Hi Richard, I think it all becomes a moot point on Feb 7. I was looking at the ETSI site yesterday and they indicate there that EN 300-220-3 will be published in the OJ for the R&TTE directive on that date. EN 300-220-3 is the harmonised EN covering the essential requirements under Article 3.2 of the directive
Best Regards, Kevin Harris Manager, Approval Services Digital Security Controls 3301 Langstaff Road Concord, Ontario CANADA L4K 4L2 Tel: +1 905 760 3000 Ext. 2378 Fax +1 905 760 3020 Email: harr...@dscltd.com <mailto:harr...@dscltd.com> -----Original Message----- From: wo...@sensormatic.com [mailto:wo...@sensormatic.com] Sent: Wednesday, January 31, 2001 12:43 PM To: emc-p...@majordomo.ieee.org Subject: RTTE & Placing in Service Consider a low power radio transmitter subject to EN 300 220 that is to be used only by the manufacturer's service organization and will not be placed on the market for sale. EN 300 220 is a harmonized standard, but the operating frequency is not harmonized. It appears that the provisions in Article 6 do not apply since the product will not be placed on the market. Article 7 contains the provisions for putting into service. Notification to the spectrum authorities (from Article 6) does not appear to be a requirement even though the frequency is not harmonized. It appears that it is sufficient to comply with the essential requirements and apply the CE marking which must include the alert symbol per Annex VII since the frequency is not harmonized. A member state may restrict the placing in service, but only for the three reasons specified in Article 7.2: efficient use of the spectrum, interference and public health. It appears there is no legal requirement to notify the state prior to placing in service. Thus, any restriction would occur due to the state determining that one of the three reasons apply to one or more devices after it being placed in service. While it may be argued that it is a good idea to notify the states anyway, it does not appear to be a legal requirement. Comments? Richard Woods ------------------------------------------- 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