Agreed. So, in Peter's case, he stated that his product is SELV and
therefore is not designed or intended to connect to the PSTN. From that
statement, I would venture to say that his product is Network Equipment (not
CPE) and therefore does not fall within the scope of the R&TTE Directive.
Thx,
Joe
-----Original Message-----
From: Paul Didcott [mailto:pdidc...@ktl.com]
Sent: Wednesday, October 02, 2002 3:59 AM
To: 'Joe Finlayson'
Cc: 'Richard Hughes'; 'EMC PSTC'; 'NEBS Newsgroup'; 'TREG Newsgroup'
Subject: RE: RTTE or LVD for Equipment with E1 SELV interface
Guys,
>>As this product does not connect to the PSTN and is destined for the
Central Office only, I would say the R&TTE Directive does not apply as the
scope does not include Network Equipment.
Correct.
>>It will be seen from the above that the R&TTED is not limited to PSTN
since it is quite possible that a network operator could provide a business
with an E1 interface, for instance.
Correct. The R&TTED applies to terminal equipment which connects to any
public service of the network operator, whether that be a leased line
service or PSTN service.
>>"Public" telecommunications network is included in the scope of the R&TTE
Directive
Incorrect. The R&TTE scope statement, "intended to be connected directly or
indirectly by any means whatsoever to interfaces of public
telecommunications networks", only relates to TE, not network equipment.
The term 'indirect' simply means via another piese of equipment, e.g. such
as a telephone connected to a PBX which connects to the public telecom
network. Hence equipment connected behind PBX falls within the scope of the
R&TTED, for example.
As has been mentioned, the LVD and EMC Directives & CE marking still applies
to equipment destined for use only 'within' the public network, for EU/EFTA
Member countries.
Hence, E1 equipment desined for connection to a public telecom network
service, must be CE marked for compliance with the R&TTED. However, the
applicable standards will be exactly the same for EMC and Safety compliance
under the R&TTED as would apply under the EMC Directive and LVD.
Hope this helps,
B-regards,
Paul G Didcott
Snr Approvals Consultant
Tel: +44 (0)1482 801801
Mailto:pdidc...@ktl.com <mailto:pdidc...@ktl.com>
KTL is now fully recognised by the DSL Forum as an Independent Testing
Laboratory (ITL).
Laboratory Accreditation Services Ltd t/a KTL. Registered No. 4407692.
Registered Office:
KTL, Saxon Way, Priory Park West, Hull, HU13 9PB, UK. www.ktl.com
<http://www.ktl.com> "
-----Original Message-----
From: Joe Finlayson [mailto:jfinlay...@telica.com]
Sent: 01 October 2002 23:15
To: 'Richard Hughes'; 'EMC PSTC'; 'NEBS Newsgroup'; 'TREG Newsgroup'
Subject: RE: RTTE or LVD for Equipment with E1 SELV interface
Richard,
Good point - the "directly or indirectly" part grabbed my attention
but that seems too broad a description which could encompass quite a wide
range of equipment. However, the point of discussion here is whether a
product classified as SELV by IEC 60950, Type 2 by GR-1089, etc. and does
not connect (interface) to the "Public" telecommunications network is
included in the scope of the R&TTE Directive. This type of product resides
in the network and does not connect to outside plant conductors - terminates
to another piece of equipment with the proper isolation to outside plant
conductors. My interpretation is that if there is no provision for physical
connection to the PSTN, the R&TTE does not apply.
Any takers??? I'll copy the TREG and NEBS gurus on this one as well.
Thx,
Joe
-----Original Message-----
From: Richard Hughes [mailto:rehug...@nortelnetworks.com]
Sent: Tuesday, October 01, 2002 5:57 PM
To: 'Joe Finlayson'; "EMC-PSTC (E-mail)" <
Subject: RE: RTTE or LVD for Equipment with E1 SELV interface
Joe,
The R&TTED applies to the following types of equipment:
1) Radio equipment
2) Terminal equipment.
The Directive also contains the following definitions:
'telecommunications terminal equipment' means 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
public telecommunications networks (that is to say, telecommunications
networks used wholly or partly for the provision of publicly available
telecommunications services).
'interface' means
(i) a network termination point, which is a physical connection point at
which a user is provided with access to public telecommunications network,
and/or
(ii) an air interface specifying the radio path between radio equipment
and their technical specifications
It will be seen from the above that the R&TTED is not limited to PSTN since
it is quite possible that a network operator could provide a business with
an E1 interface, for instance.
Peter,
It is for the manufacturer to decide to which market, e.g. terminal
equipment or central office equipment only, they whish to sell their product
into. EN 60950 has nothing to do with it since this standard can be used to
evaluate either type of product - and other non-telecom ICT products as well
of course.
Simplistically, if the product does not have an input or output voltage in
the range 50-1000Vac, 75-1500Vdc then the LVD does not apply {ref. Article 1
of LVD}. Clearly, if the LVD does apply then certain editions of EN 60950
do provide a presumption of conformity with the safety objectives of the
LVD. If the LVD does not apply then that should not be taken as an excuse
to not comply with EN 60950, but that's another debate entirely.
If the R&TTED applies then the EMC is not applied as such, because the EMC
requirements are then covered by the R&TTED. However, this is largely an
administrative technicality because Article 3(1)(b) points to the EMC
Directive for its essential requirements, just as Article 3(1)(a) points to
the LVD for safety (minus any upper or lower voltage limit).
Well, that's enough personal opinions expressed on this matter for me...
Richard Hughes
-----Original Message-----
From: Joe Finlayson [ mailto:jfinlay...@telica.com
<mailto:jfinlay...@telica.com> ]
Sent: 01 October 2002 17:52
To: "EMC-PSTC (E-mail)" <
Subject: RE: RTTE or LVD for Equipment with E1 SELV interface
Peter,
As this product does not connect to the PSTN and is destined for the
Central Office only, I would say the R&TTE Directive does not apply as the
scope does not include Network Equipment.
Thx,
Joe
-----Original Message-----
From: Peter Merguerian [ mailto:pmerguer...@itl.co.il
<mailto:pmerguer...@itl.co.il> ]
Sent: Tuesday, October 01, 2002 9:33 AM
To: "EMC-PSTC (E-mail)" <
Subject: RTTE or LVD for Equipment with E1 SELV interface
Dear All,
For an equipment where the E1 has been assessed for SELV under EN 60
950 (ie for intrabuilding use and not subject to overvoltages), does the
equipment fall under the RTTE Directive or can the manufacturer declare
compliance to the LVD and EMC Directives.
If under the RTTE Directive, what telecom standard applies to the E1
intrabuilding interface?
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