According to the Type Approval Regulation, Ethernet and fiber optics interfaces do not require approval as they do not connect DIRECTLY to the PSTN. The concern is about equipment with Ethernet ports
which can be used as terminal equipment in public networks where Ethernet is used as the interface
between the access network and the terminal equipment. Does the TRA require any particular test report or even testing of the Ethernet port for this case? If so, what are the applicable standards?
The equipments that couldn’t be connected directly to the public network and are not emitters of electromagnetic radiation are not subject to type approval. These equipments include those with Ethernet and fiber optics interfaces. Later on the TRA will present to the customs a list of the equipments that are Type Approval Exempt, but meanwhile, the importers are requested to present to the customs a type approval exemption letter from the TRA allowing entering such equipment. So the importer should submit to the TRA a type approval request with the specifications of the equipment and all the interfaces in order to decide whether it requires a type approval or not.
Please not that if one of the interfaces requires approval then the whole equipment requires a type approval certificate and should comply with the specifications for this interface.
Does an RF receiver need a separate approval or can it be certified together with the associated RF transmitter?
Your Type Approval certificate can be obtained for both RF receiver and the associated RF transmitter at the same time. However, the TCF should include all the documents describing this equipment and the list of all the TRA technical specifications with which the receiver and the associated transmitter should comply. These equipments are classified under the Class 2 RTTE and therefore the importer should be holding a Class 2 import license in order to be able to apply for type approval.
How to certify an 802.11 WLAN product operating in 2.4 GHz band in Lebanon?
- The product does not connect to the PSTN, and will be used only on the customer premises. Does it require a local representative with valid importers license to sell this product?
- The product comes with its own international power supply. Can the product be shipped with it knowing that it comes with international safety approvals?
- What class will the product be classified under? Would be Class 2 or Class 3?
- For all types of telecommunication equipments the manufacturer should have a local representative or importer holding an importation license in order to be able to import such equipments into the Lebanese territories.
- The international power supply is not related to telecommunication equipment and thus it is not the responsibility of the TRA to grant approval for such type of equipment.
- The 802.11 WLAN products operating in 2.4 GHz band is intended for internal use (indoor) and thus is considered as the Short Rage Devices (SRD). These types of equipments are classified as Class 2 RTTE, therefore the importer and/or local representative should apply for a Class 2 Importation License and then for Type Approval for this equipment type.
A laptop to be introduced into the Lebanese market includes a device (e.g. WIFI-card) which sends electromagnetic waves. Does the product need a certification for the device (WIFI-card) or is a certification for the whole product (the laptop) sufficient? If there is a need for a device certification, is an additional testing of this device necessary for the validation of the whole product?
The importer of a laptop including a WIFI-card, should hold a Type Approval for the device only (WIFI-card), which is considered as an RTTE, to be able to import such equipment into Lebanon, there’s no type approval certificate for the whole product.
Additionally, only a test report for the WIFI-Card will be necessary and no additional test for the validation of the whole product will be required.
Are RECEIVERS subject to Type Approval under the new scheme and particularly:
- Remote Key Entry System (Receiver) in 433MHz
The device is a fixed installation inside vehicles, used together with Remote Key carried by the driver
- Standalone GPS Receiver on L1-Band (1575.42 MHz)
The device is a fixed installation inside vehicles, used together with Car Navigation Systems.
No telecommunication equipments are exempt from Type Approval. The receivers to be imported are part of the non-specific SRD that should be approved as Class 2 RTTE. The Standalone GPS Receivers are also considered as Class 2 RTTE, so for both of them a TCF with the Importer should be prepared and submitted along with the Type Approval application to the TRA.
Is it possible to apply to a Family Approval (approving 1 original product as well as family products) in the case where for example a “Car Navigation System with Bluetooth module” has 4 family models and there will be no difference in the RF characteristics but with the software only?
The new Type Approval regime does not support “family approval”. However, as the importer is allowed to apply for Type Approval certificate for different types of telecom equipment, he can apply for all the equipment models but in this case the models are considered as separate type of equipment and the importer should submit all the required documents for each model.
Is a special license for Encryption services and products needed?
R7: For Encryption services and product, the authorization of the Ministry of Defense (MoD) is needed prior to obtaining the Type Approval and importation license from the TRA. Generally, the MoD may require a copy of the Encryption / Decryption code/ Key.
We understand that only DoC is needed to be prepared for class 0 RTTE (such as Bluetooth) instead of receiving TA certificate from TRA, which is shown in the Figure 2: Overall RTTE Type Approval Process in Type Approval Regulation. For this case, we understand that local Importer can receive labels of requested number also after preparing DoC. Is our understanding correct?
To import Class 0 RTTE the Importer should be holding only an Import license for Class-0 RTTE, and he is not required to apply for Type Approval for such equipments, however the importer should prepare the DoC as well as the TCF for each type of imported equipment and store them at an address in Lebanon for inspection, then the importer can receive the labels for Class-0 RTTE.