Dear Cynthia,

In most cases this would be considered an upgrade. I would suggest
that in many cases a retest for noise and balance would be appropriate.
Some jurisdictions such as Japan have rules governing upgrades to higher
speeds or different protocols which in part deal with whether or not
such a service is available. Korea is also very strict on the issue
of product registration In addition how the upgrade is implemented is
also dealt with. In the case of Australia I think you also would have
to document and test this. EMI may have to be rechecked if the
upgrade could potentially create different effects. I have experienced
this effect in software upgrades on highly populated boards in some but
not all instances. 

In a number of jurisdictions if you are now going to mark and declare
a modem as V.90 as opposed to X2 or 56K this is a variation since
the approval records would not indicate this. Standard practice in
most marketing departmens isto present this as a new enhanced model.

The best way to approach this is to draw up a table indicating how
the V.90 product is being implemented in terms of physical change,
chipset change, software change, firmware change, downloadable 
upgrade for those in service now, model number and/or part number
change, marketing approach and compare this to the approval 
records of the model being upgraded. This should allow you to
derive the issues that you have to address with each regulator.

I hope this helps you out.


Yours truly,


G. Rae Dulmage, B. Comm.,
President-TelApprove Services Corporation
1+613 257 3015 



Jon D Curtis wrote:
> 
> From: [email protected]
> Subject: Modem question
> 
> I just getting started in the modem approval realm so bear
> with me if I ask elementary questions.
> 
> When you get an approval with a certain speed modem
> (ie 56K) and then wish to upgrade the modem to a
> higher speed (ie V90) do the agencies consider this
> a new product or simply an upgrade??  Does it require
> the manufacture to redo all the approval testing??
> 
> Thanks
> Cynthia

Reply via email to