Non-ECM image data rate adaption deals with exchanging TCF data, and non-ECM image data using T.4 1-D or 2-D compression. Non-ECM image data is typically padded with zero bits at the end of each pixel row. This is used to avoid rows arriving at the receiving FAX machine faster than the mechanical paper handling can process them. It is also used by sending FAX machines for flow control, when their paper handling falls behind. The minimum duration of a row is negotiated between the FAX machines, before image transfer commences.

TCF data is a continuous stream of zero bits. It may, optionally, be preceeded by a continuous block of one bits. So, when transferring TCF data between the T.38 entities, flow control is simply a matter of repeating the last received bit when the late arrival of TCF data packets causes underflow at an emitting gateway.

T.38 entities may negotiate to generate and check TCF data locally, and not exchange it. Generally, this is only used when TCP/TPKT is used as the transport for the T.38 messages. A TCF checker and a TCF generator are needed by a T.38 gateway supporting this option.

Some T.38 entities are capable of negotiating the removal of end of row padding bits in the data passing between the T.38 entities. This may reduce the amount of data significantly, for some types of image. If negotiated, most or all surplus zero bits are stripped from the image bit stream, at the sending T.38 entity. If a T.38 gateway is receiving such stripped data, it may need to reimpose a minimum row time, by inserting zeros, as part of its non-ECM rate adaption process. By checking the contents of the DCS messages, it can determine what this minimum should be.

Only two types of image compression are used for non-ECM transmission - T.4 1-D and 2-D. The end of line (EOL) marker for both these is 11 zero bits, followed by a one bit. In 2-D mode, an additional one or zero bit follows, which defines the mode of the next row. It turns out that the maximum number of valid consecutive zeros which could preceed the 11 zeros of an EOL is 3. In a valid image there are no longer runs of zeros than at an EOL, and the maximum there is 14. Therefore, if the padding stripper reduces all runs of zeros longer than 14 to just 14, it will strip most of the padding with very simple logic. Simple logic is a good thing in this case. It not only avoids the need to fully analyse the image data, it also minimises problems when there are bit errors in the image data stream.

For image data sent without error correction (T.4 1-D or 2-D) there may be underflow at the outgoing gateway, if image data packets arrive too late. To deal with slow mechanical paper handling in FAX machines, the T.30 specification includes an end of pixel row padding scheme for non-error corrected image data. The receiving machine may request a minimum row duration. The sending machine is required to impose that minimum, but can arbitrarily make it much longer to meet its own paper handling needs, sending padding bits as appropriate. This mechanism provides a robust basis for flow control in a T.38 gateway. If the outgoing gateway only starts sending a pixel row when it has the entire row in its buffer, it can safely idle, sending padding bits, at any row end it needs to. Only the 6 EOL markers, which terminate an image, must be protected from this kind of flow control. Those markers are defined as being consecutive, with no zero bit padding separating them.

When ECM is used (usually with T.6 image data) the image is packetised in HDLC frames. In this case rate adaption is handled in a similar manner to the V.21 HDLC packets.