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Central and South American Approvals: Green Light or Red Tape?

Helen Jones

Some progress is being made, but many Central and South American countries still present many unique requirements for telecom approvals.

Recent liberalization of telecommunications and services in Central and South America has resulted in a great deal of investment in the telecommunications sector and has created an exciting new market offering ample opportunities for manufacturers and equipment suppliers. Getting approval for telecom equipment in the region can still be hard work, but as this article demonstrates, the situation is improving overall.

Manufacturers looking to distribute and sell telecommunication products in these markets must contend with a wide range of approval issues, some of which are unique to a particular country. One of the main problems facing applicants to all countries is language. As a general rule, approval applications for Central and South American countries should always be submitted in the local language (Spanish or Portuguese). Although English is spoken in some organizations, the ability to speak the local language offers a distinct advantage when dealing with the approval authorities and test laboratories.

Approval requirements and processes vary greatly from country to country in Central and South America. Some countries, such as Bolivia, have no formal approval regime in place, whereas other countries such as Argentina, Brazil, and Chile have much more formalized approval regimes with their own national standards and certain requirements for in-country testing for almost all product types. Between these two extremes are countries such as Ecuador, Paraguay, and Peru, which have their own national procedures and standards for certain equipment types, but will accept certain other foreign approvals as the basis for issuing their own national approval.

The countries of Central America such as El Salvador, Honduras, and Nicaragua will frequently carry out a review and validation of U.S. Federal Communications Commission (FCC) test reports and approvals. Several initiatives have been developed over the past few years to harmonize approval processes within Central and South America. Although much progress has been made, a lot of work still remains to be done before the goal of mutual recognition of test reports—and especially mutual recognition of type approval—will be achieved to provide manufacturers with a one-stop approval route to the markets of Central and South America.

The key to success, therefore, is to gain contact with each country to confirm the individual approval requirements. The individual requirements of the 10 most important markets, listed here in alphabetical order, are detailed in this article.

Argentina

Equipment Requiring Approval. Approval is required for all terminal equipment to be connected to the public telephone network. Approval is also required for most radio equipment. For those interested in Bluetooth and WLAN, approval is also required for low-power spread-spectrum products operating in the 2.4–2.4835 GHz band.

Historically, telecom operators have included type approval as a requirement for equipment procurement and will request additional testing of network equipment to be performed prior to purchasing of equipment.

Equipment Not Requiring Approval. There are no approval requirements for equipment connecting to private networks, digital leased lines (DLL), or integrated services digital network (ISDN). In the case of ISDN, no public service is currently available, but this is now set to change following the opening of the market to full competition in November 2000.

There is also no route to approval for telecommunication equipment that offers optical interfaces. However, standards are being drafted, and it is likely this type of technology will begin to be used in Argentina in mid-2001.

Approval Process. The organization responsible for type approval is the Comisión Nacional de Comunicaciones (CNC), which also controls the Register of Telecommunications Equipment and Activities. Approved telecommuni-cation equipment is listed on this register. The local company applying for type approval should apply for registration on the "activities" part of the register at the same time.

When submitting approval applications, it is important that product-specific application forms are used. Typical of many of the South American requirements (and much like that of Spain itself in the days before the R&TTE Directive), all documentation provided in the application pack must be reviewed and endorsed by a local expert engineer who is a member of COPITEC (the Argentine professional engineering body). The COPITEC engineer is personally responsible for all of the technical documentation he signs and stamps as being correct. The engineer also submits the application to CNC. Taking the time and effort to find a local engineer who takes initiative can facilitate the path to approval.

It is important to note that a product approval application must be submitted for each model, regardless of whether the products belong to the same family or share common circuitry.

Equipment Testing. CNC will not accept test reports from laboratories outside of Argentina, and products must undergo in-country testing at one of the three accredited test laboratories. Although foreign test reports are not accepted, experience has shown that including them in the application pack can speed up the approval process.

Testing costs and time scales vary among the laboratories. In the case of radio products, test lead times can be quite lengthy. CNC, however, sometimes issues provisional approval when testing lead times prove excessive.

Local Presence. Only companies or individuals that have a legal presence in Argentina and are registered on the Public Trade Register can apply for approval. Although individuals can apply, normally companies submit applications, because the applicant must provide a guarantee to provide equipment spares and maintenance for the duration of the product
approval.

EMC and Safety Requirements. There are no mandatory EMC requirements for approval in Argentina. Argentine safety requirements for low-voltage electrical products are covered by Resolution 92/98 (Resolución S.I.C y M N 92/98) of the State Department of Industry, Commerce, and Mining. Only products that comply with the safety requirements of this resolution are allowed on the market.

The Instituto Argentino de Normalización (IRAM) is the body responsible for safety certification, and reference can be made to national or international standards, such as the International Electrotechnical Commission (IEC) standards for the purposes of demonstrating compliance. Implementation of the resolution has been scheduled to occur over three different stages depending on product voltage.

Electrical and Electronic Products <50 V and >63 A. There are currently no electrical safety requirements for these products. Disposition No. 507/2000 has delayed implementation of Resolution 92/98 for these products until December 31, 2002, when these products must meet the requirements of Stage I of the resolution.

Stage I, lasting a period of one year, will require a manufacturer or importing company to present before the State Office of Home Trade in Argentina a declaration of conformity of the product to the essential safety requirements of Resolution 92/98. The declaration must be in Spanish and must conform to the example included in Resolution 92/98. The declaration must be presented for every shipment and must indicate the quantity of equipment contained in that declaration.

Electrical and Electronic Products Rated between 50 and 1000 V ac or 50 and 1500 V dc. All electrical and electronic products rated >50 V must meet the requirements of Stage II of the 92/98 Resolution: Certificate of Conformity to Type.

Under this stage, between now and April 2002, manufacturers must obtain a certificate of conformity to type from IRAM. This certificate is based on in-country product safety testing. However, in-country testing can be avoided by presenting test reports from recognized laboratories (e.g., Underwriters Laboratories or the Canadian Standards Association) within foreign countries with which IRAM has established mutual recognition agreements (MRAs).

From April 2002, Stage III of Resolution 92/98 will apply to those electrical and electronic products rated between 50 and 1000 V ac or 50 and 1500 V dc. Under this stage, a product certificate will be issued by IRAM under a conformity marking scheme, and the products must display the national safety mark. IRAM will issue the certification mark to UL clients if test reports compliant to IRAM, IEC, or UL/IEC harmonized standards are supplied. These reports must be from IRAM-recognized UL test laboratories.

Brazil

From June 1, 2001, manufacturers and telecommunication equipment suppliers must comply with a new Brazilian approval regime. The new regime brings in a lot of changes, most notably stricter requirements for product testing and the establishment of new certification assessment bodies (CABs) to evaluate a product's conformity to relevant standards.

Equipment Requiring Approval. According to the new regime, approval is required for: all telecommunication terminal equipment, all network equipment, a wide range of radio products, all equipment connecting to ISDN, all DLL (E1, E3, etc.) equipment, and all optical interfaces.

Approval Process. Accredited CABs are being set up in order to analyze test results and to verify a product's conformity to Brazilian standards. Type examination, product quality assurance, and total quality assurance will be performed. The CABs will be able to issue certificates of conformity to type, which must then be presented to Agência Nacional de Telecomunicações (Anatel). This approvals body then endorses the certificate and issues its own homologation document.

Product Testing. Under the new regime, third-party accredited laboratories must be used for product testing. Products manufactured outside of Brazil must be tested by one of the following:

  • Brazilian laboratories accredited by Inmetro, the Brazilian accreditation organization.
  • Foreign laboratories accredited by Inmetro.
  • Foreign laboratories with which Inmetro has established MRAs.

The requirements for product testing will become much stricter, and it will no longer be possible for foreign manufacturers to use a local specialist engineer (a member of CREA, the professional Brazilian engineering organization) to review and endorse existing foreign test reports.

Local Presence. An in-country presence is required in the form of a locally registered company (either directly or via an authorized agent) in order to apply for and hold approval in Brazil. The local company applying for approval will also be required to guarantee the supply of spares and maintenance for the product.

Other Changes. Under the new approvals regime, Anatel will also introduce a fee of approximately $500 for the issuance of approval certificates.

Safety and EMC. Brazil plans to introduce new requirements for EMC and electrical safety soon. Details are currently unclear, but standards are likely to be based on IEC and International Special Committee on Radio Interference (CISPR) standards. All certified products must bear the Inmetro mark for safety and, after being approved, they must also carry the Anatel mark.

Chile

Equipment Requiring Approval. Only terminal equipment for connection to the country's analog public network requires approval. Network operators, however, are likely to require confirmation of compliance with international standards for equipment connecting to their networks.

Equipment Not Requiring Approval. There are no approval requirements for connection to leased lines, and even though there is a public offering of ISDN services, there are currently no approval requirements for connection to ISDN because no standards have been developed for this technology. Chile has no requirements for approval of radio products; therefore, licensing requirements exist to ensure control of spectral utilization.

Approval Process. The approval process in Chile is much simpler and less bureaucratic than in Argentina or Brazil. The body responsible for type approval in Chile is Subsecretaría de Telecomunicaciones (Subtel). All that is required for approval is a compliant test report from one of the five national accredited test laboratories. Approval application is usually by letter, and documentary requirements are not exhaustive. Subtel relies on the opinion of the test laboratory following its testing and review of the relevant technical documentation.

Once an approval is issued, it is the responsibility of the manufacturer or local representative to publish approval details in the Chilean Official Journal.

Product Testing. Subtel will not accept test reports from laboratories outside Chile, so in-country product testing in one of Chile's five accredited laboratories is mandatory. It is beneficial to include foreign test reports in the test application pack because they could help to reduce the extent of testing required. All testing is carried out to the relevant national standards (for functionality, EMC, and safety). Lead times at each test laboratory vary, but testing generally takes about one week, with a further week required to complete the test report.

Local Presence. There are no residency requirements for companies applying for terminal equipment approval. It is possible for a foreign manufacturer to apply for and hold the approval.

Colombia

Equipment Requiring Approval. Currently, only basic telephone handsets, satellite phones, and mobile cellular phones require approval in Colombia. However, plans for a new approvals regime that will include all types of telecommunication products, including fixed telephones, are being discussed.

Equipment Not Requiring Approval. Under the current regime there are no approval requirements for radio products, but it is necessary for the end-user to register them on a database. There is a public offering of ISDN and E1 DLL services, but no approval is required for connection to either one.

Approval Process. The organization responsible for type approval is the Comisión de Regulación de Telecomunicaciones (CRT). There is no specific application form for applying for type approval in Colombia—the applicant should submit a letter of application along with typical product technical documentation and test reports.

Product Testing. Colombia has only one accredited laboratory. While accreditation of new in-country laboratories is being carried out, CRT will accept compliant European Telecommunications Standards Institute (ETSI) and FCC test reports to demonstrate compliance.

Local Presence. A suitably registered local presence is required in order to apply for approval.

EMC and Safety Requirements. Currently, CRT accepts products that meet CISPR 22 requirements or equivalent standards. However, local operators generally accept equipment shown to meet European or equivalent standards. There are no mandatory safety certification requirements.

Ecuador

Equipment Requiring Approval. All terminal equipment connecting to the public switched telephone network requires approval. Approval is also required for cellular phones, trunk radios, and spread-spectrum radio products.

Approval Process. Ecuador has a well-formalized procedure to which applicants should adhere when applying for type approval of telecommunication equipment. There are specific application forms to be used, and these must be submitted to the approvals body, Secretaría Nacional de Telecomunicaciones (Senatel), along with product technical
documentation.

Product Testing. In-country testing is usually necessary, and a fully configured test sample is required. The equipment is tested to Ecuadorian national standards where they exist. Where standards do not exist, products are tested for compliance with the appropriate FCC requirement or international ETSI standard. Some basic functional testing will also be carried out. Once product testing is complete, the test report is forwarded to Senatel, which usually issues an approval certificate within one week.

Local Presence. A local presence is required in order to obtain approval in Ecuador. The local representative is also responsible for honoring guarantees for providing spares and maintenance.

EMC and Safety Requirements. Ecuador has no mandatory requirements for EMC and safety certification.

Mexico

Equipment Requiring Approval. Approval is required for all terminal equipment connecting to the public telecom network, including DLL and ISDN. Approval is also required for all radio products, including most digital products.

Approval Process. The body responsible for type approval is the Comisión Federal de Telecomunicaciones (Cofetel). Cofetel issues two types of approval certificates—provisional and permanent.

Provisional Approval. Similar to the processes of Brazil and Argentina, a local specialist engineer (perito) is used to analyze test reports issued by laboratories outside of Mexico for conformity with Mexican standards. If noncompliant, further testing will be requested. If satisfied that Mexican requirements have been met, the perito then prepares a specialist report and submits the application to Cofetel. Provisional approval lasts for one year, and it is possible to renew the certificate twice.

Permanent Approval. Permanent approval for products new to the Mexican market can be obtained by first submitting samples for in-country testing at Mexico's radio laboratory or its newly accredited terminal equipment testing laboratory. Once the equipment is confirmed as being compliant, the laboratory issues a test certificate that can be used to support the application package submitted to Cofetel.

Existing provisional approvals can be updated to permanent status provided that two peritos review and confirm that the foreign test reports conform with Mexican standards. In applying for both provisional and permanent approvals, it is necessary to include product technical documentation such as schematics, lists of components, and user guides along with the specific application forms.

Local Presence. A local presence is required in order to obtain type approval in Mexico. The local representative should be legally registered and must also provide a maintenance warranty (for a minimum of five years) against telecom products approved and supplied in Mexico.

Safety Requirements. Mexican safety certification is known as Norma Oficial Mexicana (NOM) certification and is performed against specific NOM standards. Without this certification, electrical equipment cannot be imported into Mexico. The body that deals with NOM safety certification is Normalización y Certificación Electrónica A.C. (NYCE). Safety certification is a totally separate procedure from the approval process. Just as with telecom approval applications, certification for NOM safety will only be accepted from the local importing or distributing company. It is useful to note that NOM certificates are nontransferable, and each company must apply for its own NOM certificate.

NOM Certification Procedure. Application to NOM should be made in the Spanish language using specific NOM application forms. The application should include technical information, legal documents, and test reports. Test reports from certain laboratories will be accepted by NYCE, although in-country testing is frequently required. After testing has been satisfactorily completed or an existing report assessed, the test laboratory sends the test report to NYCE.

Paraguay

Comisión Nacional de Telecomunicaciones (Conatel) is the body responsible for approval of telecommunication products in Paraguay. Currently the approval certification is voluntary, and provisional approval certificates are issued lasting five years. Changes to the present regime are under way, however, and it is expected that type approval will eventually become mandatory.

Products Subject to Voluntary Approval. Manufacturers have the option to apply for voluntary approval of telecommunication terminal equipment and all radio communication equipment with a transmission power greater than 10 MW. Another option includes obtaining approval of equipment connecting to DLL, ISDN, and fiber-optical networks.

Local Presence. To pursue voluntary approval, manufacturers must appoint a locally based representative to apply for and hold the approval.

EMC and Safety Requirements. Paraguay has no mandatory safety or EMC requirements.

Peru

Approval Process. The body responsible for type approval is the Ministerio de Transportes, Comunicaciones, Vivienda y Construcción (MTC). Approval is required for each make and model. There are specific approval application forms that must be submitted along with technical documentation.

Equipment Requiring Approval. Both radio and terminal equipment require approval in Peru. Approval is also required for connection to E1, E2, and E3 DLL and for equipment connecting to fiber-optical networks. Network equipment is also subject to type approval. Approval is required for all types of wired and wireless terminal equipment.

Equipment Not Subject to Approval. For those interested in LAN and Bluetooth frequency hopping, spread-spectrum products are not permitted in Peru.

Product Testing. Very few national standards are developed in Peru, and no laboratories have received accreditation for testing against these standards. As a result, MTC usually accepts foreign test reports against international standards. It is not necessary to submit a product sample for testing with the application; however, random testing is sometimes carried out by MTC.

Local Presence. Although a local presence was previously mandatory, it is no longer necessary, and a foreign company can now submit an approval application. It is advisable, however, to appoint a local representative to coordinate with MTC and to collect the approval certificate because MTC does not mail approval certificates overseas.

EMC and Safety Requirements. MTC recognizes test reports for EMC based on CISPR 22, and standards for electrical safety in Peru are based on the relevant IEC standards.

Uruguay

Equipment Requiring Approval. All communication equipment types require approval in Uruguay. ISDN services are available in Uruguay, but they have little experience in approving terminal equipment for connection to an ISDN network, so ISDN approvals is a relatively new process. As the process evolves, Uruguay intends to develop new and relevant procedures. Currently, applications for approval of ISDN products should include a copy of the national or international standard with which the product complies.

Approval Procedure. Approval of wired telecom equipment falls under a separate organization. The organization responsible for approval of wired terminal equipment is Administración Nacional de Telecomunicaciones (Antel). The Dirección Nacional de Comunicaciones (DNC) is responsible for the approval of radio equipment.

Specific application forms must be submitted for terminal and for radio equipment, and both must include the product technical documentation. Uruguay currently does not have any of its own accredited laboratories, and so foreign test reports are accepted as the basis for issuing national approval. Provided good quality reports are used, no in-country product testing is required.

Local Presence. To apply for approval of radio products, it is not necessary to have a locally based representative. For terminal equipment type approval, however, it is advisable to have a local representative because approval fees are paid by the unusual means of being added as a supplementary charge to the telephone bill of the approval applicant.

Venezuela

Equipment Requiring Approval. From January 2001, in accordance with the new Organic Telecommunications Law, type approval is obligatory for most types of telecommunication terminal and radio equipment. However, Consejo Nacional de Telecomunicaciones (Conatel) is currently working on developing a list of "products exempt from approval," which will be published shortly. Product types that appear on this list will not require further approval for Venezuela.

Approval Process. Conatel does not have any accredited laboratories or national standards, which means that in-country testing is not required. Recognized foreign standards are usually accepted as a basis for issuing approval. The approval application form should be accompanied by product technical documentation.

Local Presence. Application for approval in Venezuela is not dependent on an authorized local representative.

EMC and Safety Requirements. Venezuela has no mandatory requirements for safety and EMC certification.

Conclusion

As this article shows, there is great diversity among approval regimes in Central and South America. Several initiatives have been made over the past few years, however, and a great deal of work has been done toward harmonization of telecommunication equipment approval and testing procedures in this area. The principal aim of these initiatives is similar to that of the European Union: to reduce technical barriers to trade in order to create a competitive free market for telecommunication products.

Of significant importance in this area is the work carried out by the trade groups Inter-American Telecommunication Commission (Citel) and Mercosur. Both groups have set up working groups responsible for creating commonality in certification procedures, for developing MRAs for conformity assessment, and for promoting harmonization of telecommunication standards. So far, Citel's progress is far more
encouraging than that of Mercosur.

Until the Citel MRA becomes fully implemented, manufacturers and suppliers of telecommunication equipment looking to launch their products onto the Central and South American markets will have to contend with the wide variety of national approval regimes that continue to evolve with new changes expected in a number of areas.

Approvals consultant Helen Jones is a fluent speaker of both Spanish and Portuguese. For the past three years she has managed multicountry approvals worldwide and has been a key figure in expanding InterConnect Communications's (http://www.icc-uk.com) range of expertise in telecommunications throughout Central and South America. InterConnect is based in Chepstow, Monmouthshire, UK. Jones is also coauthor of the Americas Approvals Manual and Radio Approvals Manual—Americas.

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