In my opinion, you must issue a DoC according to the procedures specified in the RTTE Directive and all of the essential requirements of Article 3 must be addressed. Article 10 allows you to follow the conformity assessment procedures of the EMC and LV Directives for the essential requirements covered by those directives. I have followed that route and my DoC has three sections: safety, EMC and radio, and includes the following statements:
". . .conforms with the essential requirements for protection of health and safety of the user and any other persons by application of the following standards: [list of safety standards]" "and conforms with the essential requirements for electromagnetic compatibility by application of the following standards: [list of safety standards]" "and conforms with the essential requirement for effective use of the radio spectrum by application of essential radio test suites included in [reference of standard]" "and therefore complies with the essential requirements and provisions of the Radio and Telecommunication Terminal Equipment Directive, 99/5/EC, when installed according to the installation instructions and used as intended." Richard Woods Sensormatic Electronics Tyco International -----Original Message----- From: Kevin Harris [mailto:harr...@dscltd.com] Sent: Wednesday, March 06, 2002 12:28 PM To: EMC-PSTC (E-mail) Subject: R&TTE DoC Philosophy Question 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" ------------------------------------------- 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"
