Over several decades, the FCC, the US Trade Representative, Department of Commerce (NIST) and the Industry (TCB Council, ACIL, Private Labs, including WLL) have been involved with opening up regulatory trade arrangements under the guise of “Mutual Recognition Arrangements” (MRAs).
The purpose of MRAs is to even the playing ground for labs and their industrial clientele. In the early 90s, this engineer remembers the cumbersome tasks of trying to help US manufacturers place products on the European Market. Then, a miracle happened: the CE Marking appeared in the early 1990s which knit together trade and tariff agreements between the then EU member states.
This emerged from the “Common Market” so that the horrors of WWII were not to repeat themselves. Hence, no more cross-border inspections, burdensome paperwork, a single passport for all EU members and, ultimately, the emergence of the US-EU MRA (specifically for our industry, the Telecommunications or “TEL-MRA.” Others exist).
Over a relatively brief period of time, the progressive EU stance on promoting free trade opened markets for US and Canadian manufacturers (and, very significantly, the global electronic markets) emerged.
China was a huge recipient of the benefits of this action.
In the beginning of my various visits to the Middle Kingdom, the country was just-then emerging from years of colonialization, as well as centralized and anti-private industry policies that formed during the Mao era. It was opened up by a small-of-stature but larger-than-life Deng Xiaoping, who proclaimed that China should be a rich country.
Over many challenging spasms of a pupa emerging to a chrysalis, millions of people were lifted from abject poverty and gave wings to an emerging middle class. To understand the profound impact on the ordinary folk, one must look back at the “Great Leap Forward,” a Maoist idea that led to the death of 30 millions+ of people. A desperate and tragic account of crushing authoritative rule. Well, that’s history.
Not a perfect transformation, but an economy of freedom-from-want was nascent and, notably, effervescent. Whole pent-up capital practices emerged and blossomed. I argue that it was a necessary transformation to raise an enormous populace from the maw of poverty.
China, one should notice, has gone from a backwards and crippled economy to the known global provider of practical and high-technologies (yea, robbed, copied…who doesn’t?) that make our modern systems of communications and computing at the touch of our metaphorical and physical fingers.
To the matter at-hand, the banning of “Bad Labs.”
Back in the late ’00s, as the success of the US/Canada/HK/Japan/EU MRAs were apparent to many (invisible to many more), the ground seemed ripe to plant the notions of an MRA with China. It was a struggle.
Rumors and anecdotes abound: the FCC was attempting to even the playing ground with (seemingly) endless dialogue and discussions between like-minded practitioners across the Pacific Ocean to restrict participation in the US Market by non-MRA partners.
But, in the end, the MRA discussions devolved to a mist and the FCC (in my view) decided that this was a trade matter and not at the core of the FCC’s mandate to protect the use of the Radio Frequency Spectrum.
The entire mandate was borne of the Communications Act of 1934 (Wiki, which we do, and all of us should, monetarily support).
This prescient document, during the rise of storms stirring over Europe, reads in-part:
“For the purpose of regulating interstate and foreign commerce in communication by wire and radio so as to make available, so far as possible to all the people of the United States a rapid, efficient, Nation-wide, and world-wide wire and radio communication service with adequate facilities at reasonable charges, for the purpose of the national defense [emphasis added], for the purpose of promoting safety of life and property through the use of wire and radio communication….”
To me, these words satisfy completely the mission.
Fast-forward: the political will has shifted, and the banning of certain Chinese/Russian/N. Korean (to a much lesser extent) adversarial countries from putting into service critical equipment has grown over the past ~15 years. Huawei, ZTE, Kaspersky, and others are on the so-called “Covered List” (look it up).
The recent action of the FCC, which seeks to ban “Bad Labs”— truly awful language coming from the highest levels of the US Government — from participating in the Testing and Certification industry is on the Docket.
This action seeks to limit or eliminate the participation of “adversary countries” from the FCC’s process of Equipment Authorization.
Opportunistically, this represents a market for certain privately held companies in China and whole fields of the Western-dominated labs in the US and partners (if we should be so hopeful that we can make good returns on decades of friendships).
At the crux is the notion that the PRC/Russia/others can influence the testing of devices, not in a technical way, but in a malicious way. Of course, malicious intent exists, but it is a dark shadow over the many, many thousands of “Good Actors” who seek a fair and technically sound basis for compliance with regulations which seek to do a myriad of things.
So, in retrospect of my own experience between and with the US and Chinese industries, (and I am not an apologist, nor an antagonist of either system), we need to recognize the worth and value of like-minded people who seek, in our own little spheres of influence, fair and practical trade and mutual respect.
If this Docket advances, and it quite possibly will, the many thousands of hours of work on behalf of the good interests of a global community will evaporate.
Better, the advancement of an US-China MRA would be a soothing salve on this long-standing wound of misunderstanding. The resources are there; the will is to advance the fair and reasonable approach to recognize the core underlying mutually-beneficial advancements in the process of producing meaningful goods for the world’s populace.
