Exemptions to ISO 11784 and ISO 11785 currently under review in WG3
Suggestions involve explicitly permiting code duplication and to permit ISO 11784-incompatible coding

June 25, 2001 -- Two documents are being circulated by WG3 on the matter of proposed 'exemptions' to the ISO 11784 and ISO 11785 standards. Both involve a UK request to modify the standard to accommodate current visual tag standards within the scope of ISO 11784 and ISO 11785. The proposals will compound the problems with the standard that have been objected to by P-member nations in the past:

(1) incompatibility among various elements of the standard HDX, FDX-B and now "UK-coding" (for lack of a better term). Readers must be specially modified to read each of the three classes of transponders. (see "Recommendations for using the UK ending system for farm animals within the 11784 code structure," dated 18 June, 2001)

(2) official endorsement by WG3 for use of OTP technology (field-programmable transponders which can be coded with any ID number desired in the field) (see document ISO/TC23/SC19/WG3/TWG/193, dated 31 May, 2001 entitled "Recommendations for replacing lost animal transponders by specimen containing an identical national ID code." )

About the document "Recommendations for using the UK ending system for farm animals within the 11784 code structure."
Entities in the UK are advising WG3 that they want to use ISO 11784/85, but require a 'special' form of coding that doesn't fit within ISO 11784 as written. Instead of using ISO 11784 coding, they want to carry over their existing visual tag ID numbering scheme into electronic eartags. The author of the referenced paper "Recommendations for using the UK ending system for farm animals within the 11784 code structure," is proposing that WG3 bend over backward to accommodate this request.

As far as the technical aspect of the proposal is concerned, the UK's proposal is seriously incompatible with ISO 11784. Note the author's reference to making the check digit an 'information bit' in order to accommodate the UK's requirements - see point 4 under "Possible Solution." This means that transponders programmed in this way will be incompatible with the standard. The ID numbers of these transponders will not display correctly on ISO 11784- compliant readers already in use.

In other words, in addition to the FDX-B/HDX incompatibility that is already known, and that IDEA has pointed out, (see the warning issued by IDEA) we now have another incompatibility in the offing: a proposed 'accommodation' for a particular country. This sets a very bad precedent: When will the next incompatible special request be accommodated?

Note also the requirement for special species coding, location coding etc. Logistically, implementation of this proposal places a tremendous burden on the distribution systems to get the right transponder to the right end user, with no screw-ups anywhere along the line. It also presupposes that everyone is going to play by the rules and nobody will try to manipulate the system. (How likely will that be, human nature being what it is?) How will it be assured that the correct species code ends up in the correct animal? That transponders with a given regional ID code end up only in the designated counties? Mix-ups are inevitable, even assuming that there is no bad-faith attempt to manipulate the system.

Furthermore, the requesting entity has explained they would like ID codes for tags reported 'lost' to be duplicated. (see ). The author of the referenced document explains that it is logistically impossible to accommodate this request in a transponder production. (In other words, the requirement for custom code duplication precludes the use of factory pre-programmed transponders). As a solution he recommends use of OTP (one-time field-programmable) transponders, which would allow ID codes to be duplicated in the field.
It is becoming very apparent that this standard

(1) cannot ensure unique ID codes (contrary to what is claimed in ISO 11784)

(2) cannot ensure a single standard transmission protocol and a single standard programming scheme for transponders (i.e. Displays of a given transponder's ID number will differ depending upon the reader being used).

Transponder manufacturers promoting the standard (even those issued manufacturer codes by ICAR) have themselves contributed to the corruption of the standard by issuing transponders with custom codes in the country code field that have not been endorsed by ICAR (to Arowana fish breeders in Singapore), (Australian pet market), etc. and have volunteered to provide non-ISO compliant coding to entities issuing tenders for livestock ID. The proposed accommodation for the UK entity, as laid out in the enclosed two official WG3 documents, takes the corruption of the standard to a new and higher level. If even the supporters of the standard will not exercise the discipline required to conform to the rules they themselves have laid down for standards compliance, the ‘standard’ will quickly degenerate into a situation where ‘ISO 11784/85 transponders’ issued for various customers are not mutually readable, where customers buying cattle in a given market cannot be assured that the transponders in those cattle can be read by his or her reader... And we are back to where we started: various, mutually incompatible systems. However, there will be one key difference: the ID codes can be freely duplicated, in the field, by the end user, and, depending upon the situation, can even be changed and reprogrammed by the user, according to the requirements of the moment.