Dear all, I realised later in the discussion regarding the USB telephone that I was too short in my statement. It could be mis-interpreted when dealing with radio equipment. See the mail from Allan G. Carr. Therefore an addition to the scope discussion of the R&TTE directive:
As a principle all RADIO equipment falls under the scope of the R&TTE directive, not only radio-terminals but radio-equipment used in the PUBLIC NETWORK too (for example radio-links, point to point and -multipoint). There are exemptions, for example maritime radio equipment for "professional" use. If we speak about wire-connected telecom-equipment, only terminals are falling under this directive (as stated before; connected directly or indirectly by any means whatsoever to interfaces of public telecommunications networks) A last word regarding the consequences of the R&TTE directive for USB telephones. I hope that it is clear now that the requirements of the LVD (without voltage restrictions) and EMC directive are relevant, as a consequence of articles 3.1a and 3.1b. of the R&TTE . It could be done -for example- by self-declaration using "harmonised" standards. In addition the administrative requirements of the R&TTE are relevant (for CE marking, manual, packaging) Best regards, Theo Hildering KTL -----Original Message----- From: owner-emc-p...@ieee.org [mailto:owner-emc-p...@ieee.org] On Behalf Of H.T. Hildering Sent: 14 November 2000 10:07 To: Gary McInturff; 'Allan G. Carr'; emc-p...@ieee.org Subject: RE: FW: Compliance of a USB telephone Dear all, The R&TTE is meant for terminals. If my message was not clear enough I repeat here once again the R&TTE scope (see below). I disagree with Gary regarding his statement that an USB telephone, computers and other indirectly connected stuff are not falling under the R&TTE scope (connected directly or indirectly by any means whatsoever whatsoever to interfaces of public telecommunications networks). Just read for yourselves what is stated in the R&TTE and conclude for yourselves. >"telecommunications terminal equipment" means a product enabling >communication or a relevant component thereof which is intended to be >connected directly or indirectly by any means whatsoever to interfaces of >public telecommunications networks (that is to say, telecommunications >networks used wholly or partly for the provision of publicly available >telecommunications services); Perhaps you were confused by the former TTE directive. Indirectly connected equipment was excluded under that directive, but that's history now. Best regards Theo Hildering KTL -----Original Message----- From: owner-emc-p...@ieee.org [mailto:owner-emc-p...@ieee.org] On Behalf Of Gary McInturff Sent: 14 November 2000 00:01 To: 'Allan G. Carr'; emc-p...@ieee.org Cc: H.T. Hildering Subject: RE: FW: Compliance of a USB telephone Allen, I agree fully with you. The response below, and in particular "Only when it is IMPOSSIBLE to reach a public network, ..." is wrong for a couple of reasons, but principally ignores the obvious. The USB (and IP) phone is nothing more than a computer peripheral just like a printer or monitor and cannot reach the public phone system. Even if the signals did exit first the phone, then the computer, and then some IP switching system and if, and that is not a certainty, the signal is then sent through a metallic contact to the public phone system it is that interface that must meet the RTT&E directive. The phone is at least two devices removed from metallic access. More explicitly using the USB phone example. A USB interface doesn't connect to any public phone system, it can't. At a minimum it doesn't have the right connector. The device it plugs into, the computer itself, is also incapable, again as a minimum it doesn't have the right connector. In the best case an internally installed modem would be the first point at which the RTT & E directive can be applied. Even then one should not confuse what is actually being certified. It is the modem not the computer that is powering the modem that has to meet the requirements. Modem manufactures attest to the RTT & E regulations by using a computer in a type test but they sure don't test one of each type of computer that is manufactured in the world that happens to have a bus that will accept the modem. Following the "Only when it is IMPOSSIBLE...." dictum would say that all computers should meet the RTT&E directive because somebody MIGHT put a modem in them. Good for test labs, not so good for product prices. Nor should there be any concern that the public phone system is being left vulnerable. There indeed is a point at which all of these devices, USB, IP or whichever, MAY be routed to the public phone system through some metallic contact, but those devices at which that actually happens are subject not only to the RTT&E but FCC part 68 among others. If it doesn't look like a duck, and it can't quack then it probably isn't a duck. I have my asbestos underwear on - fire away. Gary -----Original Message----- From: Allan G. Carr [mailto:e...@agctel.co.uk] Sent: Monday, November 13, 2000 7:07 AM To: emc-p...@ieee.org Cc: H.T. Hildering Subject: Re: FW: Compliance of a USB telephone Theo I thought I should post the consensus of our discussion on the applicability of the R&TTE Directive for the avoidance of doubt by other readers of this newsgroup. The R&TTE applies to TERMINAL equipment - that is equipment connected on the subscribers side of the NTTP (Network Test and Terminal Point). Therefore a modem in a users home is covered by the R&TTE as would a modem used by a company that does not have a telecommunications operators licence. It does not apply to NETWORK equipment - that is equipment on the network side of the NTTP which is owned by the PTO (licensed Public Telecommunications Operator). Therefore an ISP's (Internet Service Provider's) modem, typically rack mounted and sited in the local exchange, is Network equipment and is not within the scope of the R&TTE. This difference may seem academic as there are no Telecommunications Terminal Equipment specifications designated under the R&TTE Directive and safety to EN 60 950 applies on both sides of the NTTP but the EMC specifications are slightly different. EN 300 386-2 "Electromagnetic compatibility and Radio spectrum Matters (ERM); Telecommunication network equipment; Electro-Magnetic Compatibility (EMC) requirements; Part 2: Product family standard" applies to Network equipment but not to Terminal equipment. Hope this helps Allan __________________ In article <EDFA411E5E4AD2118D6F00A0C99E4BAC01DF752E@FLBOCEXU02>, wo...@sensormatic.com writes > >Forwarding a reply > >---------- >From: H.T. Hildering [SMTP:h.t.hilder...@ktl.com] ><mailto:[SMTP:h.t.hilder...@ktl.com]> >Sent: Friday, November 10, 2000 11:49 AM >To: wo...@sensormatic.com <mailto:wo...@sensormatic.com> >Subject: RE: Compliance of a USB telephone > >Sorry for my late reply. >For applying the R&TTE directive, the intended use is the crux. I wander or >it is possible nowadays - if computers are connected to the internet- , to >deny that it is not intended for communication using the internet; for >example using Voice over IP! >I would say that every computer (and connected equipment), that can >communicate to the internet is falling under the scope of the R&TTE. >Consider for yourself what is stated in the R&TTE directive: >"telecommunications terminal equipment" means a product enabling >communication or a relevant component thereof which is intended to be >connected directly or indirectly by any means whatsoever to interfaces of >public telecommunications networks (that is to say, telecommunications >networks used wholly or partly for the provision of publicly available >telecommunications services); >Only when it is IMPOSSIBLE to reach a public network, the R&TTE is not >applicable. >The consequence for the USB telephone is that there are no restrictions on >the power voltage (as stated in the LVD), so the telephone must fully comply >with all the requirements as mentioned in the safety directive(for example >acoustical shock) > >Best regards, >Theo Hildering >KTL > > > >-----Original Message----- >From: owner-emc-p...@ieee.org <mailto:owner-emc-p...@ieee.org> >[mailto:owner-emc-p...@ieee.org] <mailto:[mailto:owner-emc-p...@ieee.org]> >On Behalf Of >wo...@sensormatic.com <mailto:wo...@sensormatic.com> >Sent: 02 November 2000 19:29 >To: ico...@itl.co.il; <mailto:ico...@itl.co.il;> emc-p...@ieee.org ><mailto:emc-p...@ieee.org> >Subject: RE: Compliance of a USB telephone > > >Let me see if I understand this product. It is a telephone like device that >is solely intended to be connected to the USB port of a PC and it is not >intended to be connected to the telephone network. >If this is true, then no telephone standards, regulations or directives >apply. Only the EMC directive applies in the EU. The RTTE directive does not >apply since the device is not intended to be connected to the telephone >network. The LVD does not apply since the source voltage is too low. >Compliance with safety requirements of EN60950 is sufficient to show due >diligence for the Liability Directive and General Product Safety Directive. > > > > Dear Group > > > > We are testing an PC telephone unit! > > > > It is a telephone terminal unit that connects to the USB port of >the PC from > > which it receives power. There is no other connection, just the >USB. > > > > Clearly this unit must comply with EMC requirements. Safety >requirements are > > not mandatory but clearly they are recommended to be performed >for >UL1950 > > for the US and EN60950 for Europe. > > > > Two questions: > > > > 1) What about Part 68 in the US? Since unit is not directly >connected to the > > PSTN officially it is exempt from the standard. (Acoustics tests >are covered > > under UL1950) > > > > 2) What about RTTE directive in Europe? There is no standard you >can test > > for. All of TBR 21 tests are not applicable. > > > > Thanks > > Ilan > > > > ---------------------------------------------------- > > Ilan Cohen > > Manager, Telecom Division > > I.T.L (PRODUCT TESTING) Ltd. > > 26 Hacharoshet St, POB 211, Or Yehuda, Israel. > > Tel 972-3-5339022, Fax 972-3-5339019 > > ico...@itl.co.il <mailto:ico...@itl.co.il> , website: >http://www.itl.co.il <http://www.itl.co.il> > > ---------------------------------------------------- > > > > ------------------------------------------- > > This message is from the IEEE EMC Society Product Safety > > Technical Committee emc-pstc discussion list. > > > > To cancel your subscription, send mail to: > > majord...@ieee.org <mailto:majord...@ieee.org> > > with the single line: > > unsubscribe emc-pstc > > > > For help, send mail to the list administrators: > > Jim Bacher: jim_bac...@mail.monarch.com ><mailto:jim_bac...@mail.monarch.com> > > Michael Garretson: pstc_ad...@garretson.org ><mailto:pstc_ad...@garretson.org> > > > > For policy questions, send mail to: > > Richard Nute: ri...@ieee.org ><mailto:ri...@ieee.org> > > > ------------------------------------------- >This message is from the IEEE EMC Society Product Safety Technical Committee >emc-pstc discussion list. >To cancel your subscription, send mail to: >majord...@ieee.org <mailto:majord...@ieee.org> with the single line: > unsubscribe emc-pstc >For help, send mail to the list administrators: > Jim Bacher: jim_bac...@mail.monarch.com ><mailto:jim_bac...@mail.monarch.com> > Michael Garretson: pstc_ad...@garretson.org ><mailto:pstc_ad...@garretson.org> > >For policy questions, send mail to: > Richard Nute: ri...@ieee.org <mailto:ri...@ieee.org> > >------------------------------------------- >This message is from the IEEE EMC Society Product Safety Technical Committee >emc-pstc discussion list. >To cancel your subscription, send mail to: >majord...@ieee.org <mailto:majord...@ieee.org> with the single line: > unsubscribe emc-pstc >For help, send mail to the list administrators: > Jim Bacher: jim_bac...@mail.monarch.com ><mailto:jim_bac...@mail.monarch.com> > Michael Garretson: pstc_ad...@garretson.org ><mailto:pstc_ad...@garretson.org> > >For policy questions, send mail to: > Richard Nute: ri...@ieee.org <mailto:ri...@ieee.org> > > > >------------------------------------------- >This message is from the IEEE EMC Society Product Safety >Technical Committee emc-pstc discussion list. > >To cancel your subscription, send mail to: > majord...@ieee.org >with the single line: > unsubscribe emc-pstc > >For help, send mail to the list administrators: > Jim Bacher: jim_bac...@mail.monarch.com > Michael Garretson: pstc_ad...@garretson.org > >For policy questions, send mail to: > Richard Nute: ri...@ieee.org > > -- Allan G.Carr B.Sc.(Elec.Eng) AMIEE | AGC-Tel Consultants Ltd Telecommunications Consultant | Tel: +44(0)141-956-2506 European Approvals Specialist | Fax: +44(0)141-956-5347 62 Crawford Road, Milngavie | Voice Mail: +44(0)1252-30-3062 Glasgow, G62 7LF, Scotland | http://www.agctel.co.uk ------------------------------------------- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher: jim_bac...@mail.monarch.com Michael Garretson: pstc_ad...@garretson.org For policy questions, send mail to: Richard Nute: ri...@ieee.org ------------------------------------------- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher: jim_bac...@mail.monarch.com Michael Garretson: pstc_ad...@garretson.org For policy questions, send mail to: Richard Nute: ri...@ieee.org ------------------------------------------- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher: jim_bac...@mail.monarch.com Michael Garretson: pstc_ad...@garretson.org For policy questions, send mail to: Richard Nute: ri...@ieee.org ------------------------------------------- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher: jim_bac...@mail.monarch.com Michael Garretson: pstc_ad...@garretson.org For policy questions, send mail to: Richard Nute: ri...@ieee.org
