Global Regulatory Changes Prepared for TCBC Meeting

1
Global Regulatory ChangesPrepared for TCBC
Meeting 09-Apr-14

2
Scope of Presentation

• Introduction to PCS
• Global Regulatory Changes Overview
• Country Specific Focus
• Eurasian Customs Union
• Indonesia
• India BIS
• Ukraine
• Summary on other Regulatory Changes

3
Introduction to PCS

• Dynamic UK based Company established in 2004
• Specialists in managing certification of radio,
  telecommunications and ITE products
• 12,000 Approvals obtained in 160 countries
• Multi-lingual team with 9 key languages spoken
• We specialize in international projects and
  frequently manage projects for 50 countries
  simultaneously
• International blue chip customer base

4
Global Regulatory Changes - Overview

• Significant Regulatory Changes in the following
  countries
• Argentina
• Bolivia
• Malaysia
• Pakistan

5
Regulatory Changes - Argentina

• Sep 2013 - New standard affecting 2.4GHz and 5GHz
  WLAN released
• Came into effect on 4th November 2013
• All 2.4GHz and 5GHz devices tested under previous
  standard must be retested at the time of renewal
• 5600 - 5650MHz portion of the 5GHz Band 3 no
  longer permitted
• Bluetooth 2.1 exempt from retesting requirement

6
Regulatory Changes - Bolivia

• Type Approval requirements enforced June 2013
• Previously FCC Approval was sufficient
• Temporary Approvals issued during transition
  period, invalidated full Approval now required
• Local applicant required
• Paperwork only process
• Lead-time 5 6 weeks
• Validity 5 years

7
Regulatory Changes - Malaysia

• Add-Host Approval Scheme for Modules Abolished
  Mar 2014
• No longer possible to add host models to Approved
  modules via paperwork only process
• Each host now requires Approval in full,
  inclusive of local testing / sample inspection.
• Products Approved prior to change in regulations
  not affected.

8
Regulatory Changes - Pakistan

• Approval requirements for Mobile Phones
  introduced.
• Jan 2014 Pakistan Telecommunication Authority
  (PTA) introduced Type Approval requirements for
  cellular mobile devices
• New rules also apply to WWAN equipped tablets,
  and WWAN devices which are data only

9
EA Customs Union (EAC) Approval Scheme

10
Customs Union Agenda

• Introduction
• Scope and Limitations
• Differences to GOST, Advantages and Disadvantages
• Overview of Approval Schemes
• Certification
• Declaration
• Exemption Letter
• Serial and Batch Approval
• Product Categorization
• Labelling Requirements

11
Customs Union IntroductionOverview

• Harmonization of regulations for EMC
  (Electromagnetic Compatibility) and LVE
  (Low-voltage equipment) across Customs Union
  member states of Russia, Belarus and Kazakhstan
• Implemented Feb 2013 as replacement to the
  independent national GOST EMC / Safety Approval
  schemes previously enforced in these countries
• EA Customs Union (EAC) Approval is a singular
  harmonized Approval Certificate for EMC and / or
  Safety that covers all member states in the union

12
Customs Union IntroductionScope and Limitations

• Customs Union Approval does not cover RF or
  Telecom
• For RF or Telecom devices, separate national
  Approval to cover RF / Telecom function must
  still be obtained in Russia and Belarus
• Kazakhstan has no separate RF scheme so Customs
  Union Approval alone is sufficient.

13
Customs Union IntroductionKey Differences From
GOST
Changes GOST Scheme Customs Union Scheme
Applicant Foreign Manufacturer or Local Company Local Company
Route to Approval Single route via accredited lab Multiple routes and options CoC, DoC, Exemption Letter
Local Testing Requirement weakly enforced Requirement much more rigidly enforced
Factory Inspection No requirements / requirement weakly enforced Requirement much more rigidly enforced
Certificate Validity Maximum up to 3 Years Maximum up to 5 Years
Voluntary Approval Voluntary Approval Possible No Voluntary Approvals Possible
14
Customs Union IntroductionAdvantages and
Disadvantages

• Advantages
• Single EMC/ Safety Approval Certificate covering
  all customs union member states
• Options for Longer Approval Validity
• Flexibility to apply for Approval in any of the
  member states
• Disadvantages
• Increased complexity multiple routes and
  schemes to Approval
• Stricter requirements introduces local test and
  factory inspection requirements.
• Stricter supervision and monitoring of
  Certification Bodies

15
Customs Union IntroductionTransition from GOST

• Two Year Transition Period Allowed
• Existing GOST Certificates remain valid until
  stated expiry date or 15th March 2015 (whichever
  comes first)
• As of 15th March 2015, all GOST Certificates in
  circulation will cease to be valid and must be
  replaced with a Customs Union Approval

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Customs UnionApproval Schemes

• Three Approval Schemes
• Certification (Certificate of Conformity)
• Declaration (Declaration of Conformity)
• Exemption Letter
• Certification and Declaration scheme divided in
  to sub schemes
• Serial Approval
• Batch Approval

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Customs UnionApproval Schemes

• Approval Scheme
• Certification, Declaration or Exemption Letter
• Determined by product type, function and HS code
• Approval Scope
• Batch or Serial
• Applicant at liberty to select option that best
  suits their needs and requirements

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Customs UnionApproval Schemes

• Certification Scheme
• Third Party Certification Certification Body
  takes responsibility for compliance
• Required for devices in scope of Customs Union
  Technical Regulations on EMC and LVE
• Local Testing Required
• Physical Factory Audit / Inspection Required
• Family Approval Possible
• Local Approval Holder Required
• Lead Time 12 weeks (FI 12 weeks)
• Certificate Validity 1 - 5 Years

19
Customs UnionApproval Schemes

• Declaration Scheme
• Applicant takes responsibility for compliance
• Required for devices out of scope of Customs
  Union Technical Regulations on EMC and LVE
• Local Testing Required
• Local Approval Holder Required
• Family Approval Possible
• Lead Time 4 Weeks
• Certificate Validity 1 - 5 Years

20
Customs UnionApproval Schemes

• Exemption Letter
• Required for spare parts which are intended to be
  imported and sold in Customs Union Region as part
  of already Approved Host Device.
• Foreign Manufacturer can hold Approval

21
Customs UnionApproval Schemes

• Serial and Batch Approval
• Serial Approval For Serial Production valid
  for import of unlimited quantity of stated
  product(s) during lifetime of Approval
• Batch Approval For Single Import Consignment
  Only. Max units unstipulated. Manufacturers
  expected to apply reasonable judgement.

22
Customs UnionProduct Categorization

• Categorization In Scope and Out of Scope
  Determines which Approval scheme applies
• Products In Scope of Customs Union EMC and LVE
  Regulations are subject to Certification.
• Products Out of Scope of EMC and LVE
  Regulations subject to Declaration
• Rules can be open to interpretation. Lots of
  scope for variation and differences of opinion
  between Customs Union Certification Bodies

23
Customs UnionProduct Categorization

• Key Factors Determining Product Classification
• HS Code (Harmonised System Code)
• Model Name
• Power Supply and charging mechanism i.e mains
  A/C, DC Battery Only
• Input Voltage Rating
• Intended Use Industrial or Consumer
• HS Code is the chief determinant factor, however
  is rarely used in isolation alone. One or more of
  the above may also need to be considered

24
Customs UnionProduct Categorization

• Getting correct classification is crucial
• Incorrect classification can lead to
• Problems at import stage
• Severe penalties to manufacturer, local holder
  and Customs Union CB including
• Financial Penalties
• Confiscation of products
• Loss of accreditation status
• Imprisonment

25
Customs UnionLabelling

• Customs Union Label Artwork

26
Customs UnionLabelling

• Labelling Rules
• Label should be placed on the product itself, the
  packaging and the user manual
• If labelling product not feasible due to size
  restrictions label may be placed on packaging and
  user guide only
• Label must be clear and visible to the naked eye
• Minimum character height is 5mm

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Indonesia Regulatory Changes

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Indonesia Agenda

• General Regulatory Overview
• Focus on Regulatory Changes
• Rules for Modular Approval
• Approval of Dual Band Access Points
• Other Planned Changes
• Changes to Type A / Type B Approval
• New Application Prioritisation System

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Indonesia Regulatory Overview

• Process and Requirements relatively stable at
  current
• Potential for frequent regulatory changes of both
  minor and major impact
• Often implementation of changes can be disjointed
  and problematic due to lack of cohesion between
  Indonesian Government, Authority, Lab and Customs
• Several notable and significant changes
  introduced in 2013

30
IndonesiaRules for Modular Approval

• Multiple changes introduced during 2013 eroding
  strategic advantage previously conferred through
  Modular Approvals
• Modular Approval now only advantageous if the
  module is imported in to Indonesia in its
  stand-alone state, not integrated in to any host

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IndonesiaRules for Modular Approval

• Under new regulations - if module is imported in
  to Indonesia installed inside a host then host
  Approval must be obtained again in full from
  scratch
• Local testing on host must be repeated not
  possible to leverage any modular level results.
• Local importers no longer able to apply for Type
  B Host Approval, leveraging from Type A Modular
  Approval

32
IndonesiaDual Band Access Points

• Previously WLAN Access Points could only be
  Approved for single band use either 2.4GHz or
  5GHz only
• New Regulations from Jan 2013 WLAN Access
  Points may now be Approved for Dual Band Use
• Indonesia Frequency Plan - Unchanged
• 2.4GHz Channels 1 13
• 5GHz Band 4 Only Channels 149 161

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IndonesiaDual Band Access Points

• Approval Process for Dual Band Operation is the
  same as for Single Band Operation
• Two Accredited Laboratories
• Authority Lab
• Accredited Lab
• Sample Requirements - Strict
• Samples must be locked to Indonesian bands /
  channels only

34
IndonesiaProposed Changes

• Numerous proposed changes planned for Indonesia
  Regulatory process
• Proposed changes currently still under
  development and in consultation stage
• No commitments at current time regarding extent
  or timeframe of implementation

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IndonesiaProposed Changes

• Type A and Type B Approval format to be abolished
  and replaced with new system
• Type A Approval issued to manufacturer
• Type B Approval issued to importer (Required to
  Import Goods)
• Most common approach at current manufacturer
  obtains Type A Approval. Importer then obtains
  Type B Approval via paperwork only approach,
  leveraging local testing from manufacturers
  Approval

36
IndonesiaProposed Changes Cont.

• Price structured applicant selected
  prioritization system for processing of Type
  Approval applications
• Standard
• Expedite
• VIP
• New requirements for assessment of EMC, Safety
  and Human Exposure
• For WWAN products requirement for IMEI letter
  from authorised body

37
India BIS Safety Approval Scheme

38
India BIS Agenda

• Introduction
• Background to India Approval Schemes
• Overview of new BIS Approval scheme
• What and when
• Products requiring mandatory BIS Approval
• Organisations involved in scheme
• Procedure Overview
• Registration and product testing
• Moving forward
• Labelling Requirements

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India Approvals Overview

• Up until 2013 there have always been 2 Approval
  schemes in place in India specifically for this
  industry
• WPC (Ministry of Communications and IT
  Department of Telecommunications) covering Radio
  Approvals
• TEC (Telecommunication Engineering Centre)
  covering Telecom Approvals

40
India BIS What and when

• In September 2012, the Electronics and
  Information Technology Goods (Requirements for
  Compulsory Registration) Order was introduced,
  and enforced in March 2013.
• The Order requires that certain products imported
  to, manufactured in, stored, distributed or sold
  in India must conform to the Indian (safety)
  standards specified in the schedule. These
  products must then be registered as compliant
  with the Bureau of Indian Standards (BIS)
• Technical standards in interest of public health
  and safety
• Global quality standards for domestic
  manufacturers

41
Products requiring mandatory BIS
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Products requiring mandatory BIS
43
Testing standards
Product Indian Standard Title
1. Electronic Goods IS 6162010 (IEC 600652005) Audio, Video and Similar Electronic Apparatus - Safety Requirements
2. Laptop/Notebooks/Tablets IS 132522010 (ISO/IEC 60950-12005) Information Technology Equipment - Safety - General Requirements
3. Plasma/LCD/LED Televisions of screen size 32" and above IS 6162010 (IEC 600652005) Audio, Video and Similar Electronic Apparatus - Safety Requirements
4. Optical Disc Players with built in amplifiers of input power 2000W and above IS 6162010 (IEC 600652005) Audio, Video and Similar Electronic Apparatus - Safety Requirements
44
Testing standards
Product Indian Standard Title
5. Microwave Ovens IS 302-2-251994 (IEC-60335-2-252010) Safety of household and similar electrical appliances Part 2 Particular requirements Section 25 Microwave ovens
6. Visual Display Units, Video Monitors of screen size 32" and above IS 132522010 (ISO/IEC 60950-12005) Information Technology Equipment - Safety - General Requirements
7. Printers, Plotters IS 132522003 (ISO/IEC 60950-12005) Information Technology Equipment - Safety - General Requirements
8. Scanners IS 132522010 (ISO/IEC 60950-12005) Information Technology Equipment - Safety - General Requirements
45
Testing standards
Product Indian Standard Title
9. Wireless Keyboards IS 132522010 (ISO/IEC 60950-12005) Information Technology Equipment - Safety - General Requirements
10. Telephone Answering Machines IS 132522010 (ISO/IEC 60950-12005) Information Technology Equipment - Safety - General Requirements
11. Amplifiers with input power 2000W and above IS 6162010 (IEC 600652005) Audio, Video and Similar Electronic Apparatus - Safety Requirements
12. Electronic Musical Systems with input 2000W and above IS 6162010 (IEC 600652005) Audio, Video and Similar Electronic Apparatus - Safety Requirements
46
Testing standards
Product Indian Standard Title
13. Electronic Clocks with Mains Powers IS 302-2-251994 (IEC-60335-2-252010) Safety of household and similar electrical appliances Part 2 Particular requirements Section 25 Microwave ovens
14. Set top box IS 132522010 (ISO/IEC 60950-12005) Audio, Video and Similar Electronic Apparatus - Safety Requirements
15. Automatic Data Processing Machine IS 132522010 (ISO/IEC 60950-12005) Information Technology Equipment - Safety - General Requirements
CB Test reports therefore play a pivotal role in
the BIS Safety Scheme
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Who is involved

• Deity Department of Electronic and Information
  Technology Ministry of Communications
  Information Technology, Government of India
• BIS Bureau of Indian Standards
• Deity introduced and oversee the scheme, they
  update the mandatory list. Manufacturers also
  must register with Deity.
• BIS write the Indian standards and responsible
  for Approval process.
• No more extensions.

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Process Outline
49
Procedure Overview

• Manufacturer and Product Registration
• Both Deity and BIS involved
• Prior to product registration, each physical
  manufacturer (final assembly factory) needs to
  register with Deity
• Manufacturer registration and product local
  testing can proceed simultaneously
• Tests can only be conducted at BIS approved labs
  in India (per manufacturer)
• BIS allow for Approval of family/type on one
  certificate all models must still be tested.

50
Manufacturer Registration

• Pre-requisites
• 1. Full name and address of physical
  manufacturer (as per safety report)
• 2. Business registration license (or other
  official government issued document)
• 3. Contact details of the appointed member of
  factory manufacturer responsible for BIS
  registration
• 4. English translation of above is essential
• 5. Local nominee required
• 6. Online process, 3-4 days.

51
Accredited labs
52
Test Report requirements CB Test reports and
critical components

• CB Test Reports technical documentation must be
  submitted ahead of local testing
• All critical components must be declared and have
  evidence of conformity to IEC standards
• Conformity of Critical Components to standards
  harmonised with IEC will also be accepted.
• Where IEC standards are not available, test
  reports issued in compliance with other
  international national standards are accepted.
• Various cannot be listed on the Safety report.
  All sources of manufacturers, models and brands
  of a component must be identified and verified
  (with supporting evidence of conformity)

53
Product Registration Overview
54
Summary

• CB test reports still play an essential role and
  must be submitted to the lab ahead of test start
• Test reports will be issued by accredited lab for
  review at BIS
• Physical manufacturers must be registered before
  products can be Approved
• Once reports are issued, applicants can then file
  for product Approval/registration
• Certificates are issued for each physical
  manufacturer
• Approvals are valid for 2 years full renewal
  process is yet to be confirmed

55
Procedure Overview moving forward
56
Labelling requirements

• Self Declaration - Conforming to IS xxxxxx,
  R-xxxxxxxx
• IS xxx standard
• R registration number
• On the product and its packaging

57
Ukraine Approval Scheme

58
Ukraine Agenda

• Introduction
• Background to Ukraine Approval Schemes
• Overview on current requirements
• What and when
• Organisations involved in scheme
• Procedure Overview
• Certification
• Declaration
• Moving forward
• Labelling Requirements

59
Ukraine Approvals Background

• Beginning of 2011 - EMC standards and
  regulations were released mandating requirement
  for Declaration on EMC standards in addition to
  Certification (CoC).
• Beginning of 2012 - Safety standards and
  regulations were released mandating requirement
  for Declaration on Safety in addition to the CoC
  and EMC Declaration (if applicable)

60
Ukraine Approvals Background

• Beginning of 2013 - RF / Telecom standards and
  regulations were released to mandate that all RF
  and Telecom devices would require an RTTE
  Declaration, in addition to any applicable EMC
  and Safety Declaration.
• End of 2013 advised that Ukraine Certification
  (CoC) for RF/Telecom would be abolished.
  Declarations would remain.

61
What and when
Changes Before At present
Legacy Type Approval (RF / Telecom Certification) Mandatory Failure to sign European Association Agreement in Nov. 2013 - still legally in place, however CAB opinion remains divided Agreement in process for signature, however.
Route to Approval Via bi-monthly Commissions Meeting at Authority for Certification CABs now issuing Approvals directly for majority of products Commissions Meeting now only takes place once a month and is for Access Point Declarations Telecom Certifications only
62
What and when
Changes Before At present
Local Testing Enforced CABs will follow paperwork only process while political unrest continues and customs issues encountered
Certification Validity 1 year No expiry for devices such as Short Range Devices, Access Points and Cellular devices. Other products falling under Telecom Law will still have a validity of 1 year
Annual Technical Inspection N/A Under discussion for all Certificates with no expiry. Nothing yet in place.
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Who is involved

• National Commission for the State Regulation of
  Communications and Information (Authority)
• Mandate requirements for Certification and
  Declaration
• State Service of Special Communication and
  Information Protection of Ukraine (Authority)
• Commissions Meetings and Technical Standards
• Conformity Assessment Bodies (CABs)
• Local testing
• Issuance of Certification and Declaration

64
Procedure Overview - Certification

• At present, Certification is still legally
  required for
• all RF and Telecom devices
• Still 2 routes to
• Approval
• Local testing still required
• Manufacturer can still hold Approval
• At present, varies by CAB

65
Procedure Overview -Declaration (DoC)

• EMC - most host devices
• Safety anything mains connected
• RTTE all RF and Telecom
• Self Declared or via CAB

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Outline Declarations

• Local testing required 2 samples required
• Local holder required
• Manufacturer EU test reports can be leveraged to
  avoid testing for
• EMC Safety Declarations.
• If RTTE DoC process runs in parallel to CoC,
  testing does not
• need to be repeated.
• A single DoC listing EMC and/or Safety and/or RF
  standards can be obtained.
• No expiry local holder must maintain DoC for 10
  years
• Products which have obtained RTTE DoC must also
  be registered in the national Electronic Device
  Register of Ukraine mandatory for import

67
Procedure Overview moving forward
68
Labelling requirements
Mandatory for all Products with Declaration(s) If
processed via a CAB, CAB number should feature
below logo
Voluntary only for Certification CAB number
should feature below logo
Product and/or its packaging, operation and
accompanying documents or smallest consumer
packaging
69
Regulatory Updates
Country Change
Belarus Early 2014 - Compulsory certification requirement for all radio and telecommunication removed. Declaration now sufficient Removes the need for physical Factory Inspection, but local testing still required.
Vietnam New technical standards introduced affecting all RF devices. Additional EMC testing required to ensure its Compliance with QCVN18, full effects being investigated at present.
70
Regulatory Updates
Country Change
Gambia Changes to Type Approval guidelines introduced in July 2013. Certificates issued before 30th October 2013 will automatically expire on 31st December 2015. Renewal is then required.
Ghana New Type Approval guidelines implemented in January 2014. Now mandatory to submit samples for local testing.
Peru Portions of 902-928MHz band opened up again in 2013 915-928MHz and 916-928MHz have now been assigned as unlicensed bands
Yemen Type Approval procedures and requirements introduced at the end of 2013 Type Approval now mandatory.
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