China's wireless certification really does cost more time and money

2022-10-19 original Engineering

This story may not be familiar to those who have never been involved in a product release, but it comes up often in the industry.

Products differ so much in whether disclosure is required that no blanket statement is possible. So here I’ll only explain why some people say such things.

I first noticed a certain unease while researching certifications for various countries during a product release. This was more than 10 years ago now. For wireless products, there’s a convenient certification scheme called “module certification.” Regarding the intentional and unintentional radiation mentioned earlier, the intentional radiation portion can be certified at the module level, and as long as the same module is used, re-certification isn’t required. Many countries, including Japan, have adopted this scheme. Wireless certification requires putting the wireless device into several special states (for example, radiating only a specific frequency at a specific power, or applying a specific modulation) and taking measurements, and most engineers at finished-product makers don’t know how to do this.

Module makers do know how, though, so if the module maker itself obtains module certification in advance, it becomes a huge help to the finished-product maker. This shortens certification times and lowers costs for wireless products. In short, you could call it a measure for activating the market. China has no such mechanism. Every maker must conduct wireless testing on the finished product there. That raises one hurdle. I remember prioritizing countries where module certification was possible, handling those first as a matter of course.

Regarding certification standards, many countries reference what is organized under the IEC. Some countries find it difficult to reference these, though, and organize their own national standards instead. In such cases, it’s often the case that “having a CE mark is sufficient.” It’s not “if you have a CE mark, you can sell it in our country too” but rather, in most cases, “hand over the various documents related to obtaining the CE mark, and then we’ll let you attach our country’s certification mark to it,” which is somewhat troublesome. But finishing with just a document review still helps makers a great deal, since it keeps the man-hours spent on certification down. Countries like Japan, the US, and South Korea are confident in their technical capabilities, can secure the resources to operate a certification body, and are motivated to protect the interests of their domestic manufacturing industry, so they create their own standards. China naturally falls into this category.

Starting from Japan, I gave top priority to North America and Europe, the major markets at the time, then prioritized obtaining certification in Asia, Oceania, South America, and other countries where CE results could be reused, and eventually arrived at China. A major unease arose while I was proceeding with the application in China, when I was asked to “provide all drawings and software.” In other countries, too, you’re sometimes asked to explain the parts related to wireless functionality. In such cases, it was customary to provide the schematic or block diagram of the analog front-end portion (the circuit that actually emits radio waves). But providing all schematics and software means something else entirely: it means a copy product could be made from that information. On top of that, the certification procedure was said to take 4 months at the time. (These days it’s a bit shorter.)

You still see it even recently, but it’s not at all rare for a product launched simultaneously worldwide to carry a note saying “*Note: sales in China undecided.” Apple, with its iPhone series, was the company that showed this attitude most blatantly for a while. The time and effort certification demands is naturally one reason, but I imagine the main reason was concern over the leakage of design information.

Looking at the tense state of US-China relations these days, though, I also understand there was a side to it where China, in order to avoid leakage of its own confidential information, had no choice but to become sensitive about selling other countries’ products domestically, especially when it comes to communication equipment.

China remains a promising market. But it hasn’t changed over the past 20 years: it remains a market that’s difficult to enter because of political complexity. I was also freshly shocked recently to learn that releasing an LTE product in China requires registration as a telecommunications carrier, which alone costs several million yen. (It’s always something like this.)

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Originally published in Japanese at https://clazytech.com/2022/10/1109/. Translated with LLM assistance and reviewed before publication.