Can an Embedded Modem
obtain Global Telecom Certification?
Floyd Kling
(2/28/06)
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.
http://www.fcc.gov/wcb/iatd/part68faqs.pdf
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 |
Austria |
Bulgaria |
Albania |
Belgium |
Croatia |
Andorra |
Cyprus |
Romania |
Belarus |
Czech Republic |
Turkey |
Bosnia-Herzegovina |
Denmark |
|
Yugoslavia(former) |
Estonia |
|
Iceland |
Finland |
|
Liechtenstein |
France |
|
Moldova |
Germany |
|
Monaco |
Greece |
|
Norway |
Hungary |
|
Russia |
Ireland |
|
San Marino |
Italy |
|
Serbia and Montenegro |
Latvia |
|
Switzerland |
Lithuania |
|
Ukraine |
Luxembourg |
|
Vatican City |
Malta |
|
|
Netherlands |
|
|
Poland |
|
|
Portugal |
|
|
Slovakia |
|
|
Slovenia |
|
|
Spain |
|
|
Sweden |
|
|
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
julia.luke@ccsemc.com
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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