Q1: Did the TRA take over Type Approval requests or do they still need to be sent to the Ministry of Telecommunications? According to the Type Approval Regulation, the transition period ends on December 31, 2009; is the transition period extended?
A1:
The implementation of the new Type Approval Regime as well as the transition period for the existing Importation Licenses has been postponed. As the implementation still requires procedural decisions from the Ministry of Telecom (MoT) and the General Directorate of the Customs, we cannot at this time specify the starting dates. Information about the implementation date and the starting of the transition period will be posted on the TRA Website upon taking the final decision. Currently and until taking the final decision, the old regime operated by the Ministry of Telecommunication is still active and therefore any approval provided by MoT is still valid. You can submit the approval requests to the MoT.
Q2: In case the new regime in not implemented yet, what would be the status of licenses provided by the MoT when the TRA takes over?
A2:
Once the TRA announces the kick-off of the new regime, a transitional period will take place during which all the importation licenses provided by the MoT will be converted to licenses according to the new TA regime. However the Approvals provided by the MoT have no validity period and according to the old regime are used once by presenting to the Customs the signed “Customs Declaration” and therefore will not be considered as valid Type Approval under the new regime. Thus the importer should apply for new approval for the already approved equipments as well as the new ones all of which should comply with the TRA technical specifications and use the allowed frequency bands.
Q3: What are the next steps after having filled the Type Approval applications? Where filled applications should be presented or registered?
A3:
As the implementation of the new regime has been postponed, you should apply through the MoT where you have to present the “Customs Declaration” including the Importation license and the Technical details of the equipment. For more information on the current regime please contact the MoT / Internal exploitation department / Eng. Khaled Chaaban / Tel. 9611/979138.
Q4: What are the items (information, documentation, test reports etc) required for the approval application? Is the Regulatory Type Approval connected with the importation process in any way (e.g. must each shipment includes a copy of the Approval Certificate or other proof of Type Approval prior to import?)
A4:
All the information about the Type Approval processes and the required documents for each class of RTTE and for NIE can be found in the Type Approval Regulation on the TRA website
www.tra.gov.lb Prior to the importation of the RTTE and/or NIE, the importer should apply for an Import License for the specific class of RTTE and/or for NIE and then apply for type approval related to the imported types of equipment. Copies of the Import License and the Type Approval certificate should be included in the document presented to the customs upon importing the approved equipments and during the validity period of both the license and the TA certificate.
Q5: Is a license* required besides the Type Approval for the distribution of radio devices installed in vehicles?
*individual license, class license, frequency license, etc…
A5:
The Importer of such Radio Devices should apply for Import License and Type approval prior to import such equipment into the Lebanese territories. According to the Type Approval Regulation, only the companies recorded in the commercial register in Lebanon are permitted to hold an Import License, therefore as an Automotive Manufacturer you are unable to hold an Import License and Type Approval, however you can through a Lebanese Importer or Authorized dealer distribute the equipments in Lebanon, so you should prepare with the importer all the required documents including DoC and TCF.
Q6: The new regulation mentions in Chapter 9 Article 42 '' During the transition period, starting from July 01 2009 and ending on Dec 31, 2009''. Is the transition period applicable to import license and Type Approval certificate or only for import license? What about exiting Type Approval issued by The Ministry of Telecommunications?
A6:
During the transition period, only Importation Licenses granted by the MoT will be transformed to new licenses under the new regime, since currently there is no Type Approval Certificates granted by the MoT. The equipments are currently approved through the signature of the "Customs Declaration" of the imported equipments, the signed customs declaration which is considered as approval is presented only one time to the Customs in order to allow entering the equipment to the Lebanese Territories. Therefore under the new regime the importer should apply for new Type Approval for all types of telecom equipment including the models already approved and existing in the market.
Q7: What is the transition phase (when did it begin and when does it end)?
A7:
When announcing the kick-off of the new Type Approval regime a transitional phase of six months will take place during which the TRA will take over the Type Approval responsibilities from the MoT. The information about the implementation date and the starting of the transition period will be posted on the TRA Website upon taking the decision.
Q8: The old Importation License granted by the MoT will be automatically transferred to the new regime by only providing the TRA with the required papers.
What are the required papers and steps?
- Local Representative (“Importer”)?
- Registration of Importer or Manufacturer for RTTE Class 2?
- Application form for Type Approval Scheme 2?
- Type Approval fees for Scheme 2?
A8:
The required papers in this case are the same papers required for applying for a new Importation/Manufacture License, in addition to a copy of the import license previously granted by the MoT.
Q9: According to the new regulation, Is it possible for an independent agent to obtain Type Approvals or is it mandatory for the approval to be in the name of the local importer?
A9:
Only Lebanese Importers or Authorized dealers owning companies recorded in the commercial register in Lebanon are permitted to hold an Import License and therefore can apply for Type Approval for the RTTE of the classes specified in their license certificate.
Q10: Is a Local rep. with a Class 2 import license allowed to import Class 2 devices for different manufacturers?
A10:
An importer holding a Class 2 Import License can import any type of Class 2 RTTE for different manufacturers, (considering also that he already has the appropriate Type Approvals for the corresponding RTTEs).