EACEM Response to the DG Information Society Working Documents

EACEM, representing the Consumer Electronics Manufacturers in Europe, was greatly surprised and disappointed that it was not invited by the Commission to participate in the consultation exercise, arising out of the documents published on the 27^th April, nor was it invited to the public hearing on 10 - 11^th May. It is difficult to understand this omission as almost all of the products, particularly digital television, that the documents relate to are produced by our members.

Nevertheless, and even in light of the very limited time available for comment, we feel that there are a number of issues that need to be taken into account before draft directives can be prepared.

Working document on "Universal Services and user’s rights relating to electronic communications networks and services".

2. Item 2 of Annex VI on "Interoperability for analogue and digital television sets" requires considerable clarification.

It is assumed that the two paragraphs dealing with analogue and digital television respectively are derived from similar requirements in Directive 95/47/EEC. If this is the case then the "open interface socket" referred to in paragraph one is intended for connection primarily of analogue signals, via a socket such as the peritelevision connector specified in EN 50049-1. On the other hand the "open interface socket" referred to in paragraph two, by the definition of the signals it is intended to carry, is a digital interface socket, such as that specified in the common interface specification EN 50221. A clear distinction between the two has to be made. To refer to both applications by the term "open interface socket" is potentially most misleading

With the above clarification in mind, paragraph one of item 2 should apply to all television sets. The Commission should consider whether paragraph one and/or two should be applied to set top boxes.

In paragraph two there seems to be no reason for the 30 cm screen diagonal to be different from that specified in paragraph one i.e.: 42 cm.

In paragraph two the clarification in brackets ".. (either standardised by a recognised European standardisation body or declared open to third parties).." permits an interface that is either standardized by a recognized European standardization body or declared and open to third parties. The latter option is unacceptable as any number of interface sockets could meet such a requirement and permitting them to enter the market as an alternative to standardised interface would nullify the principle of interoperability. It is recognized that there will be a

legitimate development of interface solutions but these should not be permitted on to the market at least until the formal standardization process ensuring "legacy compatibility" has

been initiated; this is particularly important in view of the vast amount of equipment already in the market.

For your information the subject of interoperability is covered in the EACEM Baseline Digital Terrestrial TV Specification, which refers to the future extension of the common interface to permit further development. A copy of this is enclosed.

Working Document on "Access to, and interconnection of, electronics communications networks and associated facilities".

2. It is noted that in the last paragraph of Section 4, on page 5, that new gateways have emerged since the drafting of Directive 95/47 and that these notably include Electronic Programme Guides (EPG) and Applications Programme Interfaces. The extension of obligations to these services is recognized and is repeated as the last item in Annex II. Section 15.3 of the Common Regulatory Framework document states that standards or specifications may be made compulsory, if other measures appear inadequate to ensure interoperability. The key issue arising out of these new gateways is access to content. The regulation of electronic programme guides and applications programme interfaces should be considered as a matter of priority.

3. Annex II of the Access document is not referred to in the body of the document and should appear under Section 8.

4. It is also stressed that the terms "common interface" and "conditional access" must be used consistently throughout the documents. It is suggested to define them in the Access and interconnection document with reference made to this by the other documents (Universal Services document for instance) if necessary.

Working document on "A common regulatory framework for electronic communications networks and services".

Should you wish for any further clarification or discussion on our comments, EACEM is happy to provide experts for a joint meeting.

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