Why NBTC Certification Works Differently for Foreign Manufacturers
NBTC — the National Broadcasting and Telecommunications Commission — requires that all telecommunications and RF equipment sold or distributed in Thailand holds valid NBTC approval before it enters the market. This applies regardless of whether the device already holds CE, FCC, or any other national certification.
For foreign manufacturers, two structural requirements shape the entire process:
A local representative is required
For Class A (Registration) and Class B (Certification), the applicant must be a Thai juristic person holding both an NBTC trade licence and an NBTC Supplier Code. Foreign manufacturers cannot apply directly — the application must be filed through a qualifying Thai entity. SDoC (Supplier's Declaration of Conformity) follows a different path, but the declaration itself must still reference the applicable NBTC technical standard.
Test reports must meet NBTC standards
NBTC accepts test reports from ISO/IEC 17025-accredited laboratories. Reports issued by accredited labs under MRA agreements (including ILAC and APLAC members) are generally accepted, but the applicable NBTC technical standard must be referenced in the test report. Reports that cite only CE or FCC standards without covering the corresponding NBTC standard are insufficient.
Which Certification Path Applies to Your Device
NBTC uses three certification pathways. The applicable path depends on the device's frequency, transmit power, and the application it falls under — not on the device category alone.
Supplier's Declaration of Conformity
Self-declared by the manufacturer against the applicable NBTC technical standard. No NBTC review is required before the device enters the market. The declaration must be retained and the product must carry a conformity statement referencing the relevant standard.
Registration
NBTC reviews the application and issues a Certificate of Registration with a Registration Number. The local representative files the application; NBTC conducts a document review before issuing approval. Products must display the NBTC label (purchased from NBTC after approval).
Certification
The most rigorous path, applied to cellular devices and equipment. NBTC reviews the application in full before issuing an Approval Certificate with an Approval Number. Products must display the NBTC label. Test reports from ISO 17025-accredited labs are mandatory.
The Local Representative Requirement
For Class A and Class B certification, NBTC requires that the applicant be a Thai juristic person holding an NBTC trade licence and an NBTC Supplier Code. This is a legal filing requirement — the local representative's name and credentials appear on the application, and they are the registered holder of record with NBTC.
Foreign manufacturers have two options for meeting this requirement:
| Option | Who acts as local rep | When it applies |
|---|---|---|
| Zergo as local representative | Zergo files the application using its own NBTC trade licence and Supplier Code | Most overseas manufacturers without an existing Thai partner or importer |
| Client's appointed representative | The manufacturer's Thai importer or distributor, if they hold the required NBTC credentials | Manufacturers who already have a qualifying Thai entity and prefer to keep that entity as the holder of record |
Test Reports and Documentation Requirements
Documentation requirements differ by certification path. The table below summarises what is required for each path.
| Document | SDoC | Class A | Class B |
|---|---|---|---|
| Technical specification / datasheet | ✓ | ✓ | ✓ |
| Product photographs | ✓ | ✓ | ✓ |
| Test report from ISO/IEC 17025-accredited laboratory | — | ✓ | ✓ |
| ISO/IEC 17025 accreditation certificate of testing laboratory | — | ✓ | ✓ |
| Authorised declaration / letter of authorisation | ✓ | ✓ | ✓ |
Test report requirements in practice
Test reports must reference the applicable NBTC technical standard — citing only CE (EN) or FCC standards without covering the corresponding NBTC TS is not sufficient. In many cases, existing test reports from accredited labs can be supplemented or extended to add NBTC standard references, without requiring a full retest. Zergo's Pre-Submission Review (available as an add-on service) identifies gaps in existing documentation before the application is filed.
NBTC accepts test reports from laboratories accredited under ILAC and APLAC MRA agreements, provided the report covers the applicable NBTC technical standard. In-country testing is not required — reports from accredited labs in the manufacturer's home country are accepted.
The Certification Process: What to Expect
The process follows the same steps for all three certification paths, with timelines varying by path. Foreign manufacturers typically engage Zergo before documentation is finalised — this allows gaps in test reports or missing documents to be identified early.
- 1
Documentation Verification
Zergo reviews the manufacturer's existing technical documentation — test reports, datasheets, product photos — against NBTC requirements for the applicable certification path. Missing or non-compliant documents are identified before any submission is made.
- 2
Application Preparation
Zergo prepares all application documents in the required format. This includes compiling technical specifications, formatting test reports, preparing the authorised declaration, and confirming the local representative documentation is in order.
- 3
Submission
Zergo submits the application on behalf of the manufacturer, using either Zergo's own local representative documentation or the client's appointed representative documentation. All NBTC communication from this point is handled by Zergo.
- 4
Authority Review
NBTC reviews the application. For Class A and Class B, NBTC may issue queries or request additional documentation — Zergo manages all responses. SDoC does not require NBTC review before approval.
- 5
Preliminary Approval
Before the final certificate is issued, NBTC issues a preliminary approval notice. Zergo confirms the details are correct before proceeding to certificate issuance.
- 6
Certificate Issuance
The approval document is issued: an SDoC reference number and SDoC document for SDoC path; a Certificate of Registration and Registration Number for Class A; or an Approval Certificate and Approval Number for Class B. Zergo delivers the complete documentation set to the manufacturer.
For full process documentation, see the NBTC Certification Process guide.
After Certification: Labelling and Compliance
NBTC label requirement
Devices certified under Class A or Class B must carry the official NBTC label. Labels are purchased from NBTC after the approval document is issued, based on the quantity stated in a purchase order or invoice. The label must be affixed to the physical device — it cannot be printed independently.
SDoC conformity statement
Products approved under SDoC must carry a conformity statement on the product or its packaging, referencing the applicable NBTC technical standard. This is distinct from the NBTC label used for Class A and Class B.
Post-certification obligations
The certificate holder is responsible for ensuring the approved product continues to conform to the specifications submitted at the time of application. Material changes to the product's RF characteristics — such as changes to transmit power, frequency bands, or antenna configuration — may require a new or amended application. Zergo's scope covers the certification process and delivery of the approval document; ongoing post-certification compliance responsibility rests with the manufacturer and, where applicable, the local representative.
How Zergo Works with Foreign Manufacturers
Zergo is a regulatory specialist firm, not a documentation service. The distinction matters: Zergo does not simply gather documents and forward them — Zergo manages the entire certification process, including NBTC communication, document preparation, and coordination of the local representative filing.
Core Certification Service
End-to-end management: documentation review, application preparation, submission (using Zergo's or your appointed local rep), all NBTC communication, and delivery of the approval certificate and registration number.
Service details →Pre-Submission Review USD 150
A review of your existing documentation — test reports, datasheets, product information — against NBTC requirements before any application is filed. Identifies gaps and misaligned test standards early. Fee is deductible from the core service fee if you proceed with certification.
Regulatory Consultation USD 200
A structured session for manufacturers who need to understand certification requirements before committing to a specific path — particularly useful for multi-band devices or products at the design stage. Submit your device specifications in advance. Fee is deductible from the core service fee if you proceed with certification.
Ready to certify your device for Thailand?
Zergo manages the complete NBTC certification process for foreign manufacturers — from documentation review through certificate delivery.