All,
Now, I have to chime in too. Article 12 (1) of the Directive states,
"Where the procedures identified in Annex III, IV, or V are used, the
marking [CE] shall be accompanied by the identification number of the
notified body..."
The Directive Introduction (31) states, "...manufacturers should notify
Member States of their intention to place radio equipment on the market
using frequency bands whose use is not harmonised throughout the
Community;..."
Article 6 (4) states, "...radio equipment using frequency bands whose use
is not harmonised throughout the Community, the manufacturer or his
authorised representative established within the Community or the person
responsible for placing the equipment on the market shall notify the
national authority responsible in the relevant Member State for spectrum
management of the intention to place such equipment on its national
market."
There is no stated exception for testing to harmonized standards. If a
particular frequency or frequency band is not harmonized, a Notified Body
must issue a Certificate of Conformity and each Member State must be
notified 4 weeks prior to placing the product on the market in each
country. This is true even if only one Member State disallows a frequency.
Frank de Vall
Manager Compliance Engineering
Assa Abloy ITG
stillin...@aol.com
Sent by: To:
gera...@zoom.com, richwo...@tycoint.com,
owner-emc-pstc@majordo
emc-p...@majordomo.ieee.org
mo.ieee.org cc:
Subject: Re: R&TTE
Directive Member States Notification
07/01/2003 04:02 PM
Please respond to
Stillingsl
Gerald, Richard, All
Ok, I have to chime in here. You do not need a Notified Body when
there is a Harmonized Standard published in the OJ. I understand that the
frequency is not harmonized (france because of their Military band), but
there is a harmonized standard and therefore no Notified Body is needed,
period. The point of the Notified body and number on the form is when there
is no harmonized standard and at this point I don't see how that could
happen with respect to Short Range Devices (SRDs) since the publication of
the three generic standards EN 300 220, EN 300 330 and EN 300 440 covers
basically 9 kHz to 40 GHz SRDs.
Europa's web site has more information on this at
http://europa.eu.int/comm/enterprise/rtte/infor.htm
Harmonised standards
The easiest route to demonstrate compliance with the Directive is to comply
with Harmonised Standards. For this Directive these are developed mostly by
ETSI. Some safety and health standards have been developed by CENELEC. The
3rd European Standardisation Organisation (CEN), doesn't cover this sector.
These standards are developed upon a request from the European Commission
and once adopted are published by the European Commission in the Official
Journal of the European Union (OJEU).
Notified bodies
When harmonised standards aren't available or when a manufacturer considers
them inappropriate for his product, he must seek the opinion of an
independent 3rd party, a notified body. These are appointed by the Member
States after having proven that they have the relevant expertise to provide
such an opinion. Although a Notified Body has various responsibilities
under the Directive, the manufacturer (or authorised representative) always
remains responsible for the compliance of the equipment.
Larry K. Stillings
Compliance Worldwide, Inc.
357 Main Street
Sandown, NH 03873
(603) 887 3903 Fax 887-6445
www.complianceworldwide.com
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