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Can an Embedded Modem obtain Global Telecom Certification?

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Floyd Kling 


You have a product that allows the exchange of data/fax and maybe voice via an Embedded Modem.  The Embedded Modem can dial out and/or answer incoming calls.  You have proven it works maybe even shipped it around the USA and Canada. 

Now you’re ready to send it international and literally ‘set the world on fire’ with this wonderful product.

You’re told (or strongly implied) by your Embedded Modem manufacturer that their modems have a certification number for each country.  All you need to do is insert their modem into your box, display that certificate number and you are now certified by that country to plug into that Country’s PSTN. (Public Switched Telephone Network)

Hey, this is great stuff, is this really true?…

Before we go further, let’s define an ‘Embedded Modem’.

This paper refers to Embedded Modem Modules that attaches to your mother board via a pin receptacle or soldering.  The Embedded Modem Module may be inserted at the time of manufacture, installed or replaced in the field and may (but not necessarily) be user installable. 

Embedded Modem Modules cannot operate by themselves.  Embedded Modem Modules do not have their own power supply, they rely on power supplied by the mother board or host system.  Embedded Modem Modules are not ‘Stand-Alone’, ‘desktop’ or ‘rack mount’ modems that we are familiar with.  Embedded Modem Modules are buried inside your product that you cannot physically access when they are properly installed inside your product (box).

 Embedded Modem Modules are different than the type of internal modems that are specifically designed for PC based architectures such as ISA, PCI, PC/104 or PCMCIA…etc.

You’re running a serious risk assuming an embedded modem is Globally Certified unless you know with absolute certainty you are Telecom certified for each country.

Here’s why:

Regarding Embedded Modems and Telecom Certification, you can divide the world into 3 basic regions. (Yes, this may be over simplified, but initially you will very likely market primarily in the larger countries and less time on smaller countries that may have technical exceptions to this paper.)

  • USA and Canada

  • EU (European Union)

  • The rest of the world

 USA and Canada

We’re sort of spoiled here in North America because the FCC (Federal Communications Commission) and DOC (Department of Communications, Canada) allows for Embedded Modems to be tested and certified for integration into your system and you’re good to go.

Note:   The FCC Pt. 68 rules that govern the attachment of equipment to the PSTN has transferred authority to ACTA (Administrative Council for Terminal Attachments) – attachment rules are basically the same however.

Indeed some countries outside the US and Canada may even allow you to use these FCC/DOC Certifications to allow connections to their PSTN’s

European Union (EU)

The EU recently began acceptance of CTR-21/TBR-21 testing and EC certification as the accepted compliances to attach Embedded Modems to their telephone networks.  In that regard, the EU is similar (but not exactly the same) to the US and Canada) 

Here is a list of the countries that comprise the EU and accept CTR-21/TBR-21 and CE Certifications for Embedded Modem Modules into their countries PSTN:

European Union member states and associated countries:

European Union Members

Applicant States

Other European States










Czech Republic


























San Marino



Serbia and Montenegro









Vatican City

























United Kingdom






The above EU Members honor the CTR/TBR-21/CE certifications for Embedded Modems.  The ‘Applicant States’ and ‘Other States’, while not wholly a member of the EU, for the most part follow the same recommended approval processes.

If your Embedded Modem manufacturer supplied you with the CTR-21 and CE compliance reports and performed and documented due diligence for safety, and EMI/RFI, and your box is appropriately labeled, you are probably “good to go” and legally attach the modem to the PSTN of these EU Countries.

IMPORTANT: Your final product (with modem inside) is still subject to its own CE / EMI and perhaps other testing which is not related to the modem.  You could need these other certifications even without a modem.

Outside the EU, USA and Canada, Embedded Modem Telco Certifications are “dicey” at best.

Be careful here.  Other regions and countries around the world MAY NOT, and probably DO NOT, allow or accept ‘Universal Global Certification’.  They may require country by country testing of YOUR PRODUCT WITH THE EMBEDDED MODEM INSTALLED.

Regions that are not generally easy to attach to their PSTN’s

·          Central and South America.

·          European countries outside of the EU

·          Africa

·          Pacific Rim including Australia and New Zealand

You may say, “Hey, my Embedded Modem manufacturer states that they have the Global Certification numbers for many of these and other countries which they are implying are legal numbers for me to use on my product”.

Let’s look at this…

The Embedded Modem manufacturers that make this claim are pushing the envelope with the legality of their claim of Global Modem certifications for these individual Countries certification processes.

To obtain a certification number, they may have inserted their Embedded Modem, into a box specially designed for testing and demonstrating functionality of the modem.  They basically have turned the Embedded Modem into a Stand-Alone, or Box-Modem.  They add a power supply, maybe add LEDs and maybe a speaker. 

Inside that testing box, their Embedded Modem is now a Stand-Alone Modem specific to that particular box, power supply and associated features

That test box, with the Embedded Modem inside, is then submitted to the country’s local certification agency.  That agency will perform all the required tests and “Shazam!”, this (test box) is “certified” and here is the number.

The problem is, that Certificate number is unique to the TEST BOX in its entirety… (with the Embedded Modem inside). The Certification number is not intended to be for the Embedded Modem component itself allowing the Embedded Modem to be universally installed in other products, unless specifically stated otherwise on the Certification.

Carefully read the Modem Manufacturers Certification claims

Many countries regard the Embedded Modem as a component.  As a component, it cannot function without the “box” it goes into. Therefore the MODEM + HOST BOX is considered a single product.  Outside of the USA, Canada and EU, most country’s do not recognize or offer Global Telco Certification to a “component” … i.e. an Embedded Modem.  

Look at it this way:  If you have the standard Stand-Alone “box” modem that has all of the certification and agency approvals, do you think these agency’s would allow you to remove the PCB assembly and put it into a different (non approved) enclosures and power supply’s?  That modem was approved as a whole device with the power supply, LED’s speaker and enclosure.  The only way it can operate is inside the original submitted assembly that supplied the power and controls it was certified with.

The Embedded Modem manufacturer may give you that number and tell you that number is the certification for that country, but BEWARE!

What is the liability of shipping my product into a country with an Embedded Modem with questionable Certification?

Here is the analogy:  It is like driving a car in a country without a license or perhaps using someone else’s driver’s license <numbers>.  As long as nothing terrible happens you may go unnoticed.  But, if there is a problem… perhaps a Telco employee is called for a telephone line problem and finds this (your) product with an invalid modem inside or if for some reason it is discovered that your product is using an invalid certification number… you could be penalized.  You may be required to retrieve 100% of your products that are in violation, fined for each violating product AND the government may go so far as to stop all of your future products from entering the country at customs.

Countries are spending a significant amount of money at their POE’s (Ports of Entry) to stop violations.  Penalties can be severe.

Why take that chance?  Sure it costs money to do it properly, but in doing it properly you will be assured you are legal to bring your product into these various countries.

How can I be sure an Embedded Modem is truly certified for that country?

For the USA, Canada and EU the Embedded Modem manufacturer can easily supply you with the Government Stamped FCC Certificate, or DOC certificate or the CTR-21/TBR-21 testing compliances.

Ask the modem manufacturer for the Governments Official Certificate!

More controversial and difficult are the rest of the countries around the world.  If the Embedded Modem manufacturer claims <or implies> they have Government Certified Telecom Compliance Certification for a particular country, simply ask the Modem Manufacturer for a (.pdf) copy of the Compliance Certificate. 

Ensure this document is not the modem manufacturers’ testing certification on their company letterhead, but make sure the Compliance Certificate is THE OFFICIAL GOVERNMENT DOCUMENT that clearly indicates;

·          Statement of Governmental Compliance

·          The countries Government Stamp

·          The Embedded modem part number(s)

How do I get my product with an Embedded Modem certified in these countries?

You will need to submit your product with the selected Embedded Modem inside to each country of interest.  You may proxy a qualified testing agency on your behalf of which are many.  Some countries, require the submission must be done via a local <in country> entity or representative.  Some countries, usually the smaller ones, will accept other (larger) countries certifications.  For instance, New Zealand may accept Australia AUSTEL certification approval.  (Australia recently transferred authority to ACMA (Australian Communications Media Authority).

Contact your qualified certification laboratory that specializes in country by country homologation of Dial-up <embedded> modems for International Applications.

Certification Labs:

Compliance Certification Services (CCS)

561F Monterey Road

Morgan Hill, CA  95037-9001

United States

Julia Luke

408 463 0885 Ext. 112

408 463 0888 Fax



Patton & Associates, Inc.
82 Wildwood Drive
Prescott, Arizona 86305-5093
United States

Dave Patton

Tel: 928.771.2900
Fax: 928.771.2990
Mobile: 928 899 6699
Toll Free USA 1.877.311.8735

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Questions or comments?  

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