Both solution are valid.
In the R&TTE you can find an article said that at your choice you can
demonstrate the conformity to the essential requirements 3.1b
using the procedure of the EMC directive if applicable.
I don't suggest this, for me, complicate way two declaration two
documentation..........
You can demonstrate the compliance of the equipment to the essential
requirements 3.1a using HS listing on the OJ under the R&TTE directive or
under the EMC directive this is clearly wrote on the note of the OJ:
NOTES:
1. In addition, standards published under Directives 73/23/EC and
89/336/EEC may be used to demon-
strate compliance with Articles 3(1)(a) and 3(1)(b) of Directive 1999/5/EC.
And make only one DoC for the R&TTE directive using the standards of the EMC.
But I don't understand the reason to use the standard of the EMC directive
for a R&TTE equipments.
Ciao
Paolo
At 12:27 3/6/02 -0500, Kevin Harris wrote:
Hello,
I just had an interesting conversation with the head of a approvals
authority for a country in Europe for our type of products. The discussion
centred around DoCs for the R&TTE directive. His claim was since I had a
product that has a R&TTE element to it then I just make a declaration to the
R&TTE directive and not to the EMC directive. To support his claim he refers
to Article 3.1(b) of the R&TTE directive which states "1.The following
essential requirements are applicable to all apparatus" and part (b) "the
protection requirements with respect to electromagnetic compatibility
contained in Directive 89/336/EEC. His interpretation is, then, that any
standard published in the OJ for the EMC standard is (by this clause) also
valid for the R&TTE directive and one should make their declaration
accordingly.
My interpretation of this statement is slightly different. I believe that I
cannot make an R&TTE directive DoC using EMC published standards. I felt
that the intention of this clause meant that just because you are declaring
to the R&TTE directive you are in no way relieved of the obligations of the
EMC directive. Accordingly we produce a EMC declaration and a R&TTE
declaration. The EMC declaration uses standards published in the EMC OJ to
show compliance and the R&TTE directive DoC is to the standards published in
the OJ for that directive.
In the end I suppose this is all semantics as you end up doing the same test
suite regardless but........
What are the feeling of this group. Do you agree with either position? Do
you have another interpretation?
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
-------------------------------------------
This message is from the IEEE EMC Society Product Safety
Technical Committee emc-pstc discussion list.
Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/
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:
Ron Pickard: emc-p...@hypercom.com
Dave Heald: davehe...@mediaone.net
For policy questions, send mail to:
Richard Nute: ri...@ieee.org
Jim Bacher: j.bac...@ieee.org
All emc-pstc postings are archived and searchable on the web at:
http://ieeepstc.mindcruiser.com/
Click on "browse" and then "emc-pstc mailing list"
----------
Paolo Gemma
Siemens Information and Communication Network spa
Microwave Networks MW R&D NSA EMC
SS Padana sup. KM 158 20060 Cassina de'Pecchi (MI) Italy
phone +39 02 9526 6587 fax +39 02 9526 6203
mobile +39 348 3690185
e-mail paolo.ge...@icn.siemens.it
----------
