On January 4, the Ministry of Industry and Information Technology Radio Administration released the "Ultra-Wideband (UWB) Equipment Radio Management Regulations (Draft for Public Comments)" (hereinafter referred to as "Draft for Public Comments"), for public comment. This is the first important amendment to the "Regulations on Frequency Use of Ultra-Wideband (UWB) Technology" (MIIT No. [2008] 354) (hereinafter referred to as "the Regulations") issued in December 2008, 14 years ago.

Regulating the development of the industry and formulating scientific regulations

The draft regulations are different from the previous ones, not only in terms of content, but also in terms of the current stage of development of the UWB industry. If the 2008 version of the regulations was to draw a framework for the development of the domestic UWB industry, then the release of the consultation draft is an important step to further regulate the development of the industry from a scientific perspective.

From the perspective of industry development, UWB was in its initial stage of research in 2008, when few products were launched in the market, and only afterwards did individual companies begin to apply timedomain and Ubisense products in China, although they were also non-standard products. In the regulations first announced by the Ministry of Industry and Information Technology on 6 December 2008 for the use of UWB technology, it is clear that the regulations were developed for market demand, as reflected in the beginning of the announcement:

In order to meet the application needs of short-range high-speed wireless data communications, improve frequency utilization, according to China's radio frequency division and the actual use of the situation, the development of ultra-wideband (UWB) technology frequency use regulations.

This reflects the open and encouraging attitude towards the new technology at the policy level, which is beneficial for promoting the development of UWB technology and industry in China.

Now, after 14 years, at least two important changes have taken place in the market: firstly, UWB has gone from being "little known" to being "well known" in the industry, and more importantly, the applications based on UWB technology have evolved from 2B to 2C during this period. Secondly, not only is UWB technology at an all-time high, but with the gradual spread of new communication methods such as 5G and Wi-Fi 6/Wi-Fi 7, wireless communication has ushered in a new era. Secondly, not only is UWB technology booming, but with the gradual spread of new communication methods such as 5G and Wi-Fi 6/Wi-Fi 7, wireless communication has ushered in a new era of "variety", which has also led to problems such as frequency band overlap and mutual interference between various technologies in the communication process. If the output power of UWB devices is amplified, the normal operation of other Wi-Fi devices may be affected.

RF technical requirements for ultra-wideband (UWB) radio transmitting equipment (Source: MIIT website)

Therefore, in the exposure draft can be seen, not only the use of the frequency range has been narrowed to a certain extent (the exposure draft provides for the UWB operating frequency range in the 7235-8750MHz), more detailed in the frequency division, but also the PA's transmit power has been strictly limited (equivalent omnidirectional radiation power spectral density is limited to no greater than -41dBm/MHz). This lays the foundation for the domestic resources in each frequency band to be well placed so that they can each do their own job and develop together.

Industry development to meet changes, divided into two views

"Frequency" and "power" are undoubtedly the two most noteworthy pieces of content in this draft consultation, "refinement" and "restrictions "is undoubtedly the most significant feature. For the UWB industry, which has been developing for more than 10 years and is relatively mature, these changes are undoubtedly still relatively large and will therefore inevitably have a certain impact, which needs to be viewed in two ways.

Positive aspects

Standards first, applications second. In terms of UWB standards, international standards have given UWB technology broad support, with frequencies divided into more than a dozen channels. At present, many domestic manufacturers use a wide variety of frequency bands and a wide range of products, none of which are implemented in strict accordance with international standards. In particular, in industry applications, each has its own frequency range and internal protocol barriers are high, and domestic UWB devices often add PAs to enhance output power for better performance. These issues have posed certain obstacles to the standardisation of UWB applications and the interconnection between various equipment manufacturers. The consultation draft, on the one hand, unifies and restricts the use of related technologies by UWB enterprises in terms of frequency of use and power limitation; on the other hand, it also has broader requirements and stricter regulation on the testing of UWB products. This will undoubtedly have a positive effect on further promoting the standardisation of the use of standards by UWB companies and promoting interconnection and product quality improvement among various manufacturers.

In particular, in short-range application scenarios in the 2C consumer sector, cleaner frequency bands can be used and encrypted communications are more secure. For example, mobile phones currently supporting UWB technology usually support both channel 5 and channel 9 bands, and manufacturers usually have to support both bands when designing their products, which makes design difficult and also adds new costs. If a single band, channel 9, is identified, then the handset manufacturer will only need to design for channel 9 and will not need to set aside other bands to support it.

There are also positives in terms of spectrum utilisation, such as the aforementioned overlap between UWB and Wi-Fi bands. The sooner the band conflict is resolved, the better it will be for the future development of the industry, no doubt.

This is undoubtedly beneficial to the industry's future development. For some innovative domestic companies that are still committed to mass production of UWB chips, this will also bring certain benefits. With the release of the consultation draft, these companies can take advantage of the mature market environment and technology to achieve a wave of domestic substitution under the guidance of the country's major policy of innovation, and then seize resources from the giants to maximize the benefits in the local market.

The negative side

In addition to the favourable aspects, the unfavourable aspects also require a more positive attitude to face. The most direct chain reaction caused by the release of the consultation draft is the heavy adjustment of industry chain enterprises, such as the upgrading of chips, the need to change channels for RF tuning, the re-till of the whole product line, and the strategic adjustment especially for some industry application scenarios.

Taking UWB positioning manufacturers as an example, the release of the exposure draft will likely result in the renewal of the entire product line for manufacturers that have been using UWB low-band channels. At the same time, the exposure draft adds more out-of-band spurious testing requirements to product testing, and these factors will result in a significant cost to UWB manufacturers in terms of product development costs.

In addition, these problems will extend to the operation of enterprises. If future tenders are awarded in strict accordance with the requirements of the draft, then application scenarios with high range requirements will have a greater impact, as the positioning range supported by UWB power will also be limited by the draft, such as underground positioning, coal mining, tunnels and other scenarios, which may not be easily achieved. This will not be easy to achieve in scenarios such as underground positioning, coal mining and tunnels. Even if this can be achieved by increasing the density of base station deployments, the high cost will scare off a number of applicants.

Companies need to respond well and avoid harm

As a scarce and non-renewable resource, it is only a matter of time before the use of radio spectrum can be improved through effective regulation and unified management, because only through standardisation can standardisation be achieved, and only through standardisation can further scale be achieved. The release of the draft consultation paper is in fact only a hard requirement for the standardisation of the use of UWB technology from a policy perspective, but it does not mean that UWB technology itself is perfect or that the positioning industry is fully mature. It is still necessary for enterprises up and down the industry chain to make concerted efforts to promote the improvement of the policy and respond positively for the better development of the UWB industry and the prosperity of the wireless communication industry.

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