Rules for Telecom Approvals in China
Chinese regulatory reforms streamline the rules but create higher
technical and documentary obstacles for marketers of telecom products.
a country relatively new to information technology (IT), China represents
a huge potential market for IT manufacturers. This is particularly
true in the area of telecommunications. Just five years ago, most
areas of China had five-digit telephone numbers. Many cities today,
however, have eight-digit numbers, and many of the country's 250
million city dwellers possess a pager, a cellular phone, or both.
Chinese government has undertaken a massive effort to revise its
laws and regulations in a manner consistent with World Trade Organization
(WTO) rules. But substantial barriers do remain in place, having
yet to be dismantled. Import barriers, an opaque and inconsistent
legal system, and limitations on market access combine to create
difficulties for foreign firms trying to compete in China. Although
China's trade liberalization efforts represent a step forward, new
regulations continue to be introduced.
that are contemplating seeking Chinese approvals for telecom products
will face some distinctly Chinese obstacles. Distance, language,
an unfamiliar culture, and unsophisticated local commercial market
conditions can make entry into China both difficult and expensive.
A formidable maze of cultural idiosyncrasies, laws, and regulations
confronts any company embarking on this venture.
Chinese Ministry of Information Industry (MII) has been undergoing
the largest reforms in its history since its new minister, Mr. Wang
Xudong, recently took office. But back in 2002, months before Wang
was officially named to head MII, the China State Council formed
another organization called the Information Management Group (IMG),
which answers directly to the prime minister's office. One of the
major responsibilities of IMG is regulation of the Chinese telecom
industry, including the granting of telecom approvals. A central
focus of the telecommunications industry reforms taking place during
Wang's tenure as minister has been approvals. Major telecom carriers
have reorganized to meet the requirements of China's market economy.
article summarizes the new Chinese telecom approval rules along
with the national telecom reforms. The following major changes are
Telecom products are required to meet more-specific technical
Domestic Chinese and foreign telecom manufacturers are required
to meet the same requirements.
One system of MII certification is applicable to both foreign
and domestic companies.
Two MII registration offices have been combined into one office
handing all MII applications.
The lists of telecom products for MII certification have been
Six of 12 major MII-designated laboratories are under reorganization
to form two labs.
MII certification processes were revised during 2003.
New MII certification requirements were published with the MII
Network Access License
companies view approvals purely as an expensive hindrance to commerce,
but the reasons behind them can be justified. In reality, approvals
serve to prevent the supply of potentially dangerous and poor-quality
products into the marketplace. It is necessary to ensure that telecommunications
products operate correctly when connected to the national infrastructure,
and that they do not constitute a risk to the safe and proper operation
of the networks to which they are connected. China is no exception
to this rule. The importation and supply of unapproved or gray-market
products can lead to prosecution by authorities and forfeiture of
stipulates the telecom approval regulations, and the Telecommunications
Administration Bureau (TAB) under MII takes charge of telecom product
approvals granted in the form of a network access license (NAL).
Each type of approved product is issued a network access identifier
(NAI) with an MII certification number.
June 25, 2001, MII announced the first three categories of telecom
equipment, which cover a total of 28 types of products. All regulated
products must be MII approved before entering the Chinese market.
MII also assigned 10 laboratories to perform NAL testing. Each lab
focuses on certain types of products.
applicant for an NAL must be a legal entity located in mainland
China. The application package is submitted to the MII certification
center located in Beijing.
are generally four types of applications: those for renewal, regular
equipment, high-end equipment, and equipment modification. The NAL
application process varies depending on the type.1 The major difference
between an MII approval and European or FCC approvals is that MII
includes quality assurance in the approval process. Manufacturers
must have a satisfactory quality system in place. If a manufacturer
is not ISO 9000 certified, MII will audit the company's quality
system. From the MII point of view, the quality audit and technical
audit are equally important.2-6
NAL testing must be performed by one of the MII-assigned labs in
China. Testing may also be performed in the company's lab under
special arrangement. Such testing must be performed and reported
by an MII-assigned lab. MII does not accept any report not from
an MII-assigned lab.
of the Chinese standards are similar to International Telecommunication
Union standards but are written in Chinese. It is important that
the manufacturer discuss fully with the assigned test lab the scope
of the testing to be performed, the number of test samples required,
test specifications and procedures, and the cost of testing.
cost of testing is determined and charged by the test lab. Both
the amount of the fees and the payment method are negotiable. It
is highly recommended that manufacturers to employ an approvals
expert to discuss these issues with the testing lab on their behalf.
The MII approval center will itself charge fees to cover services
such as expert-panel appraisal and certification. Those fees vary
depending on the type of product. The whole process may take several
months to complete, but some straightforward cases can be handled
in as little as three weeks.
equipment under MII and NAL regulation must be affixed with an MII
approval sticker, which is the NAI. The NAI is produced by the MII
certification center and issued with an MII certification number.
The cost of an NAI sticker depends on the type of product, but typically
ranges from 0.50 RMB ($0.06) for terminal equipment to 4.00 RMB
($0.50) for routers.
NAL normally is valid for three years. It is important that manufacturers
apply for renewal of the NAL at least three months prior to its
expiration. If the renewal application is submitted after the NAL
has expired, the manufacturer must repeat the entire process.
has been subject to significant reforms since 2002. The China Compulsory
Certification (CCC) system is a prominent example.1 However, owing
to established historical precedent, reform of the Chinese telecom
approval system faced challenges from all interested organizations.
At one time, it was proposed that MII telecom approval be placed
under the control of the China National Administration of Certification
(CNCA), which administers CCC mark certification. This idea was
strongly challenged. It will be difficult, if not impossible, to
achieve this end in just a few years.
I. Approvals-related changes implemented by MII during 2003.
the same time, under pressure from major players in the industry,
MII initiated internal reforms designed to streamline its regulations
pertaining to telecom approvals (see Table I). The new rules were
officially published in August 2003. Their full implementation by
the end of 2003 anticipated the expected completion date of April
telecom certification centers and the MII-designated test laboratories
were subjected to reorganization as part of the reform of MII. Where
there had been two separate certification centers, under the organizational
reform they became one approval agency with both centers under a
single management. This change was completed on April 1, 2003.
addition, several MII-designated test laboratories have been amalgamated
into fewer labs. The major reorganization in this area was the creation
of the China Telecom Technology Labs and China WLLC Data Communication
Test Labs. Table II summarizes the consolidation of test and qualification
facilities under the new organization of MII.
II. MII testing and qualification facilities before and after
Requirements for MII Approvals
The major changes implemented in the new rules for winning MII approvals
are concentrated in the areas of testing, certification, and quality
testing requirements have become stricter than ever. The new rules
do not allow any of the provided samples to fail the test specifications,
which now are more clearly defined. If any test sample fails to
satisfy the major parameters, the manufacturer is required to submit
as many as twice the number of normally required test samples for
retesting one month later.
If any of the resubmitted samples fails, then a specially prescribed
sampling procedure is to be followed. It requires the manufacturer
to provide 20 sequential serial numbers for the equipment under
test. From these 20 available pieces of equipment the test lab then
randomly chooses two samples by number for retesting.
1.MII Network Access License application form (image 1 of 2,
click on the image above to enlarge it).
MII certification center no longer reviews product-related documentation.
Such documents as product descriptions, circuit diagrams, and so
on are now to be reviewed and approved by the test laboratories
before submission to MII for approval. The certification center
itself will focus exclusively on documentation relating to the manufacturer
or its contractor. More-detailed information about the manufacturer
is required than was the case before.
quality assurance requirements also are stricter. An original ISO
quality management certificate or a certified true copy of one is
required for verification. A contract between the manufacturer and
a subcontracting factory also must be provided.
no original or certified copy of the ISO certificate is provided,
MII will conduct factory auditing through its newly organized China
TTL Certification Center, which was previously the Post-Telecom
Quality Certification Center.
sample MII application form is shown in Figure 1. The documents
now required to be submitted are listed in Table
2. MII Network Access License application form (iamge 2 of 2,
click on the image above to enlarge it).
its entry into the WTO, China has become an open market that everybody
has a chance to penetrate. However, to gain access to the Chinese
marketplace, manufacturers must be prepared to negotiate a challenging
cultural, legal, and regulatory maze.
recent major reforms in MII's telecom approval process, including
new documentation requirements, have, unfortunately, not lowered
the bar for most telecom products that manufacturers want to get
into the market in China. There are exceptions worth mentioning.
Optical fiber has been deregulated, and optical cable is listed
as a voluntary certification product.
article has outlined the new rules for Chinese telecom approvals
and noted the MII reforms that took place during 2003. MII has reorganized
its testing, certification, and approval agencies. Test laboratories
are undergoing reorganization and merger in order to offer efficiencies
responsibilities of the MII test labs and certification center are
now more clearly defined, and new documents have been published
that more clearly explain requirements. New quality assurance and
monitoring systems are being set up.
Leslie Bai, "China: The Final Frontier in Telecom Approvals,"
Compliance Engineering 20, no. 3 (2003): 119-125.
Xindianhan (Telecom Regulations from MII): MII Number 125, 2001.
Xindianhan (Telecom Network Access License Management Accordance--Testing
Laboratories): MII Number 028, 2003.
Xindianhan (Telecom Network Access License Management Accordance--Certification
Procedures): MII Number 027, 2003.
Xindianhan (Telecom Products Monitoring and Management Regulations):
MII Number 189, 2003.
Xindianhan (Management of New Telecom Equipment for NAL Application):
MII Number 214, 2003.
Note: Xindianhan is translated as "Ministry of Information
Industry Announcement, Notification and Publication."
Leslie Bai, director of certification for and a founder of Siemic
Inc. (Fremont, CA) and Siemic (China) Certification Services Ltd.
(Zhong Guan Cun, China), has more than 15 years of experience in
global regulatory compliance. The Siemic facilities perform compliance
testing and certification, particularly for Asian approvals. Bai
can be reached at email@example.com.