Can I sell short-range equipment in Chile without having a local presence? This is one of the most frequent questions we receive. The answer, officially confirmed by SUBTEL through their OIRS (Office of Information, Complaints, and Suggestions), is clear: No. Having a representative with legal domicile in Chile is mandatory. There are no exceptions.
Official OIRS-SUBTEL confirmation
In response to formal inquiries made in December 2025, SUBTEL confirmed through their OIRS:
"For all purposes, the manufacturer, importer, or representative must have legal domicile in Chile in order to commercialize equipment or devices regulated by the Resolution. There are no exceptions."
This confirmation is categorical and applies to all scenarios that frequently raise questions.
What does this mean in practice?
Scenarios where there are NO exceptions
| Scenario | Requires Chilean representative? |
|---|---|
| OEM modules integrated into final products | Yes, mandatory |
| Industrial equipment not accessible to end users | Yes, mandatory |
| B2B sales (only to businesses) | Yes, mandatory |
| Components sold in bulk | Yes, mandatory |
| One-time imported equipment | Yes, mandatory |
| Devices embedded in vehicles | Yes, mandatory |
The three valid roles
According to the regulation, any of these three roles can fulfill the requirement:
| Role | Description | Example |
|---|---|---|
| Manufacturer | Manufacturing company with legal presence in Chile | Samsung Chile, Apple Chile |
| Importer | Chilean company that imports directly | Local distributor |
| Representative | Authorized agent acting on behalf of foreign manufacturer | Certificación Telecom as representative |
Responsibilities of the representative
The representative with domicile in Chile assumes important responsibilities:
To SUBTEL
- Regulatory responsibility: Is accountable to SUBTEL for equipment compliance
- Inspection response: Must respond to inspections and information requests
- Documentation: Must keep technical documentation available (test reports, declarations of conformity)
- Updates: Must keep the compliance webpage updated
To consumers
- Point of contact: Is the contact in Chile for product inquiries
- Technical information: Must provide access to technical specifications
- Traceability: Enables product traceability in the Chilean market
Required representative information
The compliance page (linked by the QR code) must mandatorily include:
| Field | Description |
|---|---|
| Importer or representative in Chile | Complete legal name |
| Address | Physical address in Chile (street, number, comuna, city) |
| Contact email | Email for inquiries |
| Website | Website URL |
This information must be in Spanish and publicly accessible.
Special cases clarified by OIRS
OEM modules embedded in final products
Question: If a WiFi/Bluetooth module is integrated inside a final product (like an appliance), does the module need an individual QR?
OIRS Response: The requirement applies to "every final equipment or device." This suggests:
- The final product needs to comply with the regulation (including Chilean representative)
- The embedded module can be covered by the final product's certification
Equipment in imported vehicles
Question: Do SRD modules inside vehicles (keys, BCM, radios, TPMS) require individual QR?
OIRS Response: The same flexibility options apply. The QR can be placed in:
- Vehicle documentation (manual, warranty)
- Accessible equipment (radio, infotainment system)
Bulk sales without individual packaging
Question: How to comply when selling products without individual packaging?
OIRS Response: Resolution 2219 added flexibility:
- Exterior packaging (if it exists)
- Directly on the device
- In accompanying documentation (manual, warranty, packing list)
What happens if I don't have a representative in Chile?
Legal consequences
- Commercialization prohibition: Cannot sell or display the equipment
- Fines: Sanctions under Title VII of Law 18.168 (General Telecommunications Law)
- Market withdrawal: SUBTEL can order product withdrawal
Practical consequences
- Products stuck at customs
- Inability to sell in retail or e-commerce
- Loss of commercial opportunities in the Chilean market
How Certificación Telecom can help
If you're a foreign manufacturer without presence in Chile, we can act as your legal representative:
Our representation service includes
- Legal domicile in Chile: We provide the address required by SUBTEL
- Regulatory responsibility: We assume responsibility to SUBTEL
- Compliance page: We create and host the page with your information
- QR code: We generate QR codes compliant with the regulation
- Ongoing support: We keep documentation updated
Advantages
- No need to establish a company in Chile
- No need to hire local staff
- Fast process (1-2 weeks)
- 21 years of experience in SUBTEL certifications
Frequently asked questions
Can I use a virtual address or PO box?
The regulation requires "legal domicile in Chile." This generally implies a real physical address where official correspondence can be received and legal notifications can be made.
Must the representative be a company or can it be an individual?
The regulation speaks of "manufacturer, importer, or representative" without specifying. In practice, it's more common and advisable to be a legal entity (company) for legal liability purposes.
Does the representative assume responsibility for product defects?
Responsibility to SUBTEL is specifically about compliance with telecommunications regulations (RF emissions, documentation, etc.). Responsibility for product defects is governed by other regulations (consumer protection, warranties, etc.).
What happens if I change representatives?
You must update the information on the compliance page. The new representative must assume obligations to SUBTEL. Maintaining continuity is recommended to avoid periods without valid representation.
Does the requirement apply to equipment that already has FCC or CE certification?
Yes. Having international certifications (FCC, CE, IC, etc.) does not exempt from the requirement of having a representative in Chile. They are complementary requirements, not substitutes.
Summary
| Aspect | Detail |
|---|---|
| Requirement | Legal domicile in Chile mandatory |
| Exceptions | None (confirmed by OIRS-SUBTEL) |
| Valid roles | Manufacturer, importer, or representative |
| Required information | Legal name, address, email, website |
| Consequences of non-compliance | Commercialization prohibition, fines |
| Solution for foreign manufacturers | Contract local representative (like Certificación Telecom) |
Related resources
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