Hi Grace There are other issues that may be involved but let’s address your specific question.
Labs are not actually ‘registered’ with a Notified Body except under annexes V and up. The intent of use for an NB proposed in your email is 1 - to give credence to the test suite under annex III or 2 - to give an opinion based on a review of the technical construction file under annex IV, or 3 – have the NB audit the quality system of the manufacturer so they (the manufacturer) can declare conformity under a full quality assurance process. Under annex III the notified body would assist the manufacturer in determining the appropriate test suite for the product. This could mean that the NB produces the test suite itself or that it ‘approves’ a test suite requested by the manufacturer. The directive itself simply states that it is the NB that has responsibility of identifying the appropriate test suite. It does not say how this identification is to be made. Thus the ability of the manufacturer to assess the test requirements and submit to the NB is not ruled out. In either case however, the options obviously require that the NB has a full and complete understanding of the product in order to either agree with the manufacturers assessment of testing or to establish a test suite itself. Under annex IV the notified body makes a determination of the appropriateness of the product to the essential requirements based on a thorough review of the TCF. While some may assume that a minimalistic review of only certain aspects of the TCF is needed and while NBs may put caveats in the opinion as only applying to documentation provided, the question then becomes, how can a reasonable assessment as to the appropriateness of the product to the essential requirements be done without a full and complete review of all documentation normally required in a complete TCF? Under annex V the notified body does a complete audit of the manufacturers quality assurance program, including test methods and other capabilities. This would be the only time that any lab registration would necessarily exist. Please note however, that it is not only the lab that is ‘registered’ but all aspects of the quality system that deals with the product line and its ability to meet all essential requirements. As to the specific frequencies you mention – you have not provided enough information for any reasonable position on what would be needed. Thanks Dennis Ward Evaluation Engineer American TCB Certification Resource for the Wireless Industry www.atcb.com 703-847-4700 fax 703-847-6888 direct - 703-880-4841 cell - 209-769-8316 NOTICE: This E-Mail message and any attachment may contain privileged or company proprietary information. If you received this message in error, please return to the sender. _____ From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Grace Lin Sent: 08/09/2006 10:24 AM To: emc-p...@ieee.org Subject: RTTE Conformity Assessment Procedure Dear Members, Please help me to understand the conformity assessment procedure per the RTTE Directive. Paragraph 4 of Article 10 of Directive 1999/5/EC states: "Where a manufacturer has applied the harmonized standard referred to in Article 5(1), radia equipment not within the scope of paragraph 3 shall be subject to the procedures described in any one of Annexes III, IV or V at the choice of the manufacturer." Annex III states: "For each type of apparatus, all essential radio test suites must be carried out by the manufacturer or on his behalf. The identification of the test suites that are considered to be essential is the responsibility of a notified body chosen by the manufacturer except where the test suites are defined in the harmonized standards. The notified body must take due account of previous decisions made by notified bodies acting together. The manufacturer or his authorized representative established within the Community or the person responsible for placing the apparatus on the market must declare that these tests have been carried out and that the apparatus complies with the essential requirements and must affix the notified body's identification number during the manufacturing process." I don't understand the first paragraph of Annex III. My question is: do I need to have my lab (in a manufacturer) registed with one of notified bodies to be considered to be essential? If not, what is the marking requirement, "CE" ( 433.92MHz) or "CE plus alert sign" (2.4GHz SS), or others? Thank you very much for your time and look forward to your help. Best regards, Grace Lin Sr. Compliance Engineer Crestron Electronics, Inc. 6 Volvo Drive Rockleigh, NJ 07647 g...@crestron.com www.crestron.com - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. 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