TIA Efforts Bear Significant Progress Towards the Use of Electronic Labeling
A long-held priority for TIA has been streamlining and globally harmonizing equipment authorizations because American consumers benefit greatly from the competitive nature of the global ICT equipment market. TIA aims to promote process improvements that will decrease both the cost and time‐to‐market for equipment manufacturers, ultimately benefiting the end‐user with quicker access to devices at lower costs. Reduction in the amount of resources that need to be spent to get a product to market directly translate to improved competition in pricing of the information and communications technology (ICT) equipment that hundreds of millions of Americans use in their everyday lives, whether as consumers or through work.
The ICT market presents unique challenges to ensuring governments, consumers, and other stakeholders to readily determine whether a device has been properly certified, and for ensuring that consumers be able to obtain additional information about a device as efficiently as possible. Historically, the use of physical markings or labels have played a key role in providing this important information, but the continuous evolution of industrial design (e.g. smaller smartphones) and multiple regulatory environments has led to increased costs and difficulty in ensuring all relevant markings or labels are affixed in an efficient and convenient manner for the user of the device. The consensus view of the ICT manufacturer community is that an effective solution to this problem is the non-exclusive use of electronic labeling for RF-emitting and terminal ICT equipment, which allows consumers and other users access to easily readable and prominently displayed information about each device.
That is why TIA has been the champion for the allowance of electronic labeling globally. In 2012, TIA submitted a petition for rulemaking to the FCC requesting the allowance of electronic labeling (read our petition here). Because we’ve long argued that the FCC has the ability to allow for eLabeling under its existing statutory authority, we separately submitted a formal request that the FCC undertake that analysis (see our request here). We also urged the FCC to consider this allowance in light of Chairman Wheeler’s process reform effort (see our comments here). Even further, TIA has advocated for an eLabeling allowance to Canadian, European and Chinese regulators, among others. In short, eLabeling is a priority for the ICT manufacturing community!
This advocacy has not occurred in a vacuum. All along the way, TIA has been partnered with the FCC (and other regulators internationally) in crafting a path forward for the eLabeling allowance.
Most recently, as a result of this collaborative work, on July 11, 2014, the FCC issued a guidance document for all devices with integrated screens, such as smartphones and tablets (available here). Labeling represents a modest portion of the overall costs of manufacturing a device with integrated screens, estimated at or below 1%, or roughly 8 cents, of the average $8-$8.50 it costs to manufacture a smartphone or similar device. However, when this is multiplied by the over one billion devices manufactured per year, eLabeling would result in over $80 million in savings per year for companies. Combined with new efficiencies to the supply chain process, eLabeling translates to more competitive pricing options for hundreds of millions of consumers.
This guidance is the result of years of constructive efforts between TIA and the FCC, beginning in 2012 when TIA petitioned the Commission to allow for the optional use of eLabeling for ICT equipment manufacturers. We commend the Commission for their inclusive approach to working with the industry to advance the public interest through this guidance. TIA also can’t underscore enough that this issuance of guidance reinforces the FCC’s role as a global leader in regulatory approaches which foster innovation and advance public policy goals.
This collaborative effort between the FCC and TIA to bring about the eLabeling allowance is just the beginning of a partnership to create a global model for the most efficient and competitive environment.