Letter issued to TEC regarding Mobile Handset

Dear Sir,     

We have been informing you about the Govt requirements for mandatory testing for mobile handsets by TEC, GOI from 1st October, 2018. No mobile handset import or locally manufactured will be allowed unless mandatory tested by TEC. As of now BIS shall also continue.

There are regular meetings in TEC for framing specifications. For mobile handsets meeting was held on 26.2.2018, which was attended by some of mobile manufacturers and test labs etc.

The specifications discussed and deleted or revised etc. are available with us in association and can be asked from Manisha. and any comments needed urgently within two days.

However on issue of MSAI certificate for IMEI we have represented as below. Hope to look forward for your support:

1.   Clause 2.2 - Standard IS 16046 : 2-12 does not exist as the same has been withdrawn by BIS. Current standard is IS 16046 : 2015.
2. Clause 2.3 - BIS has issued IS 16333 (Part 1) : 2015 on the Mobile Phone Handsets.(Safety Requirements). This may be incorporated in place of IS 13252.
3. Clause 5.3:  Ipv 4/6
   DOT order of 2013 is roadmap. Not compulsory. DOT has set a date for compliance for IPV 6, but that date is not yet final and likely to extend. Mr Shakeel DDG knows this. 
   As of now it is not mandatory. As of now there is no requirement of a certificate from any lab. As of now IV 4 is also continuing and IPv 6 also continuing. This issue comes in all MATCOF and standard decision is we will follow DOT mandate and as of now both Ipv 4 and 6 are allowed but no CERTIFICATE and NO LAB TEST REQUIRED.So please change it.
4. 5.1.b  GPS
   DOT has removed GPS from feature phone. It applies to only smart phone. Hence no compliance needed. In Smart phone GPS is always available. Hence request this clause be deleted. 
   AS MATCOF does not provide option or choice...so best this clause be deleted. (The other option is to make two ERs one for feature phone and one for smart phone.....which is not advisable)
5. Clause 5.1 a  Panic button
   Panic button is a feature mandated in mobile handsets. But DOT does not envisage any test for this.  So self certificate is enough. No compliance test from any lab needed. The emergency number 112 mentioned in5.1.1.is i fact panic button. 5.1.1 has been dropped. so 5.1.1 can also  be dropped or made on self certificate.
6. Para 2.1.1 SAR Certificate...DOT allows on self certificate basis...PL FOLLOW THE SAME.
7. Clause 5.0 IMEI Numbers
    Please be informed that DOT/DGFT has mandated that telecom operators shall not permit calls/imports without valid IMEI numbers

BUT THERE IS NO POLICY GUIDELINES/REGULATION/PROCEDURE BY GOI DOT FOR ALLOCATION/REGULATION FOR IMEI.

These are provided by a private association called GSMA. There is no legal provisions governing IMEI in India.

We support and favour IMEI without any doubt, but IMEI Numbers are allotted by GSMA through its private bodies and in India we have MSAI. There are several complaints against MSAI, very well known to TRAI, DOT, Sr. DDG SA DOT, GSMA, COAI, ICA, CMAI, TEMA. BY AND LARGE, the OI DOT is UNABLE TO CHECK HIS MALPRACTICES AND FRAUD ON CUSTOMERS AND OVERCHARGING BY ANY WAY AND AS MSAI MANAGED SERVICES. There are two MSAI run by same person.

Our intention to submit all this is...NO MONOPOLY SHOULD BE ALLOWED FOR MSAI.

Now what are DOT Orders?

1. 1. To verify IMEI numbers and its genuineness ( and stop  ZERO ZERO IMEI etc.  ...a SOP has been issued by which the custom officer or authorized officer can have access to GSMA data base called IMEI Data base and check genuineness of IMEI. It does not call any certificate from MSAI or any GSMA or ANY TEST LAB.

   SOP was issued by DOT on 29.05.2015 vide number 13-11-2014-SII. Para 9 thereof details that custom officer has to log into to GSMA data base by password details.

   PL PUT ON RECORD THAT NO TEST LAB IN WORLD CAN GIVE CERTIFICATE FOR IMEI . That is why DOT laid down SOP and asked custom officers to log into data base by password.   it is different that corruption is done by custom officer asking certificate from MSAI without writing and just orally and MSAI charges 500 USD for each consignment and that is objected by all brands and DOT CONFIRMS THAT NO MSAI CERTIFICATE IS NEEDED, YET CUSTOMS ASK FOR IT).

   IMEI Certificate mentioned in clause 9.1 is not required from MSAI but from system data base.

2. There are issues of conflict of interest as MSAI has also set up LAB MSAI Research Lab.

SO OUR REQUEST MAKE 5.0 on SELF CERTIFICATION BASIS or in alternative let DOT pass on the log in pass word to TEC and TEC can check it. The GSMA password cannot be given to a private person.

REGARDS