The Ministry of Industry and Information Technology (MIIT) of China has issued a new announcement, Notice No. 52, that ultimately regulates its production, import, sale, and use of micropower short-range radio transmitting equipment (i.e. micropower equipment). This strand of equipment officially includes devices that work under the Long Range Wide Area Network (LoRaWAN®) technology, a Low Power, Wide Area (LPWA) networking protocol in IoT.

Among all the articles in the document, Article 7 has made a negative impression on the IoT community because of its strict clause on micropower equipment. It states the following conditions:

Effective January 1, 2020, cease of production or importing does not conform to this announcement but conforms to “About Release < micropower (short distance) Radio Equipment Technology Requirements >” (Notice No. 423 [2005]) stipulated in the special electronic crane scale wireless transmission equipment, 230 MHZ band wireless data transmission equipment, 230 MHZ band or crane machinery dedicated wireless remote control devices, as well as 410 MHZ band micropower equipment such as car alarm regulated in the “Notice on The Frequency of Wireless Automotive Anti-theft Alarm Equipment” (Letter No. 61[2006]).
Effective January 1, 2022, cease of production or importing does not conform to this announcement but conforms to “About Release < micropower (short distance) Radio Equipment Technology Requirements >” (Notice NO. 423 [2005]) stipulated in the civil measuring instruments, analog cordless telephones, and micro-power equipment in the 698-787 MHz frequency band.

As we can recall, IoT is divided into two major network categories: Narrowband-IoT (NB-IoT) and LoRa. Since NB-IoT operates in licensed bands or authorized frequency bands that the Chinese government authorizes, only the three major domestic operators in China are allowed to send signals within its frequency range: Telecom, Mobile, and China Unicom (although, Huawei also vigorously participated). Ordinary people and private companies venturing in IoT rely on LoRa to send signals as it works with an unlicensed spectrum. As is often the case with official restrictions in connectivity, the use of LoRa poses a possible violation.

LoRa and Chinese Private Companies

Despite the regulation, LoRa still has become very popular with major internet companies such as Alibaba Cloud and Tencent. Alibaba even announced that it will connect 10 billion devices over the next five years and integrate the requirements of the product network management platform of the IoT platform, so various companies can adapt to produce customized products. Tencent, on the one hand, is focused on LoRaWAN technology and applications.

This support of Chinese private companies despite the regulation comes as no surprise since long-distance communication is only for the privileged traditional telecom operators. If these private companies want to get involved in long-distance communications, they must choose from the unauthorized spectrum. As is certain, LoRa makes a good choice and is possibly set for massive growth not only in the world’s largest IoT market but in the whole world.

The Loophole Supporting LoRa

If we closely read the document, one can reckon that this issuance is in support of LoRa’s advancement. Zooming in Article 1 of Notice No. 52, LoRa can still be legally used:

Production or import of radio transmitting equipment for domestic sale and use which is listed in the “Catalogue and Technical Requirements for Micro-power Short-range Radio Transmitting Equipment” does not require the obtaining of a radiofrequency license, radio station license or type approval of radio transmitting equipment, however, it should comply with laws and regulations such as product quality, national standards and relevant provisions of the state on radio administration.

The specific regulations of the annex are explained further:

Civil measuring instrument

The application of the network area is limited to buildings, residential areas, and villages, and other small areas. Emission is restricted within a single channel at any time.

The civil measuring instrument equipment should be equipped with interference avoidance functions such as "pre-launch search" and shall not be adjusted or turned off by the user.

If the used frequency is the same as that of the local sound or television broadcasting station, it must not be used locally. If the frequency caused interference to the local sound, television broadcast, one should immediately stop its use, until the elimination of interference; or adjust to no interference frequency until it can be used again.

  1. Usage frequency:470-510 MHz
  2. Transmission power limit:50 mW (e.r.p)
  3. Transmission power spectral density limit:Occupying less than or equal to 200 kHz of bandwidth,is 50 mW /200 kHz (e.r.p) ; Occupying a bandwidth of 200-500 kHz,is10 mW/100 kHz(e.r.p).
  4. Duration of every single launch:less than one second
  5. Bandwidth occupied: no more than 500 kHz
  6. Frequency tolerance:100×10^-6

Considering these specifications, we understand that as long as the micropower device complies with these relevant regulations, non-ISM (Industrial, Scientific, and Medical) bands can be used. In other words, if LoRa meets the relevant requirements, then it can use the non-ISM band. LoRa can technically meet these requirements, so LoRa can legally use the 470 – 510 MHz channel.

Reading the revisions of the opinion draft, we can also see the official positive attitude of the ministry on LoRa. In the first edition of the “Draft for Comments” in 2017, there is a strict "not to be used for networking" rule for devices in the 470-510 MHz frequency band, while the official announcement stipulates that "the application of network should be limited to a small range of buildings, residential areas, and villages." The second version of “Draft for Comments” in 2018 also proposed that "micro-power equipment should adopt integrated antenna and be installed in a complete housing,” but this clause has been removed from the official announcement.

Therefore, this Notice No. 52 issued by MIIT is actually an official enclosure that provides an arena for LoRa’s tremendous growth.

With this new regulation in place, close collaboration among stakeholders in the IoT community is needed to push LoRa’s growth. The IoT community believes that the LoRaWAN® Alliance will make appropriate changes to the standard. As for the manufacturers and users of the LoRa industry chain (including RAK), as long as they have clear technical guidance and traction, we can legally and compliantly use LoRa products under this framework. Once this guidance from the industry and the Alliance is set and users start observing it, the LoRa industry is expected to enjoy more success and a greater following than ever before.