As countries introduced measures for privatisation and liberalisation of markets, new authorities have been established to regulate the sector, including the control of the supply of terminal equipment. In the absence of a forum dedicated to harmonising standards and procedures throughout the whole region, manufacturers will be forced to follow the individual procedures in each country. It is hoped that the harmonisation work started within Mercosur will extend to involve all countries in the Americas.
As the countries of South America have introduced measures for privatisation and liberalisation of markets, new authorities have been established to regulate the sector, including the control of the supply of terminal equipment. In Europe, this process is generally referred to as terminal type approval. This relates to terminals being certified following the testing of one sample of the equipment, and then only identical 'type' equipment being placed onto the market. The level of regulation and maturity of the processes for type approval in South America vary greatly from country to country. This ranges from countries like Bolivia, where there is no formal approval regime in place at present, to countries like Argentina, Brazil and Chile which have their own national standards and certain requirements for in-country testing. In many countries, such as Ecuador, Peru and Venezuela, there are some national procedures, but they accept testing carried out in certain other countries as the basis for issuing a national approval. Until now there has been no effort made to harmonise standards or terminal approval procedures between countries. Nor have the approval procedures been based on those which exist in more developed regions such as the US or the European Union (EU). For this reason, it is necessary to follow the appropriate procedures for each country before equipment can be placed on the market. Argentina Equipment Requiring Approval The Comision Nacional de Comunicaciones (CNC) is the body responsible for approval of telecommunications terminal equipment and radio communications equipment in Argentina. All terminals covered by the scope of a technical standard issued by the Secretaria de Telecomunicaciones must be approved by CNC prior to being placed on the market. It is illegal to sell terminal equipment covered by the scope of a standard if it has not firstly been approved by CNC. Most radio equipment is also subject to third party approval. Even where there is no product specific standard, there is a generic test specification covering most types of radio equipment. The main standards for terminal equipment cover requirements for telephones, fax machines and PABXs. The telephone operators include type approval as a requirement for equipment procurement. In general, Telefonica and Telecom Argentina will' require additional testing to be performed prior to purchasing equipment. Telefonica has its own internal laboratory. Telecom Argentina does not have its own laboratory and generally goes out to tender for test services in cases where it requires additional equipment verification. If a manufacturer is unsure whether the equipment is covered by the scope of a standard, the appropriate action is to contact CNC prior to placing the equipment on the market. Equipment Not Requiring Approval Most digital terminal equipment does not require approval in Argentina. There are no standards in force at present for equipment connecting to digital leased lines or ISDN. In the case of the latter, there is no public service available at present. There are only point-to-point ISDN connections and private networks. Equipment connecting to these does not currently require approval. There are no standards for the approval of modems at present. There is no generic analogue network access specification, so until a specific standard is produced for modems, there are no approval requirements. The only exceptions are where the modem also offers fax or telephony, in which case the relevant standard for these functions applies. There are also no approval requirements for equipment connecting to private networks, with the exception of radio equipment. Approval is not required for equipment which is not intended for sale in Argentina. Therefore it is possible for equipment to be connected at trade shows or at a potential customer's premises for demonstration purposes. In these cases, however, it is still necessary to contact CNC and request permission for the temporary connection. No test results or official paperwork are required for this purpose. In the case of radio equipment, it is necessary to ask CNC which frequencies can be used. The Approval Process The approval process in Argentina is very bureaucratic when compared with the processes in most European countries. All documentation intended for submission to CNC must first be reviewed and endorsed by a technical representative who is a member of COPITEC. This is the professional body in Argentina which all telecommunications engineers must be members of in order to practise their trade. Every page of technical documentation submitted to CNC, including the user manual, must be signed and stamped by the technical representative. This must then additionally be endorsed by COPITEC. Then when the equipment is tested, the test engineer must also personally endorse each page. An application for approval can only be submitted by an Argentine company which will take responsibility for ensuring that only equipment which is identical to the type approved is placed on the market. The company should also be in a position to guarantee ongoing spares and maintenance support for the equipment. Approved equipment must be marked with the approval number issued by CNC. Equipment Testing Results of testing carried out in other countries are not acceptable to CNC. It is necessary to test against the Argentine standards at a laboratory which is recognised by CNC. At the moment there is only one recognised laboratory, which is located just outside the Federal Capital of Buenos Aires. CNC would like to see more national test laboratories. However, at present there is no real incentive to establish new laboratories, as the cost is too great in comparison to the likely returns. This situation may change if agreement is reached within Mercosur to accredit laboratories to test against the approval requirements of each of the Member States. The national laboratory has limited resources for testing. As a result, it may be necessary to send an engineer to the manufacturer's premises to witness testing for certain types of equipment. Inevitably, this can result in lengthy delays before equipment can be tested. Enforcement of Equipment Approvals CNC has limited resources for controlling the market to ensure that only approved equipment is being supplied. Network operators insist on equipment being approved as part of their procurement procedures. However, at the lower value end of the market there are many cheap, imported telephone sets available in the shops which are unapproved. At the moment CNC is looking for ways to educate users to try to reduce the number of unapproved terminals being purchased. Chile Equipment Requiring Approval Following privatisation of telecommunications networks in Chile, the Subsecretaria de Telecomunicaciones (Subtel), was established as the regulatory authority for the Chilean telecommunications sector. Subtel is responsible, amongst other things, for approval of telecommunications terminal equipment. In general, the only terminal equipment subject to approval by Subtel at present is equipment connecting to the analogue PSTN and radio equipment. However, network operators are likely to request evidence of compliance with international standards for digital equipment connecting to their networks. The operators are responsible for providing the public with lists of equipment approved to connect to their networks. Equipment Not Requiring Approval Equipment which is not covered by the scope of a Subtel standard is generally not subject to approval. There are no requirements for approval of equipment connecting to digital networks, digital leased lines or private networks. For analogue and radio equipment, if there is not a published standard for a particular type of product, it is usually advisable to check with Subtel whether or not they wish to approve it. If they do, they will then advise what testing they wish to have carried out. Approval is not required for equipment which is imported temporarily for the purpose of trade shows or demonstrations. The Approval Process The approval process in Chile is much simpler, and less bureaucratic than that in Argentina. There are no residency requirements for the approval holder, therefore the manufacturer can apply for approval directly, even if he does not have an office in Chile. All that is required to gain approval is a copy of a test report, against the relevant standard, issued by one of the five national accredited test laboratories. There are no application forms, and no requirements for any other technical documentation to accompany the test report. The report is submitted directly to Subtel by the test laboratory. Subtel relies on the test laboratory to review all of the relevant technical documentation prior to issuing the test report. Once approval has been granted, it is necessary to publish details of the approval in the Chilean Official Journal. It is the responsibility of the manufacturer or local distributor to arrange this. Details of the text which should appear are provided to the approval holder by Subtel at the time of approval. It is obligatory for these details to be published in the Official Journal prior to the equipment being placed on the market. There are no requirements for marking of approved equipment. An approval number is issued, but it is entirely at the discretion of the supplier whether this is marked on the equipment or not. Equipment testing Results of testing carried out in other countries are generally not accepted by Subtel. Out of the five accredited test laboratories, there are only two independent laboratories. Radio equipment testing is carried out by Subtel and terminal equipment testing is carried out by the Centro Nacional de Electronica y Telecomunicaciones (CENET). For certain types of radio equipment, it may be necessary for Subtel to witness testing at the manufacturer's premises. Enforcement of Equipment Approvals Subtel is not involved in controlling the market to ensure that equipment is approved. The responsibility for selecting approved equipment is left to the network operators and users. Subtel reports that they have not received any complaints from network operators that unapproved equipment is causing problems, therefore they are happy to continue to let the market regulate itself. The Future Although there are currently no moves at a pan-American level to harmonise terminal equipment standards and approval procedures, there is work being conducted within Mercosur. The authorities in Brazil, Argentina, Paraguay and Uruguay are working to create a regime where there would be mutual recognition of test results between these countries. Eventually they hope to move to a system of mutual recognition of type approvals issued in each of the Member States, similar to the one-stop approval regime operating in Europe. This is likely to take about 5 years to achieve. Conclusions The number of South American countries which require terminals to be approved before being placed on the market is increasing. The procedures detailed above for Argentina and Chile demonstrate just two of the different approaches to terminal type approval in the region. In the absence of a forum dedicated to harmonising standards and procedures throughout the whole region, manufacturers will be forced to follow the individual procedures in each country. It is hoped that the harmonisation work which has been started within Mercosur will eventually extend to involve all countries in the Americas.