Executive Summary
Exempt Resolution No. 2.219 from SUBTEL, published in the Official Gazette on November 24, 2025, introduces significant modifications to Resolution 737, which will regulate short-range equipment starting February 22, 2026.
The changes directly respond to difficulties expressed by the industry through multiple formal submissions (No. 78,419, 83,328, 86,493, 86,513, 88,469, 88,509, and 89,914 of 2025).
This guide analyzes the 4 fundamental changes and their practical impact.
Change 1: QR Code Placement Flexibility
The Original Problem
The original Resolution 737 required QR codes to be printed or adhered exclusively on the exterior packaging of the equipment. This created serious difficulties for:
- Automotive components (Bluetooth/WiFi modules integrated into vehicles)
- Industrial devices without commercial packaging
- Bulk-sold equipment without individual boxes
- OEM products integrated into larger systems
The New Flexibility
Article 2, paragraph 2 now establishes three equivalent options:
- Exterior packaging - In a visible location on the package (original option)
- Directly on the device - Printed or adhered on the device itself
- Accompanying documentation - In the manual, warranty, or other paper documents
"A QR code must be printed or adhered in a visible location on the exterior packaging of the equipment. If not feasible, it may be incorporated directly on the device, or included in the paper documentation delivered with it, such as the manual, warranty, or others."
Practical Implications
| Product Type | Before | Now |
|---|---|---|
| Automotive module | Problem: No individual packaging | Solution: QR in technical documentation |
| Industrial sensor | Problem: Minimal packaging | Solution: QR on the device |
| WiFi router | No change | Package or manual |
| Bluetooth speaker | No change | Package or box |
Important: The QR code must contain a hyperlink to a Spanish-language website with the required technical documentation.
Change 2: Transitional Provision for Already Certified Equipment
The New Literal D of Article 2
A crucial transitional provision is added to facilitate the transition for equipment with certifications in process:
"D. For equipment that has been authorized by the Telecommunications Undersecretariat through a Certification Official Letter in response to requests submitted by February 21, 2026, it will be sufficient to publish said certification in replacement of the information indicated in the preceding literals A, B, and C."
What This Means
If you submit your certification request before February 22, 2026:
- You DO NOT need to publish all the detailed technical documentation (literals A, B, C)
- You ONLY need to publish the Certification Official Letter issued by SUBTEL
- The QR code website can display only this official document
Who Benefits
- Importers with existing stock - Products already certified under previous regulations
- Manufacturers in process - Certification requests in progress
- Distributors - Products arriving before the deadline
Key Date
February 21, 2026 - Last date to submit requests that qualify for this transitional provision.
Change 3: New MEDL 430-440 MHz Band
New Literal g.3)
A new category of short-range equipment is incorporated:
"g.3) Medical data acquisition devices operating in the 430 - 440 MHz frequency band, with an e.i.r.p. of 0.1 µW and employing frequency hopping technology."
Technical Specifications
| Parameter | Value |
|---|---|
| Frequency band | 430 - 440 MHz |
| Maximum power (e.i.r.p.) | 0.1 µW (microwatt) |
| Required technology | Frequency Hopping |
| Application | Medical data acquisition |
Immediate Effect
This change takes effect upon publication of Resolution 2.219, not waiting until February 2026. Certification requests for these devices can be submitted now.
Typical Applications
- Patient monitoring sensors
- Medical telemetry devices
- Portable diagnostic equipment
- Medication tracking systems
Change 4: Technical Requirements Simplification
Elimination of Spectral Density References
Resolution 2.219 eliminates multiple references to spectral power density, leaving only e.i.r.p. (equivalent isotropically radiated power) limits.
Specific changes in literal j.1):
| Paragraph | Before | After |
|---|---|---|
| Second | e.i.r.p. + density of 17 dBm/MHz | e.i.r.p. only |
| Third | e.i.r.p. of 30 dBm + density of 5 dBm/MHz | e.i.r.p. of 30 dBm only |
| Fifth | e.i.r.p. of 24 dBm + density of -1 dBm/MHz | e.i.r.p. of 24 dBm only |
| Literal j.5) | e.i.r.p. + density of 13 dBm/MHz | e.i.r.p. only |
Benefits
- Simplifies laboratory testing - Fewer parameters to measure
- Reduces certification costs - Simpler tests
- Clarifies requirements - Single power parameter to comply with
- International alignment - Many jurisdictions use only e.i.r.p.
Implementation Timeline
Key Dates
| Date | Event |
|---|---|
| Nov 17, 2025 | Publication of Resolution 2.219 |
| Nov 17, 2025 | Effective: MEDL 430-440 MHz band |
| Feb 21, 2026 | Last date for requests under transitional provision |
| Feb 22, 2026 | Effective: remaining modifications + complete Res. 737 |
Recommendations by Company Type
Importers with stock:
- Review current products with SUBTEL certification
- Prepare website with Certification Official Letters
- Evaluate if they benefit from transitional provision
Manufacturers/OEM:
- Decide QR code location (packaging, device, or manual)
- Update documentation materials
- Consider certifying before February 21, 2026
Medical Sector:
- Evaluate devices that could use 430-440 MHz band
- Start certification process immediately
- Coordinate with testing laboratories
Frequently Asked Questions
Can I use any of the three QR placement options?
Yes, as long as the previous option in the hierarchy is not feasible. The regulation establishes a preference for exterior packaging but recognizes it's not always possible.
What if my product already has previous certification?
If you submitted the request before February 22, 2026, you only need to publish the Certification Official Letter on your website, not all the technical documentation.
Is the 430-440 MHz band already available?
Yes, this provision took effect with the publication of Resolution 2.219 on November 24, 2025.
Do I need to update existing certifications?
No. Existing certifications remain valid. You only need to comply with QR labeling requirements starting February 22, 2026.
Is the Chilean representative requirement still in effect?
Yes. Resolution 2.219 does not modify the requirement to have a manufacturer, importer, or representative with legal domicile in Chile. According to official OIRS-SUBTEL confirmation, this requirement is mandatory with no exceptions, even for OEM modules, industrial equipment, or B2B sales. If you don't have presence in Chile, we can act as your representative.
Conclusion
Resolution 2.219 represents a pragmatic adjustment that responds to the real needs of industry without compromising the transparency and traceability objectives of Resolution 737.
Main beneficiaries are:
- Component and OEM module manufacturers
- Importers with already certified products
- Medical device sector
- Companies requiring labeling flexibility
Recommended next steps:
- Review your product portfolio
- Identify which products benefit from each change
- Prepare documentation and website
- Contact us for certification process assistance
Official References
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