Re: [PSES] SV: [PSES] SV: [PSES] RTTE - Radio product or not
In message <3f0347ac6ed9504191f91f07629fbb0c01542...@thhsle14mbx2.hslive.net>, dated Thu, 21 Mar 2013, Charlie Blackham writes: My point is that you were, perhaps inadvertently, citing a section talking about antennas as guidance for how to deal with Product A and Product B scenario. OK, now I understand. In my opinion, the *general* statement: Where a radio system is integrated on site - as in the case of microwave point-to-point and point-to-multipoint systems - the system integrators responsible for ensuring compliance of the system with the Directive when the system is brought into service. applies precisely to the A + B1, B2, B3... case, irrespective of appearing in a section on antennas. Since the A and the alternative B's are from different manufacturers, it's most likely that they would be brought together and connected on site, but the same applies if they are brought together elsewhere by the system integrator. -- OOO - Own Opinions Only. See www.jmwa.demon.co.uk SHOCK HORROR! Dinosaur-like DNA found in chicken and turkey meals John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas Mike Cantwell For policy questions, send mail to: Jim Bacher: David Heald:
Re: [PSES] SV: [PSES] SV: [PSES] RTTE - Radio product or not
John
You previously wrote:
{begin quote}
You have quoted several old messages unnecessarily, but you seem to have missed
the most important one. Anthony Thomson wrote:
QUOTE
However... I guess it's entirely possible that any meaningful assessment
against the R&TTED may not be possible on the separate components assuming both
are required to implement the 'radio'. In this case, the Commission's 2009
guide offers some very helpful advice: "Where a radio system is integrated on
site - as in the case of microwave point-to-point and point-to-multipoint
systems - the system integrators responsible for ensuring compliance of the
system with the Directive when the system is brought into service."
So my opinion would be that each component of the system falls under the R&TTED
and it is the system integrator's responsibility for compliance.
ENDQUOTE
This means that manufacturer A need only ensure that product A meets the
relevant requirements. Responsibility for making sure that combinations of A
with B1, B2, B3... rests with the 'system integrators' who put the products to
work together.
{end quote]
My point is that you were, perhaps inadvertently, citing a section talking
about antennas as guidance for how to deal with Product A and Product B
scenario.
Regards
Charlie
-Original Message-,
From: John Woodgate [mailto:j...@jmwa.demon.co.uk]
Sent: 21 March 2013 18:42
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] SV: [PSES] SV: [PSES] RTTE - Radio product or not
In message
<3f0347ac6ed9504191f91f07629fbb0c01542...@thhsle14mbx2.hslive.net<mailto:3f0347ac6ed9504191f91f07629fbb0c01542...@thhsle14mbx2.hslive.net>>,
dated Thu, 21 Mar 2013, Charlie Blackham
mailto:char...@sulisconsultants.com>>
writes:
>
>Section 1.3.1 of the guidance document, that contains this phrase,
>discusses whether or not antennas are covered by the R&TTE Directive.
I haven't any idea of what useful point you are making, if any. I think you are
indulging in pointless debate. If I'm wrong, please explain why you think that
whoever puts product A together with Product B (or B1, B2, B3 etc.) to make a
working system is not responsible for the system's conformity with the RTTED.
--
OOO - Own Opinions Only. See www.jmwa.demon.co.uk<http://www.jmwa.demon.co.uk>
SHOCK HORROR! Dinosaur-like DNA found in chicken and turkey meals John
Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK
-
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Re: [PSES] SV: [PSES] SV: [PSES] RTTE - Radio product or not
In message <3f0347ac6ed9504191f91f07629fbb0c01542...@thhsle14mbx2.hslive.net>, dated Thu, 21 Mar 2013, Charlie Blackham writes: Section 1.3.1 of the guidance document, that contains this phrase, discusses whether or not antennas are covered by the R&TTE Directive. I haven't any idea of what useful point you are making, if any. I think you are indulging in pointless debate. If I'm wrong, please explain why you think that whoever puts product A together with Product B (or B1, B2, B3 etc.) to make a working system is not responsible for the system's conformity with the RTTED. -- OOO - Own Opinions Only. See www.jmwa.demon.co.uk SHOCK HORROR! Dinosaur-like DNA found in chicken and turkey meals John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas Mike Cantwell For policy questions, send mail to: Jim Bacher: David Heald:
Re: [PSES] SV: [PSES] SV: [PSES] RTTE - Radio product or not
Section 1.3.1 of the guidance document, that contains this phrase, discusses whether or not antennas are covered by the R&TTE Directive. Point to point systems are integrated on site with an antenna, but that antenna must (typically) comply with certain requirements that may include gain and aspects of antenna pattern. For some equipment they must use antennas that are covered by other Harmonised Standards. The antenna gain will also affect other aspects such as article 3.1a EMF compliance which is another aspect that the final system integrator must consider. This particular product in question contains two separate and active parts with part B containing a frequency conversion and amplification stage. Correct consideration of the application of the R&TTE Directive to this device cannot be taken from a section discussing correct choice of antenna. Regards Charlie -Original Message- From: John Woodgate [mailto:j...@jmwa.demon.co.uk] Sent: 21 March 2013 17:27 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] SV: [PSES] SV: [PSES] RTTE - Radio product or not In message <3f0347ac6ed9504191f91f07629fbb0c01542...@thhsle14mbx2.hslive.net<mailto:3f0347ac6ed9504191f91f07629fbb0c01542...@thhsle14mbx2.hslive.net>>, dated Thu, 21 Mar 2013, Charlie Blackham mailto:char...@sulisconsultants.com>> writes: >The sentence "Where a radio system is integrated on site — as in the >case of microwave point-to-point and point-to-multipoint systems — the >system integrator is responsible for ensuring compliance of the system >with the Directive when the system is brought into service." Is in a >section dealing with the integration of a unit with an antenna, it is >not in the context of combining two or more boxes to form a radio >transmitter or transceiver. But that's exactly what it is. How A and B are connected together is surely site-dependent, because there is not just one possible B. And the length and quality of the interconnecting cables are influential. -- OOO - Own Opinions Only. See www.jmwa.demon.co.uk<http://www.jmwa.demon.co.uk> SHOCK HORROR! Dinosaur-like DNA found in chicken and turkey meals John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to mailto:emc-p...@ieee.org>> All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas mailto:emcp...@radiusnorth.net>> Mike Cantwell mailto:mcantw...@ieee.org>> For policy questions, send mail to: Jim Bacher: mailto:j.bac...@ieee.org>> David Heald: mailto:dhe...@gmail.com>> - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas Mike Cantwell For policy questions, send mail to: Jim Bacher: David Heald:
Re: [PSES] SV: [PSES] SV: [PSES] RTTE - Radio product or not
In message <3f0347ac6ed9504191f91f07629fbb0c01542...@thhsle14mbx2.hslive.net>, dated Thu, 21 Mar 2013, Charlie Blackham writes: The sentence "Where a radio system is integrated on site — as in the case of microwave point-to-point and point-to-multipoint systems — the system integrator is responsible for ensuring compliance of the system with the Directive when the system is brought into service." Is in a section dealing with the integration of a unit with an antenna, it is not in the context of combining two or more boxes to form a radio transmitter or transceiver. But that's exactly what it is. How A and B are connected together is surely site-dependent, because there is not just one possible B. And the length and quality of the interconnecting cables are influential. -- OOO - Own Opinions Only. See www.jmwa.demon.co.uk SHOCK HORROR! Dinosaur-like DNA found in chicken and turkey meals John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas Mike Cantwell For policy questions, send mail to: Jim Bacher: David Heald:
Re: [PSES] SV: [PSES] SV: [PSES] RTTE - Radio product or not
Care must be taken when quoting from guidance documents. The sentence "Where a radio system is integrated on site — as in the case of microwave point-to-point and point-to-multipoint systems — the system integrator is responsible for ensuring compliance of the system with the Directive when the system is brought into service." Is in a section dealing with the integration of a unit with an antenna, it is not in the context of combining two or more boxes to form a radio transmitter or transceiver. I suspect that a complete answer to this issue could only be given when knowing more detail as to the exact application of this device Regards Charlie -Original Message- From: John Woodgate [mailto:j...@jmwa.demon.co.uk] Sent: 21 March 2013 08:41 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] SV: [PSES] SV: [PSES] RTTE - Radio product or not In message <000b01ce2609$28d0d960$7a728c20$@no>, dated Thu, 21 Mar 2013, Amund Westin writes: >Radio tests on one combination of A+B is approximate $10.000. So doing >a reasonable number of combinations will be very costly. And we can run >into problems that is caused by Item B's, which are made from other >manufacturers ... You have quoted several old messages unnecessarily, but you seem to have missed the most important one. Anthony Thomson wrote: QUOTE However… I guess it's entirely possible that any meaningful assessment against the R&TTED may not be possible on the separate components assuming both are required to implement the ‘radio’. In this case, the Commission's 2009 guide offers some very helpful advice: “Where a radio system is integrated on site — as in the case of microwave point-to-point and point-to-multipoint systems — the system integrators responsible for ensuring compliance of the system with the Directive when the system is brought into service.” So my opinion would be that each component of the system falls under the R&TTED and it is the system integrator's responsibility for compliance. ENDQUOTE This means that manufacturer A need only ensure that product A meets the relevant requirements. Responsibility for making sure that combinations of A with B1, B2, B3... rests with the 'system integrators' who put the products to work together. -- OOO - Own Opinions Only. See www.jmwa.demon.co.uk SHOCK HORROR! Dinosaur-like DNA found in chicken and turkey meals John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas Mike Cantwell For policy questions, send mail to: Jim Bacher: David Heald: - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas Mike Cantwell For policy questions, send mail to: Jim Bacher: David Heald:
Re: [PSES] SV: [PSES] RTTE - Radio product or not
Amund, This approach typically includes a set of design and/or installation guidelines and engineering justification as needed to establish a presumption of conformity with the Directive for the untested combinations. The "reasonable number" of tests, the number of full tests, the number of partial tests, and the particular guidelines are case-by-case and subject to discussion with and approval by the NB. Best Regards, Mike -Original Message- From: Amund Westin [mailto:am...@westin-emission.no] Sent: Thursday, March 21, 2013 12:53 AM To: Heckrotte, Michael; EMC-PSTC@LISTSERV.IEEE.ORG Subject: SV: [PSES] SV: [PSES] RTTE - Radio product or not Mike I see that approach. Radio tests on one combination of A+B is approximate $10.000. So doing a reasonable number of combinations will be very costly. And we can run into problems that is caused by Item B's, which are made from other manufacturers ... But we have done a successful test on Item A + B previously. We could measured the IF spectra on output port (coax cable) of old Item A model, and compared it with similar measurements (harmonics, spurious, freq. drift, etc) on the new Item A model. Then should at least the input signals to Item B be in the same range. #Amund -Opprinnelig melding- Fra: Heckrotte, Michael [mailto:michael.heckro...@ul.com] Sendt: 20. mars 2013 17:07 Til: EMC-PSTC@LISTSERV.IEEE.ORG Emne: Re: [PSES] SV: [PSES] RTTE - Radio product or not Amund, Regarding your second paragraph, a cost-effective approach is to develop a Test Plan that specifies tests on a reasonable number of combinations, submit it to a Notified Body for review, then get the Notified Body Expert Opinion based on that plan and the test results. Best Regards, Mike -Original Message- From: Amund Westin [mailto:am...@westin-emission.no] Sent: Wednesday, March 20, 2013 1:44 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] SV: [PSES] RTTE - Radio product or not Thanks! I see the 'intended function' ... Agree that Item A should be handled as a radio product. But it will be hard to make compliance to radio standards since the product Item, A is only a part of a total radio systems. Radio parameters according to ETSI / EN standards will not be able to check before a complete systems (Item A + B) is running. These parameters will not be able to check before the complete system is running. Let me just comment that Item A is made by a single manufacturer and Item B is made by manufacturer B and there are many possible Item B's on the market. Testing out all possible configurations of Itema A + Item B is considered unacceptable, since it will cover 95% of configurations which never will be used and it would also cost a huge amount of $$. Thanks. #Amund -Opprinnelig melding- Fra: John Woodgate [mailto:j...@jmwa.demon.co.uk] Sendt: 19. mars 2013 20:42 Til: EMC-PSTC@LISTSERV.IEEE.ORG Emne: Re: [PSES] RTTE - Radio product or not In message <3f0347ac6ed9504191f91f07629fbb0c01540...@thhsle14mbx2.hslive.net>, dated Tue, 19 Mar 2013, Charlie Blackham writes: > >Product B isn’t a radio without product A attached, therefore product A >is part of a radio system and the R&TTE Directive applies. I would tentatively agree: in CENELEC long ago, the question was (half seriously) raised as to whether a washing machine with a microprocessor was a household appliance or ITE. The answer was that the 'intended function' is definitive. I think this can be extended to products like A and B, which are not intended to work alone but are components of a system. The 'intended function' of the system is a radio, so the component parts are 'radio'. -- OOO - Own Opinions Only. See www.jmwa.demon.co.uk SHOCK HORROR! Dinosaur-like DNA found in chicken and turkey meals John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas Mike Cantwell For policy questions, send mail to: Jim Bacher: David Heald: - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to All emc-pstc postings ar
Re: [PSES] SV: [PSES] SV: [PSES] RTTE - Radio product or not
In message <000b01ce2609$28d0d960$7a728c20$@no>, dated Thu, 21 Mar 2013, Amund Westin writes: Radio tests on one combination of A+B is approximate $10.000. So doing a reasonable number of combinations will be very costly. And we can run into problems that is caused by Item B's, which are made from other manufacturers ... You have quoted several old messages unnecessarily, but you seem to have missed the most important one. Anthony Thomson wrote: QUOTE However… I guess it's entirely possible that any meaningful assessment against the R&TTED may not be possible on the separate components assuming both are required to implement the ‘radio’. In this case, the Commission's 2009 guide offers some very helpful advice: “Where a radio system is integrated on site — as in the case of microwave point-to-point and point-to-multipoint systems — the system integrators responsible for ensuring compliance of the system with the Directive when the system is brought into service.” So my opinion would be that each component of the system falls under the R&TTED and it is the system integrator's responsibility for compliance. ENDQUOTE This means that manufacturer A need only ensure that product A meets the relevant requirements. Responsibility for making sure that combinations of A with B1, B2, B3... rests with the 'system integrators' who put the products to work together. -- OOO - Own Opinions Only. See www.jmwa.demon.co.uk SHOCK HORROR! Dinosaur-like DNA found in chicken and turkey meals John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas Mike Cantwell For policy questions, send mail to: Jim Bacher: David Heald:
[PSES] SV: [PSES] SV: [PSES] RTTE - Radio product or not
Mike I see that approach. Radio tests on one combination of A+B is approximate $10.000. So doing a reasonable number of combinations will be very costly. And we can run into problems that is caused by Item B's, which are made from other manufacturers ... But we have done a successful test on Item A + B previously. We could measured the IF spectra on output port (coax cable) of old Item A model, and compared it with similar measurements (harmonics, spurious, freq. drift, etc) on the new Item A model. Then should at least the input signals to Item B be in the same range. #Amund -Opprinnelig melding- Fra: Heckrotte, Michael [mailto:michael.heckro...@ul.com] Sendt: 20. mars 2013 17:07 Til: EMC-PSTC@LISTSERV.IEEE.ORG Emne: Re: [PSES] SV: [PSES] RTTE - Radio product or not Amund, Regarding your second paragraph, a cost-effective approach is to develop a Test Plan that specifies tests on a reasonable number of combinations, submit it to a Notified Body for review, then get the Notified Body Expert Opinion based on that plan and the test results. Best Regards, Mike -Original Message- From: Amund Westin [mailto:am...@westin-emission.no] Sent: Wednesday, March 20, 2013 1:44 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] SV: [PSES] RTTE - Radio product or not Thanks! I see the 'intended function' ... Agree that Item A should be handled as a radio product. But it will be hard to make compliance to radio standards since the product Item, A is only a part of a total radio systems. Radio parameters according to ETSI / EN standards will not be able to check before a complete systems (Item A + B) is running. These parameters will not be able to check before the complete system is running. Let me just comment that Item A is made by a single manufacturer and Item B is made by manufacturer B and there are many possible Item B's on the market. Testing out all possible configurations of Itema A + Item B is considered unacceptable, since it will cover 95% of configurations which never will be used and it would also cost a huge amount of $$. Thanks. #Amund -Opprinnelig melding- Fra: John Woodgate [mailto:j...@jmwa.demon.co.uk] Sendt: 19. mars 2013 20:42 Til: EMC-PSTC@LISTSERV.IEEE.ORG Emne: Re: [PSES] RTTE - Radio product or not In message <3f0347ac6ed9504191f91f07629fbb0c01540...@thhsle14mbx2.hslive.net>, dated Tue, 19 Mar 2013, Charlie Blackham writes: > >Product B isn’t a radio without product A attached, therefore product A >is part of a radio system and the R&TTE Directive applies. I would tentatively agree: in CENELEC long ago, the question was (half seriously) raised as to whether a washing machine with a microprocessor was a household appliance or ITE. The answer was that the 'intended function' is definitive. I think this can be extended to products like A and B, which are not intended to work alone but are components of a system. The 'intended function' of the system is a radio, so the component parts are 'radio'. -- OOO - Own Opinions Only. See www.jmwa.demon.co.uk SHOCK HORROR! Dinosaur-like DNA found in chicken and turkey meals John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas Mike Cantwell For policy questions, send mail to: Jim Bacher: David Heald: - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas Mike Cantwell For policy questions, send mail to: Jim Bacher: David Heald: This e-mail may contain privileged or confidential information. If you are not the intended recipient: (1) y
Re: [PSES] SV: [PSES] RTTE - Radio product or not
Amund, Regarding your second paragraph, a cost-effective approach is to develop a Test Plan that specifies tests on a reasonable number of combinations, submit it to a Notified Body for review, then get the Notified Body Expert Opinion based on that plan and the test results. Best Regards, Mike -Original Message- From: Amund Westin [mailto:am...@westin-emission.no] Sent: Wednesday, March 20, 2013 1:44 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] SV: [PSES] RTTE - Radio product or not Thanks! I see the 'intended function' ... Agree that Item A should be handled as a radio product. But it will be hard to make compliance to radio standards since the product Item, A is only a part of a total radio systems. Radio parameters according to ETSI / EN standards will not be able to check before a complete systems (Item A + B) is running. These parameters will not be able to check before the complete system is running. Let me just comment that Item A is made by a single manufacturer and Item B is made by manufacturer B and there are many possible Item B's on the market. Testing out all possible configurations of Itema A + Item B is considered unacceptable, since it will cover 95% of configurations which never will be used and it would also cost a huge amount of $$. Thanks. #Amund -Opprinnelig melding- Fra: John Woodgate [mailto:j...@jmwa.demon.co.uk] Sendt: 19. mars 2013 20:42 Til: EMC-PSTC@LISTSERV.IEEE.ORG Emne: Re: [PSES] RTTE - Radio product or not In message <3f0347ac6ed9504191f91f07629fbb0c01540...@thhsle14mbx2.hslive.net>, dated Tue, 19 Mar 2013, Charlie Blackham writes: > >Product B isn’t a radio without product A attached, therefore product A >is part of a radio system and the R&TTE Directive applies. I would tentatively agree: in CENELEC long ago, the question was (half seriously) raised as to whether a washing machine with a microprocessor was a household appliance or ITE. The answer was that the 'intended function' is definitive. I think this can be extended to products like A and B, which are not intended to work alone but are components of a system. The 'intended function' of the system is a radio, so the component parts are 'radio'. -- OOO - Own Opinions Only. See www.jmwa.demon.co.uk SHOCK HORROR! Dinosaur-like DNA found in chicken and turkey meals John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas Mike Cantwell For policy questions, send mail to: Jim Bacher: David Heald: - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas Mike Cantwell For policy questions, send mail to: Jim Bacher: David Heald: This e-mail may contain privileged or confidential information. If you are not the intended recipient: (1) you may not disclose, use, distribute, copy or rely upon this message or attachment(s); and (2) please notify the sender by reply e-mail, and then delete this message and its attachment(s). Underwriters Laboratories Inc. and its affiliates disclaim all liability for any errors, omissions, corruption or virus in this message or any attachments. - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for gra
[PSES] SV: [PSES] RTTE - Radio product or not
Thanks! I see the 'intended function' ... Agree that Item A should be handled as a radio product. But it will be hard to make compliance to radio standards since the product Item, A is only a part of a total radio systems. Radio parameters according to ETSI / EN standards will not be able to check before a complete systems (Item A + B) is running. These parameters will not be able to check before the complete system is running. Let me just comment that Item A is made by a single manufacturer and Item B is made by manufacturer B and there are many possible Item B's on the market. Testing out all possible configurations of Itema A + Item B is considered unacceptable, since it will cover 95% of configurations which never will be used and it would also cost a huge amount of $$. Thanks. #Amund -Opprinnelig melding- Fra: John Woodgate [mailto:j...@jmwa.demon.co.uk] Sendt: 19. mars 2013 20:42 Til: EMC-PSTC@LISTSERV.IEEE.ORG Emne: Re: [PSES] RTTE - Radio product or not In message <3f0347ac6ed9504191f91f07629fbb0c01540...@thhsle14mbx2.hslive.net>, dated Tue, 19 Mar 2013, Charlie Blackham writes: > >Product B isn’t a radio without product A attached, therefore product A >is part of a radio system and the R&TTE Directive applies. I would tentatively agree: in CENELEC long ago, the question was (half seriously) raised as to whether a washing machine with a microprocessor was a household appliance or ITE. The answer was that the 'intended function' is definitive. I think this can be extended to products like A and B, which are not intended to work alone but are components of a system. The 'intended function' of the system is a radio, so the component parts are 'radio'. -- OOO - Own Opinions Only. See www.jmwa.demon.co.uk SHOCK HORROR! Dinosaur-like DNA found in chicken and turkey meals John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas Mike Cantwell For policy questions, send mail to: Jim Bacher: David Heald: - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas Mike Cantwell For policy questions, send mail to: Jim Bacher: David Heald:
[PSES] SV: [PSES] RTTE - Radio product or not
Product A contains some fundamental radio parameters that you have mention (modulation, demodulation) and probably some others as well such as Frequency accuracy/stability. Does it offer any useful functionality without being connected to B? == > Yes, even though it’s not possible to verify all radio parameters because Item B is missing, it should be possible to check some relevant requirements in the ETSI/EN 301 XXX standards on the TX/RX ports of Item A. == > No, Item A doesn’t have any functionality when Item B is missing. Regards Amund Fra: Charlie Blackham [mailto:char...@sulisconsultants.com] Sendt: 19. mars 2013 20:12 Til: amund; EMC-PSTC@LISTSERV.IEEE.ORG Emne: RE: [PSES] RTTE - Radio product or not Amund I’d look at it the other way around: Product B isn’t a radio without product A attached, therefore product A is part of a radio system and the R&TTE Directive applies. Product A contains some fundamental radio parameters that you have mention (modulation, demodulation) and probably some others as well such as Frequency accuracy/stability. Does it offer any useful functionality without being connected to B? (some other regulatory regimes often only require “certification” of the bit that actually “transmits”, but the R&TTE directive is a bit different) Regards Charlie From: Amund Westin [mailto:am...@westin-emission.no] Sent: 19 March 2013 10:41 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] RTTE - Radio product or not Item A: Processing unit. Connection to PC and LAN (not directly to telecom network). Radio modulator & demodulator. Output radio signal 800MHz / 0dbm on cable to Item B. Item B: Upconverter to 10GHz and High Power Amplifier and antenna Item A and B together is a complete radio system and RTTE apply. Item A stand-alone: I would say that it’s not a radio product since it does not transmit / receive to space. The radio signals (TX and RX) in on the cable to Item B and could be categorized as a signal line. LAN connection is not directly coupled to public telecom network. RTTE will not apply, that’s my opinion. The system integrator (Item A + B) will put his system into use and should be responsible for fulfilling RTTE. Folks, do you agree? Cheers, Amund PS: >From RTTE guidelines: Telecommunications terminal equipment is defined as a >product enabling communication or a relevant component thereof which is >intended to be connected directly or indirectly by any means The wording “indirect” makes maybe Item A to a telecom terminal equipment …. - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas Mike Cantwell For policy questions, send mail to: Jim Bacher David Heald - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas Mike Cantwell For policy questions, send mail to: Jim Bacher: David Heald:
