[Asterisk-Dev] OT - Regulatory hurdles for Zaptel and Japanese PRI

[Benjamin on Asterisk Mailing Lists]

Hi

in a private email exchange, John Todd said I should post this to the
Dev list. He thought it would at least have some curiosity value even
for those who are not interested in Japanese PRI. Anyway ...

Japanese PRI is derived from US PRI but the Japanese have the tendency
to protect their turf by changing specs they borrow just enough to be
incompatible so as to put up hurdles for foreign vendors to sell their
gear unmodified in Japan. This allows the Japanese vendors to
overcharge for most of the stuff they sell domestically and thereby
subsidise dumping prices on the stuff they sell overseas.

Japanese PRI, aka J1 is one of those areas where they do this rather
successfully and seemingly with impunity.

To put this into perspective ...

The cheapest Japanese J1/VoIP gateway costs about 40.000 USD for a
single span J1. The cheapest foreign manufactured J1/VoIP gateway used
to be a box from Multitech. The T1 version of this box is available in
the US for about 4000 USD. The J1 version is about 24.000 USD.
Compared to Japanese products this was still to be considered cheap
until a few months ago, when a Mainland Chinese company entered the
market with a J1/VoIP gateway that "only" costs about 10.000 USD. By
comparison, Dialogic J1 boards are roughly in that same price range.


You can imagine what kind of tsunami effect a Zaptel card would have
in this environment if it supported J1. However, the technical side of
making this happen doesn't seem to be the biggest obstacle.
Apparently, the differences between T1 and J1 are such that it looks
as if it was possible to adjust for it in the driver software alone.
The trouble is that nobody wants to sponsor this work to be carried
out due to the regulatory situation.

The Japanese type approval authority wants applicants to submit to
their process and not do anything that puts it into jeopardy. Yet it
looks as if the way in which the drivers are released via anonymous
CVS is incompatible with the way the approvals process works.

Strictly speaking, if Japanese type approval is to be granted, no
driver updates should be made via anonymous CVS until the updated
drivers have been submitted to, tested and approved by the approval
authority. Every such release cycle will cost around 3500 USD in
application fees plus the fees charged by an accredited testing lab
for carrying out the compliance testing. If updates or patches to
drivers are released into the public without going through this
process, then - going by the book - it could invalidate the type
approval.

The trouble is that a foreign product that looks like it is going to
whack the Japanese establishment is more likely to be checked for any
possible ways to turn down the application than a Japanese product
from one of the big name vendors where the authority may not be always
as strict as their rules may imply. They don't even have to give you
reasons why they turn down an application. They can just turn you down
and tell you to submit another application in order to delay your
market entry or to make it more expensive for you so you have to sell
your product at a hefty premium, too.

I have asked Digium for their opinion on this and suggested that the
solution may lie in a forked driver which is only for J1, then somehow
control the release process for that driver more tightly so as to not
raise any objections. The J1 driver could initially be taken closed
source to get things going, then gradually open it up later on once
the initial type approval has been granted and the product is
established in the market. I haven't had any feedback from Digium yet,
I suppose they are still busy trying to fill domestic demand on their
various new products they have released this year, so J1 isn't on
their radar yet. Can't really blame them for that.

Anyway, that's the story on J1 support and JATE type approval. All I
can say at this point is that we are still hopeful that we can get
something going sooner or later. If anybody has any questions,
comments or suggestions, they're welcome to drop me an email.

rgds
benjk
-- 
Sunrise Telephone Systems, 9F Shibuya Daikyo Bldg., 1-13-5 Shibuya,
Tokyo, Japan.

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