AMETIC is the Association representing Spain's digital industry, encompassing a wide range of organizations, from SMEs to global corporations in sectors like IT, telecommunications, consumer electronics, and digital services.
TV Manufacturers represented by AMETIC already contributed to the Public Consultation that was opened by Spanish authorities, together with other companies that are engaged with AMETIC’s “TDT and DAB+” Working Group. This Public Consultation was based on the draft Royal Decree that was published on 25th September 2024 and was closed on 17th October.
Just before closing the Public Consultation, on 15th October 2024, another draft Royal Decree text was notified to European Commission in the TRIS portal. After comparing the draft text notified to EC with the previous text published in the Spanish Public Consultation, AMETIC identified one change that impacts the requirements potentially imposed to TV Manufacturers.
This change is found in 4th point of the Sixth transition provision:
“4. As regards interactive services, digital terrestrial television receivers ... must have a broadband connection and be compatible with the European standard [ETSI TS 102 796] v1.4.1 (or later) Hybrid Broadcast Broadband TV – HbbTV, implementing the specification HbbTV 2.0.4 or later.”
In the first version of the draft Royal Decree (used for Spanish Public Consultation), the required HbbTV specification version was different, as follows:
“4. As regards interactive services, digital terrestrial television receivers … must have a broadband connection and be compatible with the European standard [ETSI TS 102 796] v1.4.1 (or later) Hybrid Broadcast Broadband TV – HbbTV, implementing the specification HbbTV 2.0.1 or later.”
From our point of view, mandating the support of the latest HbbTV specification in all TV products placed in the market is excessive and it is not justified. HbbTV 2.0.4 was published last year (March 2023), and the related European standard ETSI TS 102 796 v1.7.1 was published in September 2023. Although some TV products may start supporting this version in 2025, we expect it will take some years until this version could be considered a minimum requirement.
If HbbTV 2.0.4 is mandated as a legal requirement for Spain, it would require adaptation also for derivative models that are expected to be sold in the European Union in the coming years. This impact is not limited to the software design resources, but it also includes potential re-certification costs, as a significant part of the certified product is modified. The products are common to the EU countries, so upgrading HbbTV version due to Spanish regulation will be translated to re-certification costs in other European countries, with a huge cost for TV manufacturers.
From a features point of view, AMETIC understands that keeping the same HbbTV version (2.0.1) that was enforced in 2019 (RD 391/2019) may not be enough for the future adoption of UHD services with HDR. The necessary HDR and next generation audio support was specified in HbbTV 2.0.2, and later standardised in ETSI TS 102 796 v1.5.1. We consider that this version is more suitable to be considered as a minimum requirement, as it was published in 2020, and could be adopted with a reasonable impact.
However, our recommendation is that specific HbbTV versions should not be part of a legal document, such as this Royal Decree. Due to the continuous evolution of the standard, AMETIC considers that HbbTV specification should be referenced in a more technical guideline, where other technical aspects need to be clarified anyway (such as new signalling, DVB-T2 technical parameters, detailed parameters for UHD, HDR, NGA, etc).
