: name (applicant / manufacturer), address, module FCC ID / IC ID (their public filings reveal the OEM)	Measurements and results: frequency bands, output power, uncertainties, emission plots
Internal design: internal photos, block diagrams, schematics, operational description	Identification of the tested device (models)
Implementation details: antenna design, component lists, supplier references	Laboratory, signatures, stamps and dates

The underlying rule: what gets protected is what identifies how the product is built and who builds it; what stays visible is what proves it complies — the measurements, whose key values are public anyway in the technical section of the compliance page.

2. Generate the redacted public version

The freely downloadable version must remain available and readable: a reader must be able to verify what was tested, in which bands, with what results and at which laboratory. Only the manufacturer's corporate identifiers disappear.

3. Protect the confidential version with a password

The complete report remains available on the same compliance page, protected by a password.

4. Report the password to SUBTEL — before publishing

This step is mandatory and prior: the password is reported to SUBTEL by email to certificaciones@subtel.gob.cl before activating the protection. Publishing the lock without having sent the notice puts the mechanism outside the regulation.

The limits: what you cannot do

Knowing the mechanism's boundaries matters as much as knowing the mechanism:

• You cannot encrypt the entire test report or place the only download link behind a password: literal p requires a freely downloadable report, and the confidentiality clause presupposes that version remains readable.
• You cannot redact 100% of the document: stripping everything recreates the non-compliance de facto. Technical measurements always stay visible.
• The confidentiality is commercial, not absolute. Redaction removes the direct path from the QR code — the one a consumer or casual competitor follows. But if the report comes from a public filing (for example an FCC filing), a motivated party could reach the original document through other means. It is real, sufficient friction to protect the commercial relationship in the sales channel; it is not a state secret.

How does Certificación Telecom help?

Our platform implements this mechanism end to end. We handle the analysis of what qualifies as confidential, professional redaction of the document (including the PDF metadata, where the manufacturer's name often hides in plain sight), the password-protected confidential version, the formal prior notice to SUBTEL, and publication on the device's compliance page with its QR code.

If you sell under your own brand and worry about what your test report reveals, contact us: we will review your case and tell you exactly what can be protected.

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Frequently asked questions

Can I hide who manufactures my product and still comply with Resolution 737?

Yes. The current text of the regulation allows the freely downloadable version of the test report to omit or redact confidential information, with the complete version behind a password reported to SUBTEL in advance.

What is an OEM manufacturer?

OEM (Original Equipment Manufacturer) is the company that makes a product which another company sells under its own brand — the typical white-label or private-label model.

What counts as confidential information in a test report?

Any commercially sensitive information: the manufacturer's corporate identifiers (name, address, module FCC ID / IC ID) and also design secrets such as internal photos, block diagrams, schematics or operational descriptions. Technical measurements are not confidential.

Can I protect hardware design secrets (schematics, internal photos)?

Yes. The clause is generic — it protects any confidential information, not just the manufacturer's identity. Internal photos, diagrams, schematics and operational descriptions may be omitted or redacted in the public version of the report.

Can I password-protect the entire test report?

No. The freely downloadable version must remain available and readable; only the specific confidential information may be omitted or redacted.

Who must be informed of the password?

SUBTEL, by email to certificaciones@subtel.gob.cl, before the protection is published.

Does redaction guarantee absolute confidentiality?

No: it removes the direct path from the QR code, which is the one that matters commercially. If the report comes from a public filing, the original document still exists outside your site.

Can I also hide technical characteristics on the compliance page?

Yes, that is the other mechanism in the same clause: confidential technical characteristics may be placed behind a password, also reported to SUBTEL in advance.

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Official sources

• SUBTEL Exempt Resolution 737 (BCN) — legal text, closing paragraph after literal p
• SUBTEL Resolution 2.219 (BCN) — Article One, numeral 11: current text of the confidentiality clause
• SUBTEL — Short-range device certification — official regulator site

Related resources

• SUBTEL Resolution 737: complete guide 2026
• Complete guide to Resolution 737 QR codes
• Resolution 2.219: the changes that eased Resolution 737
• Legal representative in Chile: mandatory SUBTEL requirement
• View certified products — short-range devices already published