Re: [Elecraft] CE labels, band limits - no thanks!
Ian White GM3SEK wrote: Short version. The more serious danger comes from within - from people inventing restrictions where none actually exist. Self regulation is a standard way of avoiding restrictive legislation. Legislation that doesn't need some interpretation is generally too inflexible to be good legislation. Community market. Certain components or sub-assemblies should, under OK. It looks like the kit exemption definitely doesn't apply, but note that Elecraft are selling kits, not sub-assemblies, it is just that the kits aren't made from components. The general effect of your reply has been to make me more certain that Elecraft are on dodgy ground unless they have actually consulted with the relevant European authorities. Incidentally, I'm sure the CE approval on the pre-assembled K3 will be on the basis of the amateur radio interface definition, so will only be valid for operation on the frequencies that form that definition. That doesn't require the frequency coverage to be restricted (although BR68 certainly did, for certain licence classes, and I believe that is still the intent, even if the way it is now worded is rather opaque. -- David Woolley Emails are not formal business letters, whatever businesses may want. RFC1855 says there should be an address here, but, in a world of spam, that is no longer good advice, as archive address hiding may not work. ___ Elecraft mailing list Post to: Elecraft@mailman.qth.net You must be a subscriber to post to the list. Subscriber Info (Addr. Change, sub, unsub etc.): http://mailman.qth.net/mailman/listinfo/elecraft Help: http://mailman.qth.net/subscribers.htm Elecraft web page: http://www.elecraft.com
Re: [Elecraft] CE labels, band limits - no thanks!
Incidentally, I'm sure the CE approval on the pre-assembled K3 will be on the basis of the amateur radio interface definition, so will only be valid for operation on the frequencies that form that definition. That doesn't require the frequency coverage to be restricted (although BR68 certainly did, for certain licence classes, and I believe that is still the intent, even if the way it is now worded is rather opaque. 3 points: 1) The CE Marking is involves self-certification and not approval by a regulator or other third party. 2) Imho, the CE Marking for the K3 would have to apply to frequencies out side of the HAM bands (e.g. KBPF3 is installed) or be invalid in some configurations. 3) The CE Marking does not require band limits on the TX but some countries on the planet Earth do. Afaik some of them check for the band limits on equipment entering the country and confiscate rigs without the correct limiting. I remember reading mails on the reflector from hams who had high hopes for the K3 because Elecraft was implementing band limits for their country. So back to my original question: What happens if my K3, with US band limits, wants to accompany me to such a country? Do you need to get a special version of the FW from Wayne Eric? vy 73 de toby ___ Elecraft mailing list Post to: Elecraft@mailman.qth.net You must be a subscriber to post to the list. Subscriber Info (Addr. Change, sub, unsub etc.): http://mailman.qth.net/mailman/listinfo/elecraft Help: http://mailman.qth.net/subscribers.htm Elecraft web page: http://www.elecraft.com
Re: [Elecraft] CE labels, band limits - no thanks!
Kristinn Andersen wrote: Regarding the CE issue I believe that radio amateurs, who need to pass tests for their license to operate, construct and modify their own A number of questions asked on this list about the K2 indicate that there are people building the K2 who are unable to read and interpret a circuit diagram. Even I wouldn't be able to deduce all the design decisions that went into making the equipment compliant, and they are not documented in the public domain, so I can't look them up. framework of the Constitution and Convention of the ITU [8], unless the equipment is available commercially. Kits of components to be Elecraft products are available commercially. My interpretation of components is electronic components, i.e. resistors, capacitors, transistors, etc. Elecraft interpret it as being a noise word, with only kit being effective (although they would acccept that a combination of base unit, PA and ATU isn't a kit for that legislation. (I once read something to the effect that, when reading legal documents, every word counts.) I think that the legislators are thinking more in terms of making it possible for me to order all the components for a published design by ordering the RadCom XYZ component set, rather than having the supplier send me the exact same set of components because I had enumerated them individually (however note that the UK licence does give an advantage to those cases where the kit is supplied as a whole, with the design). assembled by radio amateurs and commercial equipment modified by and Commercial equipment would have been compliant in its original use. for the use of radio amateurs are not regarded as commercially available equipment. I think it is very important that we amateurs don't give in on this issue. Our privileges are hard earned through our testing and The danger is that if commercial sellers try to find loopholes, in closing the loopholes the legislators may restrict things that were not previously restricted. In many cases the commercial vendor has made their profit before the legislation gets fixed, so their cash flow is good. licensing process, they are actually recognized in international regulations, and if the officials who execute the laws don't know better, they need to be informed and put back on track. They are only there because the people who make the laws believe that there is a benefit to the public in amateur radio. I don't think that is based on a simple freedom argument, I think it is based on encouraging people into engineering and technical careers, general self education, the ability to provide emergency communication, and providing a potential source of military operators. I'm not sure that the last one is so valid these days. Historically, a lot of the basic radio propagation research was done by amateurs, but I think that is becoming less relevant to the economy. As such, from the legislators point of view, there is no fundamental need to protect amateur radio operators from legislation, so they will always be making cost benefit tradeoffs. Regarding band limits, I think we should not be required to limit our equipment there, either. Nor should we by any means ask for such In the UK, only those with full licences are permitted to use unrestricted equipment, and I am not aware that the ban on the import and sale of certain equipment that could be used illegally on CB frequencies has been removed. Other classes of licensee are allowed to use commercial kits, like the K2, provided they are frequency restricted. (The current UK licence drafting is confusing in this respect, but I don't believe any change in effect was intended from the previous, more direct, wording.) The US has a particular limitation on receive capabilities, although it doesn't affect Elecraft products, in that reception on the cellular radio frequencies is prohibited in commercial products which are not standard cellular phone products. However, the real issue with the current question was that it is a serious criminal offence to possess equipment operating outside of the amateur frequencies in some countries to which people often want to take equipment on holiday. That's typically because there is some separatist organisation that uses radio to coordinate military operations. limitations ourselves! By the nature of our hobby we are trusted to build our radio oscillators, amplifiers and other equipment, which In the UK, only full licensees are so trusted, and I think it might be better to say that we are trusted to know our own limits. The examinations show that we understand the issues, but don't make us fully fledged RF designers. technically may be able to radiate all over the spectrum, but it is our responsibility - and we should live up to that responsibility - to make sure that our emissions are within the regulations in effect in our countries. Not
Re: [Elecraft] CE labels, band limits - no thanks!
I think the main argument against these regulations and particularly the band restrictions is that they insult our intelligence. Presumably the bureaucrats believe that the fact that, out of the box, a transceiver is restricted to certain bands, means it cannot be used on other frequencies. But *we* know that it is easy to disable these restrictions - with the FT-817, for example, transmit locking can be removed simply by writing to an internal register, and you can freely download a small program from the internet to do it. I think Simon's FT-817 Commander can even do it. It beggars belief that the potentially malicious users of this equipment don't know this too. And other radios can presumably have their band limits changed or removed with equal ease. So exactly what, in practise, do these restrictions achieve? -- Julian, G4ILO K2 s/n: 392 K3 s/n: ??? G4ILO's Shack: www.g4ilo.com Zerobeat Ham Forums: www.zerobeat.net/smf ___ Elecraft mailing list Post to: Elecraft@mailman.qth.net You must be a subscriber to post to the list. Subscriber Info (Addr. Change, sub, unsub etc.): http://mailman.qth.net/mailman/listinfo/elecraft Help: http://mailman.qth.net/subscribers.htm Elecraft web page: http://www.elecraft.com
Re: [Elecraft] CE labels, band limits - no thanks!
David Woolley wrote: [...] The danger is that if commercial sellers try to find loopholes, in closing the loopholes the legislators may restrict things that were not previously restricted. The more serious danger comes from within - from people inventing restrictions where none actually exist. Kristinn has it exactly right. The only thing that matters is what the regulations actually SAY, so she quotes them word-for-word with no interjections, no interpretation and no invention: (2) This Directive shall not apply to: ... (c) radio equipment used by radio amateurs within the meaning of the Radio Regulations adopted in the framework of the Constitution and Convention of the ITU [8], unless the equipment is available commercially. Kits of components to be assembled by radio amateurs and commercial equipment modified by and for the use of radio amateurs are not regarded as commercially available equipment. The only detail that seems to be open to interpretation is the meaning of components to be assembled. But even here the regulations are on our side: (11) Where this Directive regulates apparatus, it should refer to finished apparatus commercially available for the first time on the Community market. Certain components or sub-assemblies should, under certain conditions, be considered to be apparatus if they are made available to the end-user. Once again, this statement can be clarified with the help of another layer of regulations and definitions. I don't have those to hand, but finished apparatus in the first sentence refers to complete products capable of functioning as an independent entity. This means that a factory-assembled K3 does require compliance testing followed by CE marking; we already know that, and we also know that Elecraft are addressing this. The first sentence of (11) does NOT apply to sub-assemblies, which are normally outside the scope of the EMC regulations. It is recognised that the EMC performance of subassemblies will depend on how they are used, so the regulations do not apply until the finished assembly is either placed on the market or taken into service. The second sentence of (11) deals only with the exceptions, to catch any cases where the requirements for EMC testing and certification should, under certain conditions be applied to components or sub-assemblies. But it only applies to certain items, definitely not all of them. My interpretation is that each case would be treated on its own merits, based on the EMC risks that it presents. As a benchmark of that risk, we already know that the regulations accept the EMC risks arising from completely home-constructed equipment, or from kits assembled from components, so long as the work is done by and for the use of individual licensed amateurs. How do the K3 sub-assemblies measure up to that benchmark? Since they can only be used to build a K3, and since each individual sub-assembly has been factory-tested, the EMC risks are far below the benchmark. Case dismissed - there is no reason to imagine that where the second sentence of (11) might apply to the K3's subassemblies, so they are free to walk in. Forgive the detailed grind through the regulations, but it's either that way or nothing. We can't just make things up according to what we imagine the regulations say, or what we think they should say. The only thing that counts is what the regulations DO say. Therefore Elecraft are categorically NOT exploiting a loophole in selling the K3 into the EU as subassemblies. Quite the opposite - they are acting in complete accordance with the EMC regulations, and in their usual correct and responsible manner. To repeat what I said yesterday, this fevered speculation is only a temporary symptom of K3 deprivation. This too shall pass... By the way, the European EMC regulations DON'T say anything about restricted transmitting bands for amateur equipment. The original question was about enabling K3 owners to restrict those bands voluntarily, if they ever need to get through the eccentric border restrictions of certain individual countries. -- 73 from Ian GM3SEK http://www.ifwtech.co.uk/g3sek ___ Elecraft mailing list Post to: Elecraft@mailman.qth.net You must be a subscriber to post to the list. Subscriber Info (Addr. Change, sub, unsub etc.): http://mailman.qth.net/mailman/listinfo/elecraft Help: http://mailman.qth.net/subscribers.htm Elecraft web page: http://www.elecraft.com
Re: [Elecraft] CE labels, band limits - no thanks!
On Nov 17, 2007 12:06 PM, Ian White GM3SEK [EMAIL PROTECTED] wrote: Kristinn has it exactly right. The only thing that matters is what the regulations actually SAY, so she quotes them word-for-word with no Kristinn looks like a bloke to me... ( http://www.simnet.is/net/tf3kx/ ) -- Julian, G4ILO K2 s/n: 392 K3 s/n: ??? G4ILO's Shack: www.g4ilo.com Zerobeat Ham Forums: www.zerobeat.net/smf ___ Elecraft mailing list Post to: Elecraft@mailman.qth.net You must be a subscriber to post to the list. Subscriber Info (Addr. Change, sub, unsub etc.): http://mailman.qth.net/mailman/listinfo/elecraft Help: http://mailman.qth.net/subscribers.htm Elecraft web page: http://www.elecraft.com
Re: [Elecraft] CE labels, band limits - no thanks!
Julian G4ILO wrote: On Nov 17, 2007 12:06 PM, Ian White GM3SEK [EMAIL PROTECTED] wrote: Kristinn has it exactly right. The only thing that matters is what the regulations actually SAY, so she quotes them word-for-word with no Kristinn looks like a bloke to me... ( http://www.simnet.is/net/tf3kx/ ) I beg his pardon! -- 73 from Ian GM3SEK http://www.ifwtech.co.uk/g3sek ___ Elecraft mailing list Post to: Elecraft@mailman.qth.net You must be a subscriber to post to the list. Subscriber Info (Addr. Change, sub, unsub etc.): http://mailman.qth.net/mailman/listinfo/elecraft Help: http://mailman.qth.net/subscribers.htm Elecraft web page: http://www.elecraft.com
