Although the trend to simplify telecom compliance procedures continues around the globe, a number of markets in Asia still require rather involved in-country testing and application procedures. This article presents an in-depth look at China and India—two critical markets for many telecom compliance professionals today.

Entry into the World Trade Organization (WTO) has been embraced with enthusiasm in China, where membership and its inherent opportunities has been anticipated for months. The market's promise is not being lost on the world's telecommunications equipment makers as they prepare to market more and more products in the world's most populous nation.

The Ministry of Information Industry (MII) of the People's Republic of China is charged with administering the country's telecommunications certification regime. Telecom approval is granted in the form of a network access license (NAL).

The MII regulations that govern the NAL are referred to as the "Measures for Administration of Interconnection of Public Telecommunications Networks." These regulations went into effect in early 2001, replacing the previous "Arrangements for the Approval of Network Access of Telecommunications Equipment," which had governed the process since the first truly national telecom type approval regime was implemented in China in 1999. Before then, it was still possible for each regional or provincial authority to require its own approvals for network connection. The system implemented in 1999 clearly established that no party was to require a certification redundant to the MII NAL.^1,2

The regulations unveiled in 1999 also gave teeth to the national type-approval regime. They provided for market sampling of telecommunications equipment and spelled out fines and other penalties for violations. This strength was carried through into the current regulations promulgated in 2001. WTO emphasizes that members evenly enforce their own laws and regulations. Because this WTO mandate levels the playing field, China has experienced an increase in the number of equipment vendors pursuing approval.

What Equipment Requires Approval? The current regulations clearly state that certain types of equipment may be neither connected to the public network nor sold in China unless approved. The three types of equipment that require an NAL are:

This article focuses on wire-line TTE and equipment for network interconnection. The approval process for radio equipment is similar, but it should be addressed separately to avoid confusion.

Product families. In the telecom industry, it is common for families or series of products to share common network interface modules or cards and vary only in chassis or host form factor. MII's system, however, is built around system model numbers. Approval is granted at the system level, and each model chassis or system must be submitted on a separate application with separate test reports. MII does not recognize the concept of independent host approvals for network interfaces. Even though in some cases test labs may want to avoid redundant testing on a series of hosts using the same interface modules, MII requires that each product must be tested. Test labs can often provide guidance on this issue.

What Documents Are Submitted to MII? The application to MII includes the following documents:

The documents marked with an asterisk in the list above must be submitted in the Chinese language. MII expects certain information in each document. A company's various product and corporate literature is likely to have much of this information, but compiling it can be tedious. The process is usually more complicated than just having product or company brochures translated.

Who Can Apply? One of the first important considerations in the approval process is who will serve as the applicant for the approval. MII requires that the NAL applicant be a properly registered Chinese company. This company can be the manufacturer's Chinese subsidiary, but it can also be a China-based distribution partner. In either case, the certification also lists the manufacturer of the equipment, which avoids some of the issues of approval ownership that can arise when only a local distribution partner is named as the approval holder.

The approval process at MII begins with a preliminary submission of an application package to the MII reception center. A preliminary submission can help flag any major shortcomings in the materials before submitting the final application package. Since China's admission into WTO, MII has scrutinized documents submitted with approval applications much more thoroughly. With an eye toward full and even enforcement of the requirements, the officials who examine applications are paying close attention to see that the submitted documents are complete and detailed and that applicants are complying with all regulations.

After the initial review, the equipment goes into testing, and MII examines the application in detail. The type of equipment determines the testing required and the steps in the
examination.

Required In-Country Testing. The application procedure for an NAL requires testing in China at an MII-accredited test laboratory. Existing test reports to international standards such as the Federal Communications Commission's Part 68 or the European technical basis for regulation (TBR) standards can be included in an application for reference. However, MII does not accept these test reports in lieu of testing by a Chinese laboratory.

Telecom testing in the laboratory is conducted to Chinese national standards, such as those listed in Table I. Some standards are available in English, but most have not been translated. Many of China's standards are based on International Telecommunication Union Telecommunication Standardization Sector (ITU-T) recommendations, which provides some measure of comfort to foreign manufacturers that their equipment will meet Chinese testing requirements. Because China evaluates equipment at the system level, MII often tests
higher-level system functions of more-complex and modular equipment rather than adhering to the strict "prevention of harm to the network" mission demonstrated by regulators in some other markets. This system-level aspect of the testing continues to be a challenge for foreign manufacturers.

Because Chinese test labs reserve the right to add tests to a plan based on their own assessment of equipment after it arrives, it can be difficult for manufacturers to define a complete test plan before the equipment enters the laboratory. Striving to agree on as much of the testing as possible at the start of the process can help avoid schedule delays, but it may not eliminate them altogether.

The number of test samples the laboratories require varies with the type of equipment. Testing fees also vary. For most equipment types, Chinese laboratories require four units to be submitted, but the laboratories sometimes make exceptions for large, complex, and costly equipment. Generally, if the total capacity of a system is more than 20 Gb/sec, as few as one unit (with two of each interface module or card) will suffice for testing.

For some types of equipment, MII also requires manufacturers to submit results of extended network field testing in China as part of the application. This requirement generally applies to what MII considers higher-end equipment or newer technologies, such as core routers and switches, ATM network equipment, and Internet protocol (IP) service platforms or gateways.

Although MII does have some guidelines for equipment that must undergo such testing, the best course is to have MII review a product to be certain of specific requirements. A report generated from performance evaluation on a Chinese customer's network often fulfills this field-testing requirement.

Once laboratory testing, any field testing, and test reports are complete, MII reviews the application. This review can also vary based on the type of equipment. For less-complex equipment like telephone sets, modems, and edge routers, MII's Telecommunications Administration Bureau (TAB) reviews the application directly and grants certification if the application is satisfactory.

For many of the same higher-end and new types of equipment that require network testing, MII also requires that a panel of telecommunications experts (convened by MII) review the application. The panel generally consists of 7–10 specialists from test laboratories, academic institutions, service providers, and others. The panel calls representatives of the applicant or manufacturer to appear to answer a battery of questions about the equipment, its function, its performance, and how it was tested.

Once the expert panel's review is complete, an application is normally circulated to TAB for final review, but it is possible that the panel could require additional information or testing before signing off on an application. Once TAB has completed its final review, it issues the NAL certificate and the equipment labels.

Time frames. The time required to complete the process from application compilation to certification can vary greatly, depending on the type of equipment. Products such as simple terminal equipment that require only straightforward laboratory testing and no review by an expert panel can often be approved in as little as six weeks. Larger and more-complex equipment subject to more-extensive testing and application review can take six months or more to make it through the process.

Testing and application fees. The application fee to MII is CNY 1100 or CNY 2200 ($133 or $266), depending on the type of equipment. This fee is paid in local currency at the start of the approval process. Laboratory testing fees also vary depending on the type of equipment, but these typically fall between CNY 9000 and CNY 165,000 ($1089 and $20,000). The test laboratory should be able to define required fees before testing begins.

Labeling. MII regulations require that approved equipment be labeled. The applicant must purchase labels, known as the network access identifier (NAI), from MII. Labels are CNY 0.60 (7 cents) each. A sample of the label is shown in Figure 1.

Figure 1. A voided MII network access identifier label.

Regulations stipulate that the NAL number must be printed on the packaging and in the advertising of approved equipment. Approved equipment must also carry warranty cards and manuals in the Chinese language.

Product modifications. MII's regulations specifically prohibit any modification to the design of approved equipment. There is no provision for notification to MII of design changes, so strictly speaking, any design change requires a new NAL application, including testing of the redesigned equipment.

Renewals. The network access license is valid for three years once granted. If the equipment is still on the market in China as the renewal date approaches, the original applicant should submit a renewal application at least three months prior to expiration so that the original approval will not expire before the renewal is issued.

Another critical telecom market is the country with the world's second-largest population. Recent regulatory changes in India removed a ban on voice-over-IP telecommunications services. These regulatory changes and India's rapidly growing information technology infrastructure make India another key destination for global equipment vendors.

In India, certification for telecommunications equipment is the responsibility of the Telecommunications Engineering Centre (TEC) of the government's Department of Telecommunications (DOT). Document No. 005 TAP TEC, "Approval Procedure," lays out the regulations governing telecommunications equipment approvals.³

Interface or Type Approval? For telecommunications equipment, TEC issues two kinds of approval, which are tied to two different kinds of TEC approval standards. Approval against TEC's general requirements (GR) is referred to as type approval. Approval against its interface requirements (IR) is referred to as interface approval. In fact, both are what most compliance professionals consider type-approval procedures in that both are certifications of a design, coupled with a commitment by the manufacturer to maintain manufacturing quality and not to change the design.

There are two key differences between TEC's type approval and interface approval. First, both the testing and the application process for type approval are much more demanding than for the interface approval. The other key difference is that approval against the GR standards is required to sell equipment to one of the government carriers in India. These service providers, Bharat Sanchar Nigam Ltd. (BSNL) and
Mahanagar Sanchar Nigam Ltd. (MTNL), are currently part of India's DOT, but there is a movement to privatize them.

TEC developed the GR standards to serve as part of the equipment procurement process for the government carriers. As long as the equipment will not be sold to these service providers, approval against only the IR standards is required to sell the equipment to consumers, enterprise customers, and competitive service providers—anyone except the government service providers.

For the most part, equipment vendors pursue interface approval unless specifically directed to obtain type approval by a service provider customer.

What Equipment Requires Approval? India's regulations specify five categories of equipment requiring TEC approval.

Essentially, any telecommunications terminal or network equipment to be connected in India requires approval. Despite the term interface approval for evaluation against the IR standards, approval is at the system level for both the IR and GR standards. That is, TEC does not approve individual interfaces; it approves systems. TEC does not recognize independent-of-whost approvals for interface modules. And it does not accept a series of hosts that share common interface modules on one application. Approval is granted to the system (host) model number. In this respect, India's TEC and China's MII are similar. TEC approval certificates list the model number or name of the host system, as well as the interfaces that were tested in the approval process.

It is important to note that TEC's GR and IR approval standards typically describe a type of equipment rather than a type of interface. For example, India has separate approval standards for routers, remote-access servers, and media gateways. Each standard then defines a variety of network interfaces that must or may be supported on an applicant's products. This prescription in the approval standards of specific equipment features makes it important to review which approval standard is best suited to the particular equipment before starting the approval process.

Who Can Apply for the Approval? TEC defines four types of companies that may apply for equipment approvals:

The location of an applicant company's headquarters in India determines where an applicant submits the approval application. Regional TEC (RTEC) offices are located in each of five geographic regions. Major RTEC facilities are in New Delhi, Mumbai (Bombay), Bangalore, Hyderabad, and
Calcutta. An application must go to the RTEC for the region in which the applicant's headquarters is located. TEC requires the following items for applications.

In addition to the required items, manufacturers should include any existing international standard telecom test reports (most often to European standards) and IEC 60950–based safety test reports for reference. Such reports can help strengthen the application package.

The appropriate RTEC reviews the application documents. If the documents are acceptable, the RTEC collects the fees and allots a test date for the equipment. The final submission to TEC includes the test results from the RTEC laboratory as well as the full application package. The RTEC issues the
approval certificate directly to the applicant generally within one month of this final submission.

Type-Approval Applications. For type-approval applications against TEC's GR standards, TEC conducts an infrastructure assessment before issuing approval. This assessment is a detailed evaluation of the applicant's facilities that will support the approved equipment once it has been sold. This requirement stems from TEC's role in evaluating equipment for procurement by DOT carriers. Evaluating the applicant that would presumably support equipment purchased for the government carrier is an integral part of this process. The infrastructure assessment includes a validation of quality-assurance measures, production processes (if the applicant is a manufacturer), test equipment, testing procedures, and other elements related to how the applicant will support the products.

TEC requires that testing be conducted at one of the RTEC facilities. India has no foreign or privately accredited laboratories, and TEC does not accept international standard test reports in lieu of its own testing.

However, some TEC facilities do not fully support testing called for in TEC's own approval standards. In such cases, it is the applicant's responsibility to arrange for the necessary equipment or facility to conduct the tests. The applicant must also arrange for the testing to be supervised by TEC staff.

The provisions that apply to individual network interfaces in the GR and IR approval standards generally focus on characteristics of the interfaces and are often based on ITU-T recommendations. However, product evaluation may be based on more than the sum of testing each network interface. For example, some features are required to be supported. Because TEC standards are organized around equipment types, and because the pace of innovation in telecommunications equipment continues to outstrip revisions of TEC standards, TEC may require certain features that a product does not support, even though the product performs its main functions very well. This provision leaves an applicant on the horns of a dilemma: make an engineering change to the product to have it support an obscure feature, or lobby TEC to waive the requirement. Either option can delay the approval process for many months.

If equipment has already been granted interface approval, testing performed against the IR standard for that approval need not be duplicated for type-approval testing. In fact, securing interface approval is often a good preparatory step for companies planning to pursue the more-intensive type-approval process. TEC officials have recommended this approach.

Equipment submitted for type-approval applications also undergoes two other sets of testing. In addition to evaluating the equipment's telecommunications function, TEC also performs rigorous environmental testing on the system.
A field trial is also conducted. The field trial focuses primarily on network compatibility and on evaluating operation and maintenance issues.

Shipping requirements. In nearly all cases, TEC requires that two working units of a product be presented for testing. It is important to review the customs procedures before shipping test-sample equipment into India. Many countries allow the import of test-sample equipment under an international carnet procedure. Such procedures enable the shipper to post a bond for customs duties that can be returned if the equipment is reexported within a certain time period. However, India does not recognize international carnets. India has its own procedure, called duty drawback, for recouping customs duties upon reexport. This procedure is cumbersome and requires close involvement by the shipment's consignee. Furthermore, the amounts eligible for refund can be difficult to calculate. This procedure is of greatest concern to manufacturers of large equipment with high declared values that would attract the attention of customs officials.

Time frames. The overall time frame from application submission to product certification in India varies based on the equipment type and the kind of approval sought. In general, interface approval for a product such as an analog modem can be completed in as little as six weeks—less time if TEC issues the certificate quickly at the completion of the process. TEC officials are very familiar with the standard. Approvals for more-complex equipment or against the GR approval standards often require as long as six months. Naturally, schedules are extended when equipment does not meet the provisions of a TEC requirement.

Testing and application fees. Fees are paid to TEC for application and testing after initial review of the application but before the test date is set. Fees were increased in October 2001. They now range from INR 17,500 ($358) to INR 1,750,000 ($35,768). Most products fall somewhere in the middle. Fees for interface approval of analog modems and other customer-premises-equipment devices are INR 63,000 ($1288). At the higher end, fees for media gateways are INR 1,050,000 ($21,460). All fees must be paid by bank draft in Indian rupees.

Labeling. Once equipment is approved, it must be marked to demonstrate approval. Manufacturers can apply their own markings; there are no labels to be purchased from TEC. The marking must include the approval certificate number, the date of the approval, the manufacturer's name, and the equipment model number.

The only format restriction for labels addresses equipment that is too small to display the approval number. In these cases, TEC may allow the approval number to be included in the packaging. If a manufacturer determines that this method is necessary, a request must be sent to TEC.

Modifications. TEC procedures have no provision for modification of an approved product. Any changes to approved products trigger the need for a new approval.

Renewals. TEC approvals are valid for three years from the date of issue. If an applicant plans to seek renewal, the application should be submitted at least three months before expiration of the current approval.

Although China and India are remarkably different in culture, history, politics, and most other aspects, their telecom approval processes do have a few things in common. Recent regulatory changes in both countries have made them more-attractive markets for telecom manufacturers.

As both markets continue to grow and make up more of the worldwide market for telecommunications equipment, knowing how to navigate the telecom approvals processes in each market will be key to successfully marketing products in both countries.