Hi Lauren, Sorry for the quick mail and lack of exact references but I'm in a rush today......
Firstly, remember that there is no "R&TTE certified". A product (like a wireless keyboard) might be CE Marked with a DoC based on the intended use. If you incorporate that product into another product...... You might have created a whole new product, which might need CE Marking. Or, you might just be creating a system; such as the Laptop/Monitor/Printer/Keyboard/Mouse octopus that I have on my desk before me, with the device being used in its intended use. If you look at the annexes at the back of EN 301 489-1 V1.9.2, you'll find all sorts of useful guidance on combining equipment. That's where I'd look first. For example, we often see wireless devices with a USB connector. By itself, many of the EMC equipment might not be applicable (less than 3m long cables, etc.), but EN 301 489-1 confirms which tests should be performed with that device connected to a typical host (such as a laptop), which could make the tests suddenly applicable (I think conducted RF immunity, etc). For your wireless keyboard issue, you really need to consider if you are just selling a system with the keyboard used correctly as a part of it; or if you have created a whole new product. I know that Charlie Blackham is on this reflector and I'll bet he could give a good answer about the 'larger scale' compliance management of complex systems. :-) Sorry for my lack of time today! Michael. -----Original Message----- From: Crane, Lauren [mailto:lauren.cr...@kla-tencor.com] Sent: 12 May 2015 00:11 To: Michael Derby; EMC-PSTC@LISTSERV.IEEE.ORG Subject: RE: [PSES] Integrating radio COSTs into other equipment Michael, Do you think this applies to the case for installing a finished product? For example if I make and industrial machine and "install" a wireless keyboard that is already RTTE certified, have I created a new item (i.e. the machine) that must be assessed for RTTE conformance? I think the common sense answer is 'no', but Commission and ETSI guidance does not seem to address this scenario. Regards, Lauren Crane KLA-Tencor -----Original Message----- From: Michael Derby [mailto:micha...@acbcert.com] Sent: Monday, May 11, 2015 6:10 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Integrating radio COSTs into other equipment Hello Amund, This is a general reply about installing CE Marked radio modules into host products...... The important thing to remember is that there no certification process under the R&TTE Directive and also no "modular approvals". Anyone installing the module into a product becomes responsible for the compliance of the overall product, with the R&TTE Directive. Radio, EMC, Safety. It's possible to imagine cases where the test results for the radio performance (made by the module manufacturer, on the module) could be used to show compliance of the overall final product. For example, if the module is installed ok in accordance with manufacturer's instructions, you could imagine that the power, frequency, etc., should not be changed. Many module installers rely on most of the tests in the radio test report of the module for their compliance to Article 3.2 of the R&TTE Directive. For radiated emissions of the transmitter module (also Article 3.2) in the final product, I know that most module manufacturers recommend that the final host product should be re-tested and I certainly think this is a good recommendation. Anyone who has tested emissions of final products with modules installed will know that the emissions from the module can sometimes fail when installed in a host. For EMC and Safety, it is very difficult (impossible?) to imagine that any tests of the module might be representative of the radio's performance inside a host; so the host should really be treated as a new product for testing to standards like EN 301 489-7, EN 301 489-24, product safety, etc. Finally; I see an incredibly wide variation in testing approach from module manufacturers for CE Marking a module. Just because it is CE Marked, does not mean they have fully tested it for every possible installation! This link is very useful...... http://www.rtteca.com/TGN01%20-%20May%202013.pdf Michael. -----Original Message----- From: Amund Westin [mailto:am...@westin-emission.no] Sent: 11 May 2015 07:55 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] Integrating radio COSTs into other equipment RTTE approved 3G GSM module (EN 301 511) is integrated into an EN 61326-1 measurement product. Maybe this call for new radio tests such as radiated spurious emission. Anyone have experience about the consequences integrating such radio COTS? Regards Amund - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. 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