Customers frequently ask me whether or not it is necessary for Otto Wireless Solutions, as the distributor of wireless products, to apply for and receive ICASA approval specifically for wireless modules, prior to selling them.
There are a lot of common misperceptions in the electronics design industry concerning this subject. Increasingly, I have heard this line from customers: “But I thought you (the supplier, Otto Wireless) don’t need to have ICASA approval on the modules, because I have to get ICASA approval on my finished product anyway.”
So is this true? Does this statement hold water? Could we as Otto Wireless Solutions be wasting time and money by diligently acquiring ICASA approval for every product we sell?
Prior to looking for an official response, let me perhaps make our position clear: as a company, it is not only about ICASA. We strive to provide high-quality products to our customers, who can make use of any product we sell to them with absolute peace of mind, because what we have supplied is not only type approved, but has the local backing and technical expertise of a responsible company, invests in local testing and approval, and employs staff capable of providing technical support. When customers come to Otto Wireless Solutions, they know exactly what they are paying for, and accordingly, over time we earn the trust of our clients.
What does the law say about this? ICASA stands for Independent Communications Authority of South Africa. It is a regulatory body set up to regulate and enforce the Communications Act. Therefore, if one is uncertain, one can consult the Communications Act of 1996, which can be downloaded from various government websites.
The Act itself was set up with a number of specific agendas in mind, one of which was to make provision for the regulation of telecommunication activities other than broadcasting, and for the control of the radio frequency spectrum. Any supplier or customer who finds themselves unsure of whether or not they have an obligation to acquire ICASA approval, can simply download the Act, and review the opening clause of chapter VI, section 56 (1) which states: No person shall supply telecommunication facilities or equipment unless, subject to subsection (2), he or she has been registered by the Authority.
The definition of ‘equipment’ may, at the outset, seem somewhat vague, but if one consults section 54, it explains that the Authority may prescribe what ‘equipment’ entails. In summary, the need to ensure that GSM, LoRA, Wi-Fi and other RF modules which we sell are ICASA approved, is prescribed by law.
Once I explain the above to customers, they then sometimes fall back on argument number two, and this question is: “But if you as Otto Wireless Solutions have ICASA approval on device XYZ, then the product is approved and I can purchase from any supplier.”
This is also a misperception. The Act mentioned above is clear that it is both the certificate holder and the equipment which are ICASA approved. Secondly, the ICASA approval certificate lists the company name on the certificate, ensuring that both the device and the certificate holder are approved.
Lastly, the ICASA type approval certificate itself is doubled sided, and on the back it spells out the standard conditions, which oblige the holder of the type approval to notify ICASA of changes to the product, but also makes it clear that the certification itself is not transferable (see clause 1.5): This type approval certificate is not transferable and the holder shall not transfer it to any other person or entity, nor surrender it in any way in favour of another, except with the written approval of ICASA.
It is very clear that an ICASA type approval is valid only when purchasing from the certificate holder.
Which brings me to the underlying concern which some customers have expressed: does this mean that when we supply our ICASA approved (for example) LoRa module to a customer, and they design it into their application, is our ICASA approval null and void? Of course the device itself remains approved, but this approval does not ‘carry forward’ to include the customer’s final product.
Once the customer has taken a product and used it in their application, it is the customer’s responsibility to have their final product ICASA approved. This is necessary because a client may have, for example, inadvertently amplified the device’s performance, or their product may, in some other ways, be operating outside of safety specifications. This makes it necessary for clients to have their final products approved, regardless of whether or not they have decided to purchase an ICASA approved module.
So there is a benefit in purchasing ICASA approved modules. The benefit is in knowing one has purchased a product which is operating within ICASA’s type approval limitations. When submitting a final product for testing, which integrates the approved module into a design, the ICASA approval of the module can be put on the table, often mitigating the level of testing which needs to be carried out, and subsequently reducing the cost of product approval tests. If the final product is found to be failing EMC emissions, the module itself can be excluded as a potential cause of noise, because it operates within known and acceptable emission parameters.
In conclusion, when selecting a wireless module, purchasing an ICASA approved device or module from the approved supplier is critical. Not only does this start the design off with peace of mind, but in the long run it can very well save you valuable time and money.
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