Whether a hardware revision needs a new Technical Conformity Certification (技術基準適合証明), commonly shortened to Giteki (技適), turns on whether the change alters the RF characteristics the original certification covers: frequency, output power, modulation, and spurious emissions. A component substitution or PCB respin that shifts any of those needs re-certification. A firmware-only update that leaves them untouched usually does not.
Does a PCB Respin Always Trigger a New Giteki Application?#
No. A PCB respin triggers re-certification only when the change affects the RF parameters recorded in the device's construction design document (工事設計書), the file that defines what was actually tested and certified. Swapping a passive component, a connector, or an unrelated digital IC that has no bearing on the transmission path generally leaves the certified RF performance untouched. Swapping the RF module itself, the power amplifier, the antenna, or anything in the matching network almost always does, because those are exactly the elements TELEC (Telecom Engineering Center) or another Ministry of Internal Affairs and Communications (MIC, 総務省)-registered certification body measured against the technical standards under the Radio Act (電波法) in the first place.
This is why the question "did we change the hardware" is the wrong frame. The right frame is "did we change anything the original test report relied on." If you certified the device under Giteki certification to import a wireless product into Japan, that certification was issued against a specific design, not against the product category. A revised design is a different thing from the regulator's point of view, even when an engineering team keeps calling it the same SKU.
What Actually Gets Re-Tested When Hardware Changes?#
Re-testing, when required, focuses narrowly on the RF characteristics that changed, not on re-running the entire original test campaign from scratch. If a PCB respin only moved trace layout without touching the RF front end, the certification body can often confirm no material RF impact with supporting documentation rather than a full retest. If the change touches the antenna, the power amplifier, the oscillator, or the filtering that shapes the emission mask, expect frequency accuracy, output power, occupied bandwidth, and spurious emission limits to be measured again against the Radio Act technical standards.
Equipment certified under the mass-production route, Technical Regulation Conformity Certification, is approved against a construction design rather than a single physical unit, which gives a manufacturer more room to argue that a minor, RF-neutral change stays inside the existing design file. Equipment certified under per-unit Technical Conformity Certification has less of that cushion, because the certification was tied to the specific unit tested. Either way, the certifying body makes the final call on whether a given change stays inside scope.
Does a Firmware-Only Update Need Re-Certification?#
A firmware-only update needs no re-certification when it leaves every RF-affecting parameter untouched: transmit power, frequency range, channel selection logic, modulation scheme. A firmware update that changes the user interface, adds an application feature, or patches a security vulnerability without touching the radio stack's RF behavior falls outside what Giteki certification tests for. The dividing line matches the hardware case: whether the firmware changed what the radio transmits.
Firmware that adjusts power output by region, unlocks additional channels, or changes modulation to improve throughput is a different matter, because that firmware now does the job that used to belong to a hardware design choice. Manufacturers that ship region-locked firmware to keep a single hardware design compliant across multiple countries should treat any update to that region-lock logic as a potential RF-characteristic change and document the review accordingly.
What Happens If You Import or Sell an Uncertified Revision?#
Importing or selling a revised unit that no longer matches its certified design, without confirming the revision stays inside scope, exposes the product to a compliance gap at the border or in the market, regardless of how trivial the revision seemed functionally. The Giteki mark on a device represents that the unit matches a specific certified design, and a device that no longer matches it carries the same exposure as one that was never certified. This is the same underlying exposure covered in whether a wireless device needs Giteki certification before it can be imported into Japan in the first place, just triggered by a revision instead of a first import.
The practical risk shows up in two places. One is import clearance, where customs can flag a declared radio product against its certification record. The other is the overlap with power-handling components: a hardware change that touches a battery, charger, or power supply circuit independently triggers a fresh look at PSE electrical safety certification alongside Giteki, since the two certifications test different things and a component swap can affect one without affecting the other.
How Should Manufacturers Document a Hardware Change for TELEC?#
Document the change as a delta against the original construction design document: the schematic diff, the bill-of-materials diff for any RF-path component, and a statement of whether the change affects frequency, power, modulation, or spurious emissions. Keeping that documentation current for every change, including ones believed to be RF-neutral, is what lets a certifying body issue a fast no-impact confirmation instead of defaulting to a full retest out of caution.
Teams still in active hardware iteration sometimes confuse this process with testing under an Experimental Station Licence for IoT development. That licence covers trial and research use before a design is frozen; once a revised design goes to commercial sale, re-certification against the construction design document is the applicable step. Aplash reviews the specific change against the certified design record, determines whether TELEC re-testing or a construction-design amendment applies, and manages the submission through Giteki and the related ACP customs filings when the revision also affects import documentation.
(a) A change that alters frequency, output power, modulation, or spurious emissions against the certified construction design document requires re-certification or a certifying-body review before the revised unit is sold or imported. (b) A change confined to components outside the RF path, such as unrelated passives, connectors, or non-radio digital logic, may stay inside the existing certification, but the certifying body confirms this; the manufacturer does not assume it. (c) A firmware update is judged by the same RF-characteristic test as hardware: it stays outside the re-certification requirement when it leaves what the radio transmits unchanged, and falls inside it when it changes power, frequency, channel, or modulation behavior.
Frequently Asked Questions#
We only changed a resistor value on the PCB. Do we still need to tell TELEC?
If the resistor falls outside the RF transmission path and has no effect on frequency, power, modulation, or emissions, it is unlikely to require re-certification. The certifying body confirms this against the construction design document; a documented change log for every component change, RF-neutral ones included, avoids a dispute later if the device is questioned at customs or during a market audit.
Does changing our antenna supplier count as a hardware change requiring re-certification?
Yes, in almost every case. The antenna is part of what the original certification tested, and a different antenna, even one with similar specifications, can shift radiated power, gain pattern, or spurious emissions enough to fall outside the certified design. Antenna changes are one of the most common triggers for a full or partial retest.
Can we keep selling existing stock of the old design while we recertify the new revision?
Existing stock manufactured and certified under the prior design keeps selling under its original Giteki certification, since that certification attaches to the design as tested. The revised design needs its own certification status before units built to the new design are imported or sold, and confirming with the certifying body that it treats the two designs as separate approved designs keeps the stock lines distinct.
This article is informational only and does not constitute legal, tax, or regulatory advice. Consult a qualified advisor before acting on the content. Last updated: October 2026.