TIA Proposals for Electronic
Labeling Programs
TCBC Workshop – Baltimore, MD
Apr. 10, 2014
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Agenda
 Introductions
 Background on TIA & Overview of TIA’s Technical
Regulatory Policy Committee (TRPC)
 Electronic Labeling
 Background on TIA’s Request for the Non-Exclusive
Allowance for eLabeling
 FCC Authority to Pursue an eLabeling Pilot Program
 Proposal to Industry Canada for eLabeling Allowance
 The eLabel
 Information for Customs Agents
 Questions?
 Adjournment
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About TIA
• Washington, DC-based trade association for
global information and communications
technology (ICT) manufacturers, vendors, and
suppliers, providing value to industry members
through policy advocacy, standards development,
networking, etc. – please visit
http://tiaonline.org/
• American National Standards (ANSI) accredited
standards development organization
• TIA 2014 Network of the Future Conference:
(http://www.tia2014.org/)
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About TIA
• Key areas of policy advocacy:
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Trade and market access
Disability access to ICT
Broadband convergence (deployment policies, IP transition, etc.)
Cybersecurity and supply chain integrity
Energy and environment
Health ICT
Intelligent transportation systems
Standards & IPR
Device approval
Spectrum allocations
Public safety issues
• Please visit http://tiaonline.org/policy
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Background on TIA’s Request for the NonExclusive Allowance for eLabeling
 Consideration of eLabeling in other
administrations is already at various stages:
 Allowances in Australia, Japan, & the United
Arab Emirates.
 EU Parliament considering the inclusion of an
electronic labeling allowance in its revision of
the radio and telecommunication terminal
attachment equipment (R&TTE) Directive
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Background on TIA’s Request for the NonExclusive Allowance for eLabeling
 In August 2012, TIA formally petitioned the FCC to
allow for the non-exclusive option of electronic
labeling.
 We believe that this option would ease technical
and logistical burdens on manufacturers while
increasing end user access to useful information
about their devices.
 The item was later put on Public Notice, and saw
no opposing comments. It has not yet been
assigned a docket number.
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Background on TIA’s Request for the NonExclusive Allowance for eLabeling
 This request was not addressed under the broader
FCC docket for device approval process reform,
although the TIA introduced it in its comments.
 TIA believes that the FCC should move forward as
quickly as possible to address the requested nonexclusive allowance of eLabeling in the United
States.
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FCC Authority to Allow for eLabeling
 The Commission has established an authorization program to
ensure that equipment reaching the market complies with the
technical requirements, which includes device labeling. 47 C.F.R.
§ 2.925.
 Subsection (d) of section 2.925 states: “[T]he nameplate or label shall be
permanently affixed to the equipment and shall be readily visible to the
purchaser at the time of purchase.”
 The Commission allows for electronic labeling on software
defined radios as long as the radio is “equipped with a means
such as a user display screen to display the FCC identification
number normally contained in the nameplate or label.” 47 C.F.R.
§ 2.925(e).
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FCC Authority to Allow eLabeling cont’d
 The Commission has already initiated rulemakings for
reducing burdens of the equipment authorization program
on manufacturers, and has stated that such reforms
“greatly benefit both large and small manufacturers and
encourage the development of innovative products that
best meet consumer’s needs.” See, e.g., Notice of Proposed
Rulemaking in ET Docket 97-94, 12 FCC Rcd 8743 at ¶ 1
(1997).
 Electronic labeling has already been allowed for:
 Software defined radios. See 47 C.F.R. § 2.925(e).
 Modular transmitters, where the Commission stated that it made this
allowance to “provide additional flexibility to manufacturers.” See 47 C.F.R.
§ 15.212(a)(1)(vi); see also Second Report and Order, 22 FCC Rcd 8028, at
¶ 12 (2007).
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FCC Authority to Allow eLabeling cont’d
 The Commission also allows for an “alternative
method of identification” for when a “permanently
affixed nameplate is not desirable or feasible,”
which demonstrates they already contemplated a
time when physical labeling would become
obsolete. See 47 C.F.R. § 2.925(f).
 Relying on § 2.925(f), TIA has also requested that the
Commission consider authorization for eLabeling under
the KDB process, while the formal rulemaking is
pending.
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Proposal to Industry Canada for
eLabeling Allowance
• TIA has also requested that Industry Canada (IC) to ease
technical and logistical burdens on manufacturers while
increasing end user access to useful information about their
devices by allowing for the non-exclusive option of
eLabeling of RF-emitting and terminal ICT as soon as
possible.
• TIA has urged IC to include this allowance in its forthcoming
draft Issue 10 of RSP-100 — Radio Equipment Certification
Procedure, in 2014.
• TIA working with RABC stakeholders.
• IC intent to approve and publish associated documents,
including a CB Notice, by Oct 2014.
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The eLabel
 TIA suggests that the eLabel consist of:
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The regulatory ID
The regulatory logo (if applicable)
The product model number
Attestation of Part 15 compliance, if applicable (47
C.F.R. § 15.19)
 Any other required information provided on the surface
of the product
 Note: many companies may choose to provide
more than the minimum threshold of information
in an eLabel to further benefit the consumer.
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The eLabel cont’d
 3GPP has recently completed a revision of standard interfaces
which provide a means of displaying electronic labels:
 6.9 Presentation of e-marking
“The ME may display the electronic marking (e-marking). If the ME
supports the e-marking and if the ME supports Physical user input features
(see section 5), the following procedure shall instruct the ME to display its
e-marking: The procedure shall be accepted and performed with and
without an inserted SIM/USIM. The e-marking may include, at the option
of the manufacturer, regulatory-mandated marking information,
regulatory restrictions of use if required and other relevant marking
information. The regulatory marking should follow the format given by the
regulation(s).”
 TIA proposes that the Commission’s allowance put forward the
3GPP effort as one means of providing required labeling
information.
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Information for Customs Agents
 For each unit of imported equipment that incorporates an
eLabel in lieu of a physical label, manufacturers may attach
on the screen of each unit a transparent, removable sticker
that contains the contents of an eLabel described above.
 TIA supports putting needed information on packaging
labels that includes required regulatory markings and other
important information including proper device care,
electronic recycling programs, and warranties.
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How Does eLabeling Help the TCBs?
 Eased testing process
 Easily address typographical errors
which sometimes appear on hard copy
labels
 Eased access to device information
 Eased post-market surveillance
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Questions?
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Thank You!
Brian Scarpelli
Sr. Manager, Government Affairs
Telecommunications Industry Association (TIA)
d: 703.907.7714 | m: 517.507.1446
BScarpelli@tiaonline.org | tiaonline.org
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