ETNO Reflection Document on “Draft ECC Recommendation (14)03: Charging Principles for National and International Freephone Numbers”
The Association of European Telecommunications Network Operators (ETNO) would like to thank the CEPT/ECC (Electronic Communications Committee) for the opportunity to comment on Draft ECC Recommendation (14)03 “Charging Principles for National and International Freephone Numbers”.
A freephone number is a number that is in principle reached free of charge for the calling party with the cost of the associated service covered by the called party. At national level, many CEPT countries have number ranges designated for this purpose.
 The European Telecommunications Network Operators' Association (ETNO) is representing 41 major companies, which provide electronic communications networks over fixed, mobile or personal communications systems in 35 countries. ETNO is Europe's leading trade association. More information about ETNO can be found at: www.etno.eu
National freephone service
Although national freephone service providers intend to offer unlimited access to the number, they do not wish to do the same for callers from abroad for a number of reasons (extra fees, irrelevance of the freephone service overseas etc.), and therefore they may request the blocking of international access to their freephone numbers. That may also apply to calls originated by foreign roamers visiting a specific country, depending also on the roaming commercial agreements that are defined with CEPT and extra CEPT mobile operators.
This draft Recommendation should take into account national freephone services market characteristics, in particular for the case of foreign roamers. A number of countries have initiated a coordinated approach on service access to freephone, added value service and 116 ranges whereby the access and the content of the service may be subject to different fees and possibly announcements. Those decisions were subject to national consultations, considerable discussions and induce significant costs. Those mechanisms are either in progress or being implemented by service providers and operators, and ETNO considers that adding new potentially conflicting principles to these initiatives can only be disruptive for the developments in progress.
International freephone service
The international freephone service and associated principles of implementation are defined in ITU-T recommendations and notably:
- E. 152: International freephone service
- E.169.1: Application of Recommendation E.164 numbering plan for universal international freephone numbers for international freephone service
- D.115: Tariff principles and accounting for the International Freephone Service (IFS).
These are used by all the industry worldwide to develop and implement these services in a consistent manner.
As far as numbering is concerned, the ITU manages the Universal International Freephone Number (UIFN) range (“+800”). A UIFN is composed of a three-digit country code for global service application, i.e. 800, followed by an 8 digit Global Subscriber Number (GSN). In that case, the caller of a UIFN has to dial an international prefix, so he is aware that this is an international call to an international freephone service.
It is ETNO’s view that some of the proposals put forward in the recommendations (e.g. tariffs, announcements) would overlap with principles laid out in the ITU-T Recommendations. Given that those principles are agreed internationally, ETNO considers that any evolution to the principles associated with the IFS should be discussed in the context of the evolution of these recommendations and not limited to a region or a group of countries.
In the following text, we propose some modifications to the draft ECC Recommendation to better reflect the commercial context and applicability, above all in the case of international end users, safeguarding in any case the consumers.
ECC recommendation of (14)03 on charging principles for national and international freephone numbers
“The European Conference of Postal and Telecommunications Administrations,
- consumer interests need to be protected
- users and callers of freephone numbers must be able to rely on the service concept
- a fee for the use of telecommunications terminal equipment is outside of the scope of this Recommendation
- special arrangements between the subscriber (holder of the freephone number) and the service provider (network operator) concerning the availability of the service and/or blocking of calls from networks with high charges are outside of the scope of this Recommendation
- that this recommendation does not address international calls to national freephone numbers.
- ITU-T Recommendation E. 152 "International freephone service” describing the international freephone principle and all ITU-T Recommendations defining the principles associated with IFS.
- That all CEPT Administrations take the necessary measures to ensure that the access, when available, to
bothnational and internationalfreephone services is always free of charge for the calling party. The access to the international freephone service (i.e. UIFN as defined and managed by ITU-T) should comply with the applicable ITU-T Recommendations.
- That the above mentioned principle should also apply for calling parties roaming in another CEPT country where technically and economically feasible.
- If not feasible, a minimum requirement is to
play an announcementinform the roaming caller that a charge may apply.