On 9/21/2007, Piotr Galka wrote:


As I understood if the factory has its own Ethernet net than (terminal)
devices destined to be connected to such net are not under the scope of RTTE
directive because their owner connects them to his own net. Right ?
But what if their internal net is also connected to the global Internet ?
Do such devices become to be "terminal equipment" (under RTTE) because their
owner is not also the owner all Internet ? 



Hi Piotr:

I think these distinctions have been discussed and debated in the past by
others on this board, and I'm not sure I want to get too involved interpreting
hypothetical scenarios.  For what its worth, my view is that a private
Ethernet network, such as a network used only internally by a private
corporation, is clearly not subject to the RTTE.

I also don't think that adding an Internet connection to this network
automatically makes it subject to the RTTE, because in my view the Internet is
not a "public telecommunications network" as defined in the RTTE.  Others may
disagree with me and my interpretation may in fact be wrong.

In my view, the only way that the RTTE would enter the picture via the
Internet connection is if the internal, private network was connected to the
Internet via the public telecommunications network, such as a T1/E1 line. 
Even in that case, though, my view is that the only piece of equipment subject
to the RTTE would be the device that contains the T1/E1 port.

There is plenty of room for varying interpretations here, since the RTTE
directive defines TTE as, "a product enabling communication or a relevant
component thereof which is intended to be connected directly or indirectly by
any means whatsoever to interfaces of the public telecommunications network."

I think that common sense has to be used in interpreting this ambiguous
definition, and interpretations may vary.  Keep in mind, though, that there is
probably very little material effect from declaring a product to be ITE or TTE
if in fact the equipment has no direct connection to the public
telecommunications network.  I would be inclined to call such a product ITE,
but I'm not sure if the actual tests that would apply would be any different
if it was called TTE.




Joe Randolph
Telecom Design Consultant
Randolph Telecom, Inc.
781-721-2848 (USA)
j...@randolph-telecom.com
http://www.randolph-telecom.com <http://www.randolph-telecom.com/> 

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