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ISO 11784/85: A short discussion

There are a number of serious flaws affecting the ISO 11784/85 standard.
This paper will discuss three issues which make it unsuitable for national companion animal registration programs and endangered species identification:
(1) Inability to ensure unique ID codes
(2) Lack of manufacturers’ accountability
(3) The problem of transponder performance

(1) Inability to ensure unique ID codes
One of the biggest problems affecting ISO 11784/85 compliant transponders is that the manufacturer cannot guarantee unique ID codes beyond his own manufacturing facility. In fact, quite the contrary is true. ISO11784/85 compliant read-only transponders (those that are programmed by the manufacturer in the factory), one-time-programmable transponders (those that come blank and are programmed upon implementation) and write-many-read-many transponders (those that come blank and can be reprogrammed repeatedly) are currently being offered by a number of manufacturers. All of these are compatible with ISO 11784 and 11785 and could be programmed to read any number the customer desires, including ID code duplicates.

Why is the lack of unique ID codes a problem?
It is only a problem in certain applications, namely, those that require unique identification in open-loop systems, such as national recovery databases, breed registries and the like. Why has no national bank ever published an “open standard” for printing paper money, so that anyone may print its currency? Publishing specifications for paper, ink and printing plates to use to print money is the functional equivalent of putting the protocol and IC coding for transponders in the public domain. Like a $100 bill, which costs only a few cents to make, a transponder, when put in a champion Pekinese or a champion racehorse, assumes an intrinsic value many times higher than its cost. Duplicating the ID number allows someone wishing to “game the system,” to clone the animal, at least as far as the database or registry is concerned.

Using ISO11784/85 compliant OTP transponders, an animal from Latvia (for example) can be made to look like one that came from Germany, or, vice versa. Dog owners can keep several cocker spaniels, for example, while registering only one: if ISO 11784/85 transponders are used to identify them, all of the others can be chipped with the same transponder ID number. A parrot poached from the Amazon rainforest can be made to look like one hatched in the Tampa Zoo, thereby circumventing CITES trade restrictions designed to protect endangered species from extinction. An animal owner can claim insurance coverage for several animals while only taking out a policy for one. By using a WMRM transponder, the same animal can even change identities throughout its life.

How does the “open standards” approach create this problem?
The premise behind the International Standards Organisation (ISO) is to create so-called “open standards.” Generic solutions. An ISO standard is designed to be a sort of “cook book recipe” that any manufacturer may follow to create a product that complies with the standard. ISO does not police compliance. Compliance is entirely voluntary. This approach to standardization works extremely well for modem protocols and paper sizes, and it is also suitable for identification of dairy cows in closed loop systems and the like, but it is flawed if the premise is to generate unique ID numbers for use in open loop systems.

Because there are no legal "teeth" behind the ISO standard, there is no means to interdict the production of unsanctioned transponders or to prevent their being applied and the animals chipped with them from being shipped around the world. The ISO "open standard" by its nature depends upon an honour code. It is susceptible to compromise by manufacturers, whose cooperation cannot be enforced.

Even obtaining transponders from pre-approved, “vetted” manufacturers and filtering all these ISO-conforming transponders through a single hub will not prevent ISO 11784/85-conforming transponders with duplicate ID numbers from entering the market.

(2) The problem of manufacturers' accountability
A related problem of all "open standards" and generic products is how to hold individual manufacturers accountable. An implantable, glass-encapsulated transponder of one brand can be visually indistinguishable from other brands. Obviously, once the transponder is implanted, you cannot even visually inspect the transponder.

Because all ISO FDX-B transponders are functional clones, the operating protocol also will not help distinguish the product (in the way a reader can distinguish between a Trovan 128 KHz transponder and an AVID encrypted transponder, for example).

A Rome-based institute called ICAR has agreed to assign so-called “manufacturer’s codes” to different suppliers of ISO 11784/85 transponders, who pay for the privilege. The idea is to give the user a means of distinguishing among different transponder brands. In this way, so the thinking went, it would be possible for the user to identify inferior product, or manufacturers who didn't strictly control their numbering schemes, and avoid the offending manufacturer's product in the future. It must be noted, however, that the published ISO 11784 and ISO 11785 standards do not assign this role to ICAR. Also, unfortunately, ICAR cannot guarantee that a given manufacturer's three-digit ID number appearing in a transponder’s ID code ensures that this manufacturer in fact made the transponder.

(3) The problem of transponder performance
Neither ISO 11784 nor ISO 11785 stipulates any minimum transponder performance requirements for microtransponders (the size of transponder that is suitable for use in companion animals, exotics etc.) Therefore, a transponder reading at "touch" reading distance (a matter of 1 cm or less) could be fully ISO-standards compliant. A transponder reading at “touch” reading distance, would yield a “no read” in a turtle, a Pekinese or a Persian cat, because the animal’s carapace/coat itself is well over 1 cm thick. The transponder is out of range of the reader. ISO 11784/85-compliance is therefore no quality guarantee or guarantee of suitability for a given application. It also offers no guarantee to the veterinary that a given RFID product will actually work when implanted into the animal. What is more, ISO-compatible transponders programmed with a given manufacturer’s code could merely be code clones that do not meet that particular manufacturer’s product or quality standards.

Hasn’t ISO/TC23/SC19/WG3 already moved to address the problem?
In response to the well-known problems with code security in the current ISO 11784/85 standard, the responsible working group, WG3, has set itself the task of developing a new standard, ISO 14223. ISO 14223 describes a so-called “advanced” transponder, and attempts to frustrate the duplication of the ID code through increased technical complexity and encryption of the integrated circuit (IC). This approach would merely raise the hurdle slightly: the product specifications would still be published and conform to all the ISO usage and accessibility guidelines, but the resulting product would be more costly than transponders in the market today and the size of the IC would be larger, precluding its use in so-called “microtransponders” (the small, glass-encapsulated transponders that are the preferred embodiment for companion animal and endangered species).

There are a number of legitimate, very worthwhile potential uses for ISO 11784/85 transponders, however national animal registration databases relying on postive and unique identification is not one of them. For a comprehensive discussion please see: http://www.rfidnews.com/iso_11784.html