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Over the past 10 years, MRAs have opened the market
to Small and Medium-Sized Enterprises (SMEs). Before the existence of
the U.S.-EU MRA, it was nearly impossible for a U.S. test laboratory
to operate across the Atlantic Ocean, providing local testing to the
manufacturers of products destined for Europe. In the EU, each country
had its own regulatory scheme and required national approvals and
in-country testing; the market was essentially closed to U.S. SMEs.
The individual country approvals presented a barrier to trade and a
high cost of entry to those markets. This has changed drastically, and
for the better. Today, in many countries, the maturation of regulatory
requirements for electronics devices has opened the door for market
access, increased transparency of regulations and continues to advance
free trade.
And not only have the MRAs improved access for SMEs,
but regulatory changes have been enacted inside markets. One example
has been the recognition of private Certification Authorities--which
has historically been the domain of federal governments. By opening up
the product certification to the private sector and its competitive
advantages, product development can proceed without undue delays
caused by government approval processes. These changes have spurred
product innovation. To illustrate, when the U.S. Federal
Communications Commission (FCC) began the Telecommunications
Certification Body (TCB) program in 2000, the number of FCC Grants of
Equipment Authorization issued was approximately 2500—all performed by
the FCC—with processing times on the order of one month or better. In
2006, well over 6000 Grants were issued, with 90% of them generated by
thirty or so private-sector “TCBs”. This means that introduction of
new products can occur at a much faster rate, the market can select
those technologies that will be effective, and the cycles of
technology development are greatly reduced. This leads to an
unleashing of creative power that drives product development. The MRAs
have the same effect: opening markets and inspiring innovation.
An important element of this process is to define
the system of conformity assessment of devices to ensure that products
entering markets are safe and effective. For electronics devices,
conformity assessment procedures need to be in place to protect the
radio frequency spectrum and ensure that electrical safety is
maintained. Regulators work to protect the interests of the consumer,
business and the government and, through the process of conformity
assessment, products can be evaluated to common criteria and meet the
requirements to be sold on the market. However, one of the challenges
is effective market surveillance. While private certification bodies
have the authority to issue FCC certifications or “grants,” they have
limited authority to rescind. In addition, enforcement actions are the
purvey of the regulatory authorities.
The role of the private certification body is
unique: the first (business) objective is to serve the needs of the
customer; the second (regulatory) objective is to observe and enact
the policy and procedures of the Regulator. Thus, the certification
body/conformity assessment process straddles the divide between the
marketplace and the regulator, a positioning that aids both parties.
Michael Violette
Founder and Director
American Telecommunications Certification Body, Inc.
(AmericanTCB) (http://www.atcb.com)
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Additional Information: Representatives from
AmericanTCB (ATCB) attended the April meeting of the PCC.I in
Buenos Aires and were invited to give a presentation on our
experiences as a Conformity Assessment Body (CAB) under the
U.S.-European Union Mutual Recognition Agreement (U.S.-EU MRA) and
the Asia Pacific Economic Cooperation Telecommunications MRA (APEC
Tel MRA). These Agreements allow a product to be tested and/or
certified by a government-designated CAB in one country to the
requirements of another country, and vice-versa. The CITEL MRA
provides an opportunity for OAS member states to implement similar
agreements.
This article summarizes our experiences on the effects of MRAs
on product certification, market access, innovation and conformity
assessment.
Michael Violette is Founder and Director of American
Telecommunications Certification Body, Inc. (AmericanTCB).
AmericanTCB (http://www.atcb.com)
provides Radio Frequency Approvals Services to International
Markets. Mr. Violette holds a BSEE from Virginia Tech and is a
Registered Professional Engineer in the Commonwealth of Virginia.
To contact him directly, email:
mikev@atcb.com. |
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