I agree. We use the same  "regulatory ID" number on a product which include
variants not affecting the rf properties.  We see no reason to apply to the
Notified Body for an opinion of compliance nor to notify the PTTs when a new
variant is marketed where the rf properties have not changed. That new
variant will have the same ID number that was previously notified to the
PTTs, 

Richard Woods

----------
From:  Kevin Harris [SMTP:harr...@dscltd.com]
Sent:  Thursday, January 11, 2001 10:35 AM
To:  EMC-PSTC (E-mail)
Subject:  R&TTE Directive Notification Period


Hello Sages,

I am trying to assess what could possibly happen under the following
scenario for the notification period. Lets say I had some SRD devices that
have gone through the notification period without comment. At some later
point I decide to introduce further devices in the line. The radios are not
identical schematically but all the RF characteristics are identical,
including "percentage on" time. The new devices are all type tested, EMC and
safety tested in exactly the same manner as the devices previously notified
and will be used in the same application. My proposal at that point would be
to not wait for 4 weeks to expire on notification but to market the devices
immediately. My reasoning for this is that a country can only object to a
device being marketed on "harm to the network" and then follow the procedure
in Article 9.5 for banning the device. Since they did not happen previously,
they cannot object now. I know that attitude might put some regulatory noses
out of joint but does anyone see a problem with the argument.


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> 

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