An RJ-45 connector used by an IP phone does not plug into an RJ-11 POTS 
line. So it can't be simple plug into the pots lines. It would take conscious 
intent and electrical knowledge to make it fit, beside being an illegal 
modification of the product. The proper standard for an ITE device is EN60950 
(and EN55024)and it addresses the connection of the RJ-11 into the RJ-45 
connection which will work through markings  similar to what you suggest below 
from the RTT&E.  
    No RTT&E required or the extra time and expense, and the vacuous no matter 
how indirectly needs to be re-written or just plain struck out of the standard.
    Gary
 
    

[Gary McInturff] 
 
 -----Original Message-----
From: david_ster...@ademco.com [mailto:david_ster...@ademco.com]
Sent: Thursday, December 05, 2002 7:09 AM
To: rehug...@nortelnetworks.com; alan.hud...@amsjv.com; 
emc-p...@majordomo.ieee.org
Subject: RE: CE for IP Phone



Alan,
If the device looks like a telephone and can easily be connected to the POTS 
(e.g. RJ-11 or RJ-45), you can assume someone will try to connect it to the 
telephone network.  So due diligence means R&TTE testing and marking, if only 
to warn via the 'alert' symbol that the device does not comply.
 
Re:  Walkman-type headphones and PC microphones.  
Direct wiring to POTS requires electrical expertise, and a conscious intent to 
make an illegal connection.  Manufacturer's liability for an illegal connection 
is quite low in this case.
 
David Sterner

-----Original Message-----
From: Richard Hughes [mailto:rehug...@nortelnetworks.com]
Sent: Thursday, December 05, 2002 7:45 AM
To: 'alan.hud...@amsjv.com'; emc-p...@majordomo.ieee.org
Subject: RE: CE for IP Phone



Alan, 

_IF_ your product is covered by the R&TTED _THEN_ there is no lower voltage 
limit for safety (or anything else).  In fact, this is also true for the upper 
voltage limits.  Therefore, the R&TTED applies to mobile 'phones even though 
they are powered from 3V batteries.  If you invented some equipment covered by 
the R&TTED that was powered directly off a 60 kV MV line then that would be 
covered too.  

However, 

If your product IS NOT covered by the R&TTED THEN the existing voltage limits 
continue to apply when considering the LVD.  There are therefore many examples 
of network infrastructure equipment which are not covered by either the R&TTED 
or the LVD, typically they are CE marked to show compliance with the EMC 
Directive.

I know that some people have the mistaken belief that the R&TTED somehow 
modified the voltage limits of the LVD.  This is not so, the R&TTED did not 
modify the LVD.  

Certainly, the European Commission are considering revising the LVD and one of 
the things they are looking at is the removal of the lower voltage limits (they 
are presently not suggesting the removal of the upper voltage limits).  
However, these discussions are still in the early stages - so it wouldn't be 
too good an idea to start making changes to your compliance strategy on the 
basis of possibilities.

Hope all is now clear. 

Richard Hughes 

-----Original Message----- 
From: alan.hud...@amsjv.com [ mailto:alan.hud...@amsjv.com] 
Sent: 05 December 2002 10:56 
To: emc-p...@majordomo.ieee.org 
Subject: Re: CE for IP Phone 
Importance: High 




Richard Hughes said: 

++ Moreover, since the said telephone is connected only to an SELV 
Circuit then 
++ it falls below the lower voltage limits of the LVD (50 Vac, 75 Vdc) 
and so 
++ the LVD does not apply.  


I thought the RTTED referral to the LVD removed the voltage limits of 
the latter? That is, under the RTTED even battery-operated portable 
equipment then came under its LVD requirements. 

I'm quite happy to be proven wrong of course, as I'm no expert on either 
Directive. 

Regards, 

Alan 

EMC Consultant 
Alenia Marconi Systems 
Scotland 

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