The Telecommunications Industry Association (TIA) recently wrote a letter to the Office of the U.S. Trade Representative to comment on the 2011 National Trade Estimate (NTE) on Foreign Trade Barriers report.  The letter focused mostly on testing and certification barriers in three countries: China, Mexico, and Brazil.  Following are highlights of the letter. 

The product testing and certification process in China is significantly more burdensome than in other markets, according to TIA.  Under China’s Network Access License (NAL), there are unnecessary testing requirements.  TIA recommends eliminating the NAL requirement, or reducing the number of tests required by the NAL.  Particularly, eliminate mandatory testing for specific enhancement functions such as WAPI, and eliminate functionality testing.

Also, TIA says that China’s certification requirements for telecommunications equipment conflicts with its WTO obligation to limit imported products to no more than one conformity assessment scheme and requiring the same mark for all products (Article 13.4(a)).  China has three different licensing regimes:

  • Radio Type Approval (RTA)
  • Network Access License (NAL)
  • China Compulsory Certification (CCC)

It can cost $35,000 to test for all three licenses.

For EMC testing, China has opted out of the IECEE Conformity Body (CB) scheme for report acceptance, so that this testing must be done in-country.

China’s policy of requiring a factory inspection before issuance of the CCC certificate has meant long delays for some U.S. manufacturers.

Regarding standards, TIA believes that China should accept all globally-relevant standards that are developed in accordance with the TBT Code of Good Practice, not just those developed in international forums like the ISO, IEC, and ITU.

Mexico is working on a conformity assessment procedure for telecommunications products where testing would be mandatory and performed only by recognized labs.  According to TIA, this reinforces the need for Mexico to recognize U.S. and Canadian accreditation and certification bodies to avoid duplicate testing.  TIA urges Mexico to implement Chapter 9 of its NAFTA obligation to recognize conformity assessment bodies in the United States and Canada.

TIA is concerned that Brazilian regulator Anatel is not accepting test data generated outside of Brazil, except in rare cases.  This requirement that testing be done in-country adds to certification time and increases costs.  TIA recommends that the United States and Brazil negotiate a Mutual Recognition Agreement under the CITEL framework.

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