Homologating Japan

By John Savageau

Without a freely accessible and reliable means of telecommunications, our business and social lives would be vastly different. Try to imagine a busy office forced to go for a day, or even for an hour, without a telephone or fax. Dependable phone service i s something we in Japan take for granted, both in the office and at home. Rarely do we give a thought to how telephone companies are able to provide this essential core service, or to all the rules and regulations needed to keep the service going.

Building and maintaining a reliable telecommunications infrastructure represents a huge investment--not only for the telephone company, but for local and national governments as well. To help ensure that this investment is protected, Japan, like most oth er OECD countries, has laws requiring the certification of all devices that connect to the telephone network. Such devices include telephones, fax machines, and computer modems.

The process of certifying communications equipment is known in the industry as "homologation." In this article, we'll look at the reasons homologation is needed, the process for homologating terminal equipment, and the way you can identify whether your c ommunications equipment is properly certified. The need for homologation

The Government of Japan recognizes the benefits of allowing the private sector the freedom to be creative with new telecommunications ideas and products. Dozens, if not hundreds, of new products are currently being researched and marketed, with an amazing array of features and capabilities. The government wants to encourage the development of new and more powerful communications devices from domestic vendors, and it seeks to allow foreign-made equipment to be used as part of the national goal to continue growing economically strong through the use of enabling communications concepts. But the government also demands that this new equipment in no way disrupt or damage components of the telecommunications network. All communications terminal devices and syst ems eventually have to connect to public or private telecommunications networks, and so they all need to be homologated.

NTT, like all national exchange carriers, operates central switching offices. These offices accommodate the needs of both residential and commercial telecommunications users. The wires that terminate at your home or business are physically connected at s ome point to a nearby NTT Central Office (GO). With a standard telephone, when you pick up the handset, you are actually completing an electric circuit path to the CO. (A key system or PBX operates a bit differently.) The CO switch recognizes your telepho ne being "off-hook" by returning a dial tone to your telephone.

The important point is that, in this process, physical energy is traveling along the wires between your telephone and the NTT CO. Because telephone switches are sensitive pieces of equipment, sending a wrong signal or energy level could conceivably damag e the switch, subsequently interrupting communications services for all other users connected to that switch.

It is homologation and subsequent conformance of communication terminal devices to local regulations that help to ensure this does not happen. Before it can be legally connected, any new telephone, modem, or facsimile must meet the safe-connection techni cal requirements of NTT and the other communications carriers.

Certification standards

In Japan, the Ministry of Posts and Telecommunications has designated the Japan Approvals Institute for Telecommunications Equipment (JATE) as the homologation certification-approval agency. JATE processes the requirements set by Type I carriers (such as N TT, Japan Telecom, KDD, IDC, and Teleway Japan) and makes the resulting regulations available to communications device manufacturers so that terminal device vendors can then design their products to comply. JATE also informs foreign manufacturers of the s tandards for certification in Japan for the eventual import of equipment into this country.

JATE bases the certification requirements on the following principles, which are set forth in its "Procedures for Technical Conditions and Requirements Compliance Approval":

· Telecommunications circuits shall not be damaged or impaired, nor shall functions thereof be impaired.
· Nuisance shall not be caused to other users of the telecommunications cir- cuit facilities.
· The demarcation of responsibility between the telecommunications cir cuit facilities established by a Type I telecommunications carrier and terminal facilities connected to them shall be clearly clarified.

Problems of the redial standard Generally, the technical specifications for certification are logical and represent no major design difficulty. Minor differences, however, can make homologation a confusing and frustrating experience for foreign manufactur ers. One example is the rules for the "redial" feature that is now common on most modems and facsimile machines. Although this function is normally controlled via supporting software or firmware, compliance of the equipment with Japanese standards must be proven prior to certification.

Until about 1980, Japan's telecommunications infrastructure would have been best described as "marginal" (at least in comparison with today's modern system). The switching equipment was poor and of low capacity, and telephone saturation was a very small percentage of the total population. At the same time, though, terminal equipment such as telephones were getting more and more sophisticated.

One feature that quickly gained popularity was the speed dialer with a redial function. When users did not have the time or patience to wait to call a busy number again later, they would "camp on" the desired number; that is, the telephone device would c ontinuously redial the number until it was free. The problem was that, since both phone lines and switch capacity were limited, these autoredial devices could create a condition in which the constant "off-hook" dial requests might overload the capabilitie s of the local CO switch.

To remedy this problem, NTT redesigned its phone equipment with a longer delay time between redial attempts. (At that time, only NTT-produced telephones could legally be connected to the telephone system.) This relieved some of the pressure on the CO swi tches, and it soon became the accepted certification standard. Although NTT has since replaced most of its CO switches with modern, high-capacity digital exchanges, the old law remains on the books and still must be complied with. This creates problems fo r many foreign vendors whose terminal equipment supports rapid redial.

The redial limitation is just one of many certification requirements that are now outdated and irrelevant given the advances in telecommunications equipment technology. But NTT is notoriously slow in moving on such points, and making "unnecessary" change s to long-established regulations is not a high priority.

The homologation process

There are alternative methods of homologating terminal equipment. A vendor can simply design its system in accordance with JATE specifications, then submit that design for approval. The design must show evidence of testing, and the actual test results mus t fall within the specific parameters allowed by JATE.

Another method is to use a certified testing laboratory (such as Chemitox in Yamanashi-ken) to certify the equipment and submit testing results to JATE in the vendor's name. This method is popular among foreigI1 telecommunications companies who sell in m any different countries. Since each country requiring homologation has different certification requirements, it is often easier to use a third party that is already experienced in local homologation to assist in both the testing and certification process.

In comparison with other countries, JATE specifications are relatively rigid. The requirements for terminal equipment vary according to the category for each type of device. For example, prior to receiving certification, a vendor homologating a modem mus t satisfy performance parameters in such areas as functions (e.g, error-checking, sending time, and equalization), circuit or program design, and even dimensions and casing material. In addition to these technical specifications, applications for JATE app roval must also include a series of supporting documents, such as equipment descriptions, circuit and block diagrams, manuals, and complete documentation on quality control (ISO 9000 certification, etc.).

Once the certification application has been submitted, JATE assigns an examiner to the case. The examiner uses the supporting documentation as evidence to determine whether certification is justified. If the examiner determines that physical inspection o f the equipment is needed prior to granting certification, the vendor may be required to supply a specimen of the actual device.

The interval between submitting a request to JATE for approval and being notified of a decision on certification is normally within 60 days. Only after this approval is received can a vendor legally sell the equipment for use on public and private teleco mmunications networks.

You can easily tell if a terminal device has passed homologation by checking for the JATE seal of approval (see figure) attached to the casing of the equipment. For those who read such things, the terminal device is also announced publicly in the JATE Jo urnal, a periodic collection of current certified terminal devices.

Staying legal

In many offices and homes here in Japan, you will find foreign-made fax machines, computer modems, fax/modems, telephones, and other communications devices attached to the phone lines. The fact is, however, that very few of these are actually homologated for use in Japan-in other words, the connection is illegal. If the telephone company were able to prove that your device had interfered with public/private communications or had disrupted or damaged its switching or transmission facilities, you or your co mpany would be liable for any associated claims and charges.

Likewise, Japanese-manufactured and domestically homologated terminal devices and telephones are rarely compatible with foreign standards. In many cases, they may not even function on a foreign communications network. This obviously is an obstacle for im plementers of global solutions, where everything has to be compatible.

On a personal level, ensuring certification with domestic requirements prior to buying or installing terminal equipment for your home or office can avoid potential problems--whether mechanical or legal. With the cheaper prices of equipment overseas and t he ease of mail-order buying, however, attempts to ensure homologation of telecommunications devices may prove to be a losing battle.

For further information on homologating commun ications terminal equipment, contact JATE at the address below.

John Savageau is Regional Services Manager, Asia Pacific Operations, of Sprint Japan Inc.

Japan Approvals Standard for Telecommunications Equipment (JATE) Isomura Building, 1-1-3 Toranomon Minato-Ku,
Tokyo 105, Japan
Tel: 03-3591-4300