RE: RTTE Conformity Assessment Procedure

[emc-p...@ieee.org]

Hi Grace

There are other issues that may be involved but let’s address your specific
question.

Labs are not actually ‘registered’ with a Notified Body except under
annexes V and up.  The intent of use for an NB proposed in your email is 1 -
to give credence to the test suite under annex III or 2 - to give an opinion
based on a review of the technical construction file under annex IV, or 3 –
have the NB audit the quality system of the manufacturer so they (the
manufacturer) can declare conformity under a full quality assurance process.

 

Under annex III the notified body would assist the manufacturer in determining
the appropriate test suite for the product.  This could mean that the NB
produces the test suite itself or that it ‘approves’ a test suite
requested by the manufacturer.  The directive itself simply states that it is
the NB that has responsibility of identifying the appropriate test suite.  It
does not say how this identification is to be made.  Thus the ability of the
manufacturer to assess the test requirements and submit to the NB is not ruled
out.  In either case however, the options obviously require that the NB has a
full and complete understanding of the product in order to either agree with
the manufacturers assessment of testing or to establish a test suite itself.

 

Under annex IV the notified body makes a determination of the appropriateness
of the product to the essential requirements based on a thorough review of the
TCF.  While some may assume that a minimalistic review of only certain aspects
of the TCF is needed and while NBs may put caveats in the opinion as only
applying to documentation provided, the question then becomes, how can a
reasonable assessment as to the appropriateness of the product to the
essential requirements be done without a full and complete review of all
documentation normally required in a complete TCF?

 

Under annex V the notified body does a complete audit of the manufacturers
quality assurance program, including test methods and other capabilities. 
This would be the only time that any lab registration would necessarily exist.
 Please note however, that it is not only the lab that is ‘registered’ but
all aspects of the quality system that deals with the product line and its
ability to meet all essential requirements.

 

As to the specific frequencies you mention – you have not provided enough
information for any reasonable position on what would be needed.

Thanks 

 

Dennis Ward 
Evaluation Engineer 
American TCB 
Certification Resource for the Wireless Industry www.atcb.com 
703-847-4700 fax 703-847-6888 
direct - 703-880-4841 
cell - 209-769-8316 
NOTICE: This E-Mail message and any attachment may contain privileged or
company proprietary information. If you received this message in error, please
return to the sender. 

  _  

From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Grace Lin
Sent: 08/09/2006 10:24 AM
To: emc-p...@ieee.org
Subject: RTTE Conformity Assessment Procedure

 

Dear Members,

 

Please help me to understand the conformity assessment procedure per the RTTE
Directive.  Paragraph 4 of Article 10 of Directive 1999/5/EC states:

 

"Where a manufacturer has applied the harmonized standard referred to in
Article 5(1), radia equipment not within the scope of paragraph 3 shall be
subject to the procedures described in any one of Annexes III, IV or V at the
choice of the manufacturer." 

 

Annex III states:

 

"For each type of apparatus, all essential radio test suites must be carried
out by the manufacturer or on his behalf.   The identification of the test
suites that are considered to be essential is the responsibility of a notified
body chosen by the manufacturer except where the test suites are defined in
the harmonized standards.   The notified body must take due account of
previous decisions made by notified bodies acting together.

 

The manufacturer or his authorized representative established within the
Community or the person responsible for placing the apparatus on the market
must declare that these tests have been carried out and that the apparatus
complies with the essential requirements and must affix the notified body's
identification number during the manufacturing process." 

 

I don't understand the first paragraph of Annex III.  My question is: do I
need to have my lab (in a manufacturer) registed with one of notified bodies
to be considered to be essential?  If not, what is the marking requirement,
"CE" ( 433.92MHz) or "CE plus alert sign" (2.4GHz SS), or others?

 

Thank you very much for your time and look forward to your help. 

 

Best regards,

Grace Lin

Sr. Compliance Engineer

Crestron Electronics, Inc.

6 Volvo Drive

Rockleigh, NJ 07647

g...@crestron.com

www.crestron.com

 

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To post 

RE: RTTE Conformity Assessment Procedure

[emc-p...@ieee.org]

The alert mark is required if the frequency band is not harmonized in the EU.

Bill 


From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of John Woodgate
Sent: Wednesday, August 09, 2006 12:47 PM
To: emc-p...@ieee.org
Subject: Re: RTTE Conformity Assessment Procedure

In message
<2a93eb060608091024h274cf040w98474b21dcc66...@mail.gmail.com>, dated Wed, 9
Aug 2006, Grace Lin  writes

>I don't understand the first paragraph of Annex III.  My question is: 
>do I need to have my lab (in a manufacturer) registed with one of 
>notified bodies to be considered to be essential?

No, it says that the Notified Body has to tell you which tests your product
requires.

>If not, what is the marking requirement, "CE" ( 433.92MHz) or "CE plus 
>alert sign" (2.4GHz SS), or others?

I think that's a different, and perhaps unrelated, question. I don't have
enough data about your product to answer it, and I don't normally advise on
RTTE stuff.
--
OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk
2006 is YMMVI- Your mileage may vary immensely.

John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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Re: RTTE Conformity Assessment Procedure

[emc-p...@ieee.org]

In message 
<2a93eb060608091024h274cf040w98474b21dcc66...@mail.gmail.com>, dated 
Wed, 9 Aug 2006, Grace Lin  writes

>I don't understand the first paragraph of Annex III.  My question is: 
>do I need to have my lab (in a manufacturer) registed with one of 
>notified bodies to be considered to be essential? 

No, it says that the Notified Body has to tell you which tests your 
product requires.

>If not, what is the marking requirement, "CE" ( 433.92MHz) or "CE plus 
>alert sign" (2.4GHz SS), or others?

I think that's a different, and perhaps unrelated, question. I don't 
have enough data about your product to answer it, and I don't normally 
advise on RTTE stuff.
-- 
OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk
2006 is YMMVI- Your mileage may vary immensely.

John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

-

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RE: RTTE apply for non-radio equipment?

[emc-p...@ieee.org]

Amund,
 
We use the RTTE Directive for batteries that are used with radios.  For the
chargers we use the EMC and Low Voltage Directive.  Finally, the radio team
uses the RTTE directive with the complete system.
 
Best Regards, 

Jody Leber 
Senior Regulatory Engineer 

jody.le...@motorola.com 
http://www.motorola.com/producttesting 
blocked::http://www.motorola.com/producttesting>  

Motorola Product Testing Services 
1700 Belle Meade Court 
Lawrenceville, GA 30043 

770.338.3581  P 
678.201.7270  C 
847.761.3145  F 


  _  

From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Amund Westin
Sent: Tuesday, January 24, 2006 4:53 PM
To: emc-p...@ieee.org
Subject: RTTE apply for non-radio equipment?


We have been told by a RTTE Notified Body that "non-radio equipment" are
covered by RTTE directive, if they are a part of a total radio system and
connected (signal transfer) to a radio RX/TX unit. Can it be correct that such
adjacent equipment applies for RTTE?
 
Personally, I thought that RTTE basically covers radio transmitter and
receivers, of course with some exceptions.  And all equipment which do not
have a TX/RX port are excluded.
 
Reagrds
Amund Westin
Oslo / Norway
 
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Re: RTTE apply for non-radio equipment?

[emc-p...@ieee.org]

In message , 
dated Tue, 24 Jan 2006, Amund Westin  writes

>We have been told by a RTTE Notified Body that "non-radio equipment" 
>are covered by RTTE directive, if they are a part of a total radio 
>system and connected (signal transfer) to a radio RX/TX unit. Can it be 
>correct that such adjacent equipment applies for RTTE?

Reading the Directive, it does not appear so. Ask them to show you the 
place in the Directive where the relevant provision is stated.

If it were so, a PC connected to a wireless router, for example, would 
fall under the Directive.

You can download the Directive free of charge from the Commission web 
site.
> 
>Personally, I thought that RTTE basically covers radio transmitter 
>and receivers, of course with some exceptions.  And all equipment which 
>do not have a TX/RX port are excluded.

RTTE also applies to telecommunications terminal equipment. Maybe your 
'non-radio' product is within that definition.
-- 
OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk
2006 is YMMVI- Your mileage may vary immoderately.

John Woodgate

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RE: RTTE apply for non-radio equipment?

[emc-p...@ieee.org]

Check this TR from ETSI this gives some guidance for radio approvals and
associated devices.

 

Below is an excerpt from ETSI TR 102 070-2 V1.1.1 (2002-11) Guide to the
application of harmonized standards to multi-radio and combined radio and
non-radio equipment; Part 2: Effective use of the radio frequency spectrum

 

Where the embedded radio function cannot operate independently from the
primary product then the combined
equipment should be assessed to the harmonized standard relevant for the radio
technology utilized.
Alternatively, for radiated spurious emissions in receive and/or standby mode,
the harmonized EMC standard for the
primary product may be used. For the remaining parts of the frequency
measurement ranges covered by the radio
standard, but not the primary product EMC standard, the requirements in the
radio standard should be used to
demonstrate compliance to article 3.2 of the R&TTE Directive 1999/5/EC [1].

 

 

Lothar Schmidt

 

Technical Manager EMC, SAR, Antenna testing and BQB

 

CETECOM Inc. 

411 Dixon Landing Road

Milpitas, CA 95035

 

Phone +1 408 586 6214

Fax +1 408 586 6299

 

This e-mail may contain proprietary, privileged and confidential information
for the sole use of the named intended recipient. Any review or distribution
of this e-mail by any party other than the intended recipient or that person's
agent is strictly prohibited. If you are not the intended recipient, please
delete all copies and immediately Contact the sender. You must not, directly
or indirectly, use, disclose, distribute, print, or copy any part of this
message if you are not the intended recipient. 

Thank you.

 

  _  

From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Amund Westin
Sent: Tuesday, January 24, 2006 1:53 PM
To: emc-p...@ieee.org
Subject: RTTE apply for non-radio equipment?

 

We have been told by a RTTE Notified Body that "non-radio equipment" are
covered by RTTE directive, if they are a part of a total radio system and
connected (signal transfer) to a radio RX/TX unit. Can it be correct that such
adjacent equipment applies for RTTE?

 

Personally, I thought that RTTE basically covers radio transmitter and
receivers, of course with some exceptions.  And all equipment which do not
have a TX/RX port are excluded.

 

Reagrds

Amund Westin

Oslo / Norway

 

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RE: RTTE apply for non-radio equipment?

[emc-p...@ieee.org]

The RTTED is for radio equipment and telecommunications terminal equipment not
just radio equipment.

Article 2 of the RTTED states “radio equipment means a product, or relevant
component thereof”.

The “relevant component thereof” is where some equipment classified and
“non-radio” are included in the RTTED.

 

Dennis Ward 
Evaluation Engineer 
American TCB 
Certification Resource for the Wireless Industry www.atcb.com 
703-847-4700 fax 703-847-6888 
direct - 703-880-4841 
cell - 209-769-8316 
NOTICE: This E-Mail message and any attachment may contain privileged or
company proprietary information. If you received this message in error, please
return to the sender. 

  _  

From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Amund Westin
Sent: Tuesday, January 24, 2006 1:53 PM
To: emc-p...@ieee.org
Subject: RTTE apply for non-radio equipment?

 

We have been told by a RTTE Notified Body that "non-radio equipment" are
covered by RTTE directive, if they are a part of a total radio system and
connected (signal transfer) to a radio RX/TX unit. Can it be correct that such
adjacent equipment applies for RTTE?

 

Personally, I thought that RTTE basically covers radio transmitter and
receivers, of course with some exceptions.  And all equipment which do not
have a TX/RX port are excluded.

 

Reagrds

Amund Westin

Oslo / Norway

 

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Re: RTTE DoC languages

[John Woodgate]

I read in !emc-pstc that richwo...@tycoint.com wrote (in <846BF526A205F8
4BA2B6045BBF7E9A6A04675F9D@flbocexu05>) about 'RTTE DoC languages' on
Tue, 20 May 2003:
>Anything the group can provide would be appreciated, but I would ask that
>persons refrain from offering translations if they are not sufficiently
>competent in the language. 

I recommend that you ask the professional translators on
sci.lang.translation because there are legal implications if a
translation is defective.
-- 
Regards, John Woodgate, OOO - Own Opinions Only. http://www.jmwa.demon.co.uk 
Interested in professional sound reinforcement and distribution? Then go to 
http://www.isce.org.uk
PLEASE do NOT copy news posts to me by E-MAIL!


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RE: RTTE - antennas

[Gert Gremmen]

Within the R&TTE harmonized standards
fa. for SRD's a distinction is made between
equipment having

1/ internal and
2/ external or
3/ dedicated
 antenna's.

If your product is tested as an equipment having an external
antenna, the test program will be such that the type of
antenna should not have impact on the R&TTE properties.
Of course, otherwise a HAM product (transceiver) would not
be able to be sold in Europe, as the antenna is unspecified.

As an antenna is basically a passive element (at least it should),
no detoriation of the transmitter properties is to be expected,
but for directional properties.
Some products won't be allowed with external antenna's,
if the requirement is to limit it's geographical
range (due to f.a. frequency sharing).


Then a dedicated antenna is part of the approval procedure.
Of course this IS the always case with internal antenna's.

Many SRD devices use dedicated or internal antenna's only.

I have to add that the requirement for external/dedicated
antenna is most often implemented on regulatory level,
and not specifically within the R&TTE.
Any permission to use the equipment will be with a prescribed
antenna type, and often heigth. Of course,
this is country and product type dependent, and subject to
frequent changes and (hopefully) harmonization within  the EC.

Regards,

Gert Gremmen
ce-test, qualified testing
Rotterdam, The Netherlands

http://www.ce-test.nl



From: owner-emc-p...@majordomo.ieee.org
[mailto:owner-emc-p...@majordomo.ieee.org]On Behalf Of Lothar Schmidt
Sent: donderdag 15 mei 2003 00:04
To: 'Amund Westin'; emc-p...@majordomo.ieee.org
Subject: RE: RTTE - antennas



It depends on which ETS/EN standard is applicable for the Radio some of them
have the antenna parameters specified as part of the spectrum parameters.

Best Regards

Lothar Schmidt
Technical Manager EMC/Radio/SAR
BQB

CETECOM Inc.
411 Dixon Landing Road
Milpitas, CA 95035

phone ?+1 (408) 586 6214
fax  +1 (408) 586 6299

 -Original Message-
From:   Amund Westin [mailto:am...@westin-emission.no]
Sent:   Wednesday, May 14, 2003 1:10 PM
To: emc-p...@majordomo.ieee.org
Subject:RTTE - antennas


Assume a CE / RTTE approved radio transmitter system, which consists of an
indoor unit (modulator), an outdoor unit (HPA/LNB/OMT) and an antenna.

If you change to another type of antenna (passive), will the system still be
compliant to the RTTE directive ? Is antenna testing a part of the RTTE
testing ?

Best regards
Amund Westin





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RE: RTTE - antennas

[Charles Blackham]

Amund

Check the standards applicable to your product - provided that you meet the
standard at the output from your transmitter system (impedance etc.) you
should be able to specify that any antenna meeting the relevant ETSI class may
be used.

You will also have to specify the maximum gain of antennas that may be
connected to your system so that it still complies with EMF/SAR requirements.

regards
Charlie Blackham
Approvals Manager
Airspan Communications Ltd


From: Amund Westin [mailto:am...@westin-emission.no]
Sent: 14 May 2003 21:10
To: emc-p...@majordomo.ieee.org
Subject: RTTE - antennas



Assume a CE / RTTE approved radio transmitter system, which consists of an
indoor unit (modulator), an outdoor unit (HPA/LNB/OMT) and an antenna.

If you change to another type of antenna (passive), will the system still be
compliant to the RTTE directive ? Is antenna testing a part of the RTTE
testing ?

Best regards
Amund Westin





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RE: RTTE - antennas

[Lothar Schmidt]

It depends on which ETS/EN standard is applicable for the Radio some of them
have the antenna parameters specified as part of the spectrum parameters.

Best Regards

Lothar Schmidt
Technical Manager EMC/Radio/SAR
BQB

CETECOM Inc.
411 Dixon Landing Road
Milpitas, CA 95035

phone ?+1 (408) 586 6214
fax  +1 (408) 586 6299

 -Original Message-
From:   Amund Westin [mailto:am...@westin-emission.no] 
Sent:   Wednesday, May 14, 2003 1:10 PM
To: emc-p...@majordomo.ieee.org
Subject:RTTE - antennas


Assume a CE / RTTE approved radio transmitter system, which consists of an
indoor unit (modulator), an outdoor unit (HPA/LNB/OMT) and an antenna.

If you change to another type of antenna (passive), will the system still be
compliant to the RTTE directive ? Is antenna testing a part of the RTTE
testing ?

Best regards
Amund Westin





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RE: RTTE - antennas

[Carpentier Kristiaan]

Amund,

Another antenna may alter the Radio and EMC behaviour of your radio
transmitter. So you must check if the complete system with the other antenna
is still compliant with the applicable harmonised EMC and radio standards.
Kris


From: Amund Westin [mailto:am...@westin-emission.no]
Sent: woensdag 14 mei 2003 22:10
To: emc-p...@majordomo.ieee.org
Subject: RTTE - antennas



Assume a CE / RTTE approved radio transmitter system, which consists of an
indoor unit (modulator), an outdoor unit (HPA/LNB/OMT) and an antenna.

If you change to another type of antenna (passive), will the system still be
compliant to the RTTE directive ? Is antenna testing a part of the RTTE
testing ?

Best regards
Amund Westin





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RE: RTTE - receive only equipment

[Gert Gremmen]

The requirement for receivers  depend on the classification
of the receiver. As you may know most ETSI standards
classify a receiver or send/receive combination
into 3 classes, depending on the amount of hinder
their failure may cause, in terms of

1 serious problem with risk for user  (cellulars / marine / rescue equipment
etc)
2 problems, easy to overcome  (walki talkies)
3 failure causes no problem  (car keyers babyphones etc)

In Class 3 most tests do not need to be carried out.
Some assessment need to be made however.
When reading the text however, i cannot stop thinking that the authors
thought of receivers being part of a transceiver combi, and not
stand alone receivers. There is no reason however to
exclude those receivers that upon failing may cause harm
to a certain user or environment.
In my opinion, commercial broadcast receivers for consumer
use are definitely to be excluded (for now).

The notification aspect  is definitely only for intentional
radiators, the scope of this may be taken wide, however.

I personnally would never even think of notifying a radio
receiver to the authorities. None of their business , and...

Notification is related to effective use of the spectrum,
unless your receiver is intentionally radiating, no
impact on spectrum is to be expected.

Gert Gremmen
ce-test



-Original Message-
From: owner-emc-p...@majordomo.ieee.org
[mailto:owner-emc-p...@majordomo.ieee.org]On Behalf Of
richwo...@tycoint.com
Sent: dinsdag 15 oktober 2002 19:09
To: emc-p...@majordomo.ieee.org
Subject: RE: RTTE - receive only equipment



Good question Amund. I found nothing in the Directive that provides a clear
direction. I think that sound of silence from the rest of the group means
that no one knows the answer. I checked the UK's notification form and there
is only one place where they ask about the receiver:

"Duplex direction (if applicable)
This should state simplex, ½ duplex or duplex operation. If duplex please
quote, where applicable, transmit and receive frequencies and/or duplex
split."

It's a mystery.

Richard Woods
Sensormatic Electronics
Tyco International


-Original Message-
From: am...@westin-emission.no [mailto:am...@westin-emission.no]
Sent: Monday, October 14, 2002 8:43 AM
To: emc-p...@majordomo.ieee.org
Subject: RTTE - receive only equipment



As far as I understand the RTTED, the directive also applies to radio
receive-only equipment. But are we required to notify it for each member
state within EU, if it use non-harmonized frequency bands ?

Best regards
Amund Westin, Oslo / Norway




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RE: RTTE - receive only equipment

[john . radomski]

The following explanation can be found in "Frequently Asked Questions (FAQ)
about the RTTE Directive (1999/5/EC) Prepared by the ERC WG RR (version 27
January 2000)":

Notification under Article 6.4 is required for radio equipment covered by
the following definition:
Radio equipment which uses frequency bands whose use is not harmonised
throughout the Community. This is considered to be all radio equipment
except those:
· which can only transmit under the control of a network; or
· which use a frequency band which is allocated to the same radio
interface in every Member State in the following way:
a)there is a common frequency allocation; and
b)within this allocation, the allotment and/or assignment of radio
frequencies or radio frequency channels follows a common plan or
arrangement; and
c)the equipment satisfies common parameters (e.g. frequency, power,
duty cycle, bandwidth, etc.); or
· which do not transmit.

John Radomski
Schneider Electric (Modicon)





richwo...@tycoint.com@majordomo.ieee.org on 10/15/2002 01:09:11 PM

Please respond to richwo...@tycoint.com

Sent by:owner-emc-p...@majordomo.ieee.org


To:emc-p...@majordomo.ieee.org
cc:

Subject:    RE: RTTE - receive only equipment



Good question Amund. I found nothing in the Directive that provides a clear
direction. I think that sound of silence from the rest of the group means
that no one knows the answer. I checked the UK's notification form and
there
is only one place where they ask about the receiver:

"Duplex direction (if applicable)
This should state simplex, ½ duplex or duplex operation. If duplex please
quote, where applicable, transmit and receive frequencies and/or duplex
split."

It's a mystery.

Richard Woods
Sensormatic Electronics
Tyco International


-Original Message-
From: am...@westin-emission.no [mailto:am...@westin-emission.no]
Sent: Monday, October 14, 2002 8:43 AM
To: emc-p...@majordomo.ieee.org
Subject: RTTE - receive only equipment



As far as I understand the RTTED, the directive also applies to radio
receive-only equipment. But are we required to notify it for each member
state within EU, if it use non-harmonized frequency bands ?

Best regards
Amund Westin, Oslo / Norway




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RE: RTTE - receive only equipment

[richwoods]

Good question Amund. I found nothing in the Directive that provides a clear
direction. I think that sound of silence from the rest of the group means
that no one knows the answer. I checked the UK's notification form and there
is only one place where they ask about the receiver:

"Duplex direction (if applicable)
This should state simplex, ½ duplex or duplex operation. If duplex please
quote, where applicable, transmit and receive frequencies and/or duplex
split."

It's a mystery.

Richard Woods
Sensormatic Electronics
Tyco International


-Original Message-
From: am...@westin-emission.no [mailto:am...@westin-emission.no]
Sent: Monday, October 14, 2002 8:43 AM
To: emc-p...@majordomo.ieee.org
Subject: RTTE - receive only equipment



As far as I understand the RTTED, the directive also applies to radio
receive-only equipment. But are we required to notify it for each member
state within EU, if it use non-harmonized frequency bands ?

Best regards
Amund Westin, Oslo / Norway




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RE: RTTE or LVD for Equipment with E1 SELV interface

[Joe Finlayson]

Paul,

I agree with your statements below.  I also agree that test reports
to the applicable interface standards may be required in other countries.  I
further agree that certain network operators within the European Union may
require said test reports as part of their procurement requirements.  My
charter is to advise management of the *legal* requirements to ship a
product into a particular region.   However, spending money and allocating
resources prematurely under the current market conditions would be frowned
upon at my company.  I have non doubt that I will end up testing to ETSI
TBR's although we would rather delay project until it is necessary.

Thx,


Joe

-Original Message-
From: Paul Didcott [mailto:pdidc...@ktl.com]
Sent: Thursday, October 03, 2002 4:34 AM
To: 'Joe Finlayson'
Cc: TREG Newsgroup; 'EMC PSTC'; 'NEBS Newsgroup'
Subject: RE: RTTE or LVD for Equipment with E1 SELV interface



Joe,

The situation is sublimely simple really.

If the equipment will ever be sold as 'Terminal Equipment' (the R&TTED
definition has already been given in this thread), it falls within the scope
of the R&TTED.  If it will only ever be sold direct to the public network
operators within the EU/EFTA countries, and used internal to the network, it
is outside of the scope of the R&TTED.  (NB: Network Operators will have
there own 'procurement requirements').

As per my post on the 2nd Oct:
>>E1 equipment designed for connection to a public telecom network service
(i.e. as terminal equipment), must be CE marked for compliance with the
R&TTED.  However, the applicable (harmonised) standards will be exactly the
same for EMC and Safety compliance under the R&TTED as would apply under the
EMC Directive and LVD.

Regarding your question:
>>Is there anyone out there who was involved in the draft of the R&TTE
that can comment on the intent?

For what it's worth, I have lectured on the application of the R&TTED at
least 1/2 a dozen times with Mark Bogers in attendance, as well as run
seminars on the application of the R&TTED within CEE 'Accession Countries'
on behalf of the European Commission, in conjunction with Stewart Davidson
(R&TTED Committee Secretary).  I'm not a betting man, but hope the above
provides further clarity :-).

A further note:
Whilst the choice of standards under the R&TTED is 'voluntary', compliance
with the specified 'harmonised standards' provides a legal 'presumption of
conformity', which simply means that the responsible person placing the
equipment on the market has no need to provide further evidence of
compliance.  Hence there is a legal benefit in using 'harmonised standards',
plus a commercial benefit as the usual EMC and Safety standards may be used
in many countries outside of the EU.  There is no need to use an accredited
lab for compliance with the EMC/LVD or R&TTE Directives.  Although reports
from 'recognised labs' are beneficial for many other markets.   - Hence a
rational compliance strategy is always advisable, giving due consideration
to all potential markets. 

Best regards,

Paul G Didcott 
Snr Approvals Consultant
Compliance Management Dept. 
Tel: +44 (0) 1482 801801
Fax: +44 (0) 1482 801806

Laboratory Accreditation Services Ltd t/a KTL. Registered No. 4407692. 
Registered Office: KTL, Saxon Way, Priory Park West, Hull, HU13 9PB, UK.
<http://www.ktl.com>


-Original Message-
From: Joe Finlayson [mailto:jfinlay...@telica.com]
Sent: 02 October 2002 19:56
To: TREG Newsgroup; 'EMC PSTC'; 'NEBS Newsgroup'
Subject: RE: RTTE or LVD for Equipment with E1 SELV interface


Roger,

Thanks for the contact.  I will do just that and post the response
from Mr. Bogers.  Anyone want to bet a beer on this one??   ;-)

Thx,


Joe

-Original Message-----
From: Roger Magnuson [mailto:ro...@tgc.se]
Sent: Wednesday, October 02, 2002 2:07 PM
To: Joe Finlayson; 'Clement Dave-LDC009'; TREG Newsgroup; 'EMC PSTC'; 'NEBS
Newsgroup'
Cc: Roger Magnuson
Subject: RE: RTTE or LVD for Equipment with E1 SELV interface


Joe et al,

It seems a little overambitious to declare it under R&TTE as Network
Equipment did not even require type approval under the old TTE Directive. If
you need a comment right from the source I suggest you contact Mark Bogers
(mark.bog...@cec.eu.int), he is the contact point for R&TTE issues.

Roger Magnuson
TGC Communication AB

-Original Message-
From: treg-appro...@world.std.com [mailto:treg-appro...@world.std.com]On
Behalf Of Joe Finlayson
Sent: den 2 oktober 2002 19:09
To: 'Clement Dave-LDC009'; TREG Newsgroup; 'EMC PSTC'; 'NEBS Newsgroup'
Subject: RE: RTTE or LVD for Equipment with E1 SELV interface


Dave,

My position was based on my particular interface (in t

RE: RTTE or LVD for Equipment with E1 SELV interface

[colin_mcgeechan]

Alain et al,

Looking on this web site (http://approval.rrl.go.kr/eng/index.html) I found the 
following exception:

Equipment exempt from certification according to Article 4 of the "Regulations 
for certification of information and communication equipment" and Article 2 of 
the "Enforcement Guidelines for the Certification of Information and 
communication" are as following; 
4.  Equipment, requiring type approval, to be used (including installed by it's 
end-users) by common carriers, and transmission network operators 
(in the case of special category telecommunications service providers, terminal 
equipment and it's accompaniment are exempt) 

I think I'll try this first.

Cheers,

Colin.


-Original Message-
From: alain.sam...@gigabyte.com.tw [mailto:alain.sam...@gigabyte.com.tw]
Sent: 03 October 2002 13:20
To: colin_mcgeec...@agilent.com; t...@world.std.com; emc-p...@ieee.org; 
n...@world.std.com
Subject: RE: RTTE or LVD for Equipment with E1 SELV interface


Dear Colin,

TTE to be approved are, according to the wording used in the Korean ministry 
decree:
1- Equipment which can be connected directly to a demarcation point of backbone 
communication network.

2- Equipment not directly connected to a demarcation point of backbone 
communication network, and which can cause harm to the backbone communication 
network: 
2.1) TTE which can be used separately without the system. (if the TTE has to be 
bundle to the system, then has to be approved as part as the system's type 
approval)
2.2) TTE for Integrated Service Digital Network (ISDN) 
2.3) Digital communications devices directly connected to Channel Service Units 
("CSU") 

3- TTE directly connected to the demarcation point of a transmission network

All these 3 points are explained at the RRL website: 
http://approval.rrl.go.kr/eng/sec01_02_1.html
The text of the decrees are at: http://approval.rrl.go.kr/eng/erow1.html

So I believe the point of the dicussion is to precise at which point(s) only 
can your equipement be used (intentionally or unintentionally).
Hope this helps

Alain Sam-Lai
Gigabyte Technolgy
mailto:alain.sam...@gigabyte.com.tw



-Original Message-
From: colin_mcgeec...@agilent.com [mailto:colin_mcgeec...@agilent.com] 
Sent: Thursday, October 03, 2002 6:32 PM
To: t...@world.std.com; emc-p...@ieee.org; n...@world.std.com
Cc: colin_mcgeec...@agilent.com
Subject: RE: RTTE or LVD for Equipment with E1 SELV interface


Hi All,

I have some Network Equipment with DS1 and E1/T1 interfaces, it is for use 
within the Telco Central Office and while I believe it to be outwith the scope 
of the R&TTE I find that in Korea this type of interface requires a Telecom 
type approval (according to the Korean Test Lab - Estech Co,Ltd).

I am trying to argue the point, but have not read the regulations (I'm trying 
to get a translation) and therefore can't put this into context. Has anyone 
else experienced similar requirements for Korea?

Thanks and regards.

Colin McGeechan 
Product Regulations Specialist 
Telecomms Networks Test Division

Agilent Technologies UK Limited 
West Lothian 
Scotland EH30 9TG 

+44 (0)131 331 7196 Tel
3132196 TN 
+44 (0)131 331 6075 Fax
www.agilent.com

Registered Office: Eskdale Road, Winnersh Triangle, Wokingham, Berkshire, RG41 
5DZ. Registered Number: 03809903 England  

-Original Message-
From: Joe Finlayson [mailto:jfinlay...@telica.com]
Sent: 02 October 2002 19:56
To: TREG Newsgroup; 'EMC PSTC'; 'NEBS Newsgroup'
Subject: RE: RTTE or LVD for Equipment with E1 SELV interface


Roger,

Thanks for the contact.  I will do just that and post the response
from Mr. Bogers.  Anyone want to bet a beer on this one??   ;-)

Thx,


Joe

-Original Message-
From: Roger Magnuson [mailto:ro...@tgc.se]
Sent: Wednesday, October 02, 2002 2:07 PM
To: Joe Finlayson; 'Clement Dave-LDC009'; TREG Newsgroup; 'EMC PSTC'; 'NEBS 
Newsgroup'
Cc: Roger Magnuson
Subject: RE: RTTE or LVD for Equipment with E1 SELV interface


Joe et al,

It seems a little overambitious to declare it under R&TTE as Network Equipment 
did not even require type approval under the old TTE Directive. If you need a 
comment right from the source I suggest you contact Mark Bogers 
(mark.bog...@cec.eu.int), he is the contact point for R&TTE issues.

Roger Magnuson
TGC Communication AB

-Original Message-
From: treg-appro...@world.std.com [mailto:treg-appro...@world.std.com]On
Behalf Of Joe Finlayson
Sent: den 2 oktober 2002 19:09
To: 'Clement Dave-LDC009'; TREG Newsgroup; 'EMC PSTC'; 'NEBS Newsgroup'
Subject: RE: RTTE or LVD for Equipment with E1 SELV interface


Dave,

My position was based on my particular interface (in this case also E1) 
and, based on my interpretation, concluded that it does not fall under the 
scope of the R&TTE Directive.  Based on your exampl

RE: RTTE or LVD for Equipment with E1 SELV interface

[John Czyzewicz]

Hi Colin,

I'd try another test lab, and if possible, ask your customer (they may want
it to make them feel good).

I did not do any telco testing on our  E1 boards that use SS7 (C.O.
location) and did not have a problem with the RRL.
You will still need to do EMC and safety .

Of course, rules do change.  ;o)

   John Czyzewicz
   NMS Communications






  colin_mcgeechan@a 

  gilent.com   To:   t...@world.std.com, 
emc-p...@ieee.org, 
  Sent by:  n...@world.std.com  

  treg-approval@worcc:   
colin_mcgeec...@agilent.com
  ld.std.com   Subject:  RE: RTTE or LVD for 
Equipment with E1 SELV 
interface   



  10/03/2002 06:31  

  AM

  Please respond to 

  colin_mcgeechan   









Hi All,

I have some Network Equipment with DS1 and E1/T1 interfaces, it is for use
within the Telco Central Office and while I believe it to be outwith the
scope of the R&TTE I find that in Korea this type of interface requires a
Telecom type approval (according to the Korean Test Lab - Estech Co,Ltd).

I am trying to argue the point, but have not read the regulations (I'm
trying to get a translation) and therefore can't put this into context. Has
anyone else experienced similar requirements for Korea?

Thanks and regards.

Colin McGeechan
Product Regulations Specialist
Telecomms Networks Test Division

Agilent Technologies UK Limited
West Lothian
Scotland EH30 9TG

+44 (0)131 331 7196 Tel
3132196 TN
+44 (0)131 331 6075 Fax
www.agilent.com

Registered Office: Eskdale Road, Winnersh Triangle, Wokingham,
Berkshire, RG41 5DZ. Registered Number: 03809903 England

-Original Message-
From: Joe Finlayson [mailto:jfinlay...@telica.com]
Sent: 02 October 2002 19:56
To: TREG Newsgroup; 'EMC PSTC'; 'NEBS Newsgroup'
Subject: RE: RTTE or LVD for Equipment with E1 SELV interface


Roger,

 Thanks for the contact.  I will do just that and post the response
from Mr. Bogers.  Anyone want to bet a beer on this one??   ;-)

Thx,


Joe

-Original Message-
From: Roger Magnuson [mailto:ro...@tgc.se]
Sent: Wednesday, October 02, 2002 2:07 PM
To: Joe Finlayson; 'Clement Dave-LDC009'; TREG Newsgroup; 'EMC PSTC'; 'NEBS
Newsgroup'
Cc: Roger Magnuson
Subject: RE: RTTE or LVD for Equipment with E1 SELV interface


Joe et al,

It seems a little overambitious to declare it under R&TTE as Network
Equipment did not even require type approval under the old TTE Directive.
If
you need a comment right from the source I suggest you contact Mark Bogers
(mark.bog...@cec.eu.int), he is the contact point for R&TTE issues.

Roger Magnuson
TGC Communication AB

-Original Message-
From: treg-appro...@world.std.com [mailto:treg-appro...@world.std.com]On
Behalf Of Joe Finlayson
Sent: den 2 oktober 2002 19:09
To: 'Clement Dave-LDC009'; TREG Newsgroup; 'EMC PSTC'; 'NEBS Newsgroup'
Subject: RE: RTTE or LVD for Equipment with E1 SELV interface


Dave,

My position was based on my particular interface (in this case also E1)
and, based on my interpretation, concluded that it does not fall under the
scope of the R&TTE Directive.  Based on your examples below, I can see that
apparently there are PSTN interfaces that can be classified as SELV.  We
definitely seem to have a divided field here.  I've seen posts stating
"Absolutely R&TTE" as well as "Absolutely not R&TTE".

Is there anyone out there who was involved in the draft of the R&TTE
that can comment on the intent?

Thx,


Joe
-Original Message-
From: Clement Dave-LDC009 [mailto:dave.clem...@motorola.com]
Sent: Wednesday, October 02, 2002 11:47 AM
To: 'Joe Finlayson'; TREG Newsgroup; 'EMC PST

RE: RTTE or LVD for Equipment with E1 SELV interface

[岑國綸]

Dear Colin,

TTE to be approved are, according to the wording used in the Korean ministry 
decree:
1- Equipment which can be connected directly to a demarcation point of backbone 
communication network.

2- Equipment not directly connected to a demarcation point of backbone 
communication network, and which can cause harm to the backbone communication 
network: 
2.1) TTE which can be used separately without the system. (if the TTE has to be 
bundle to the system, then has to be approved as part as the system's type 
approval)
2.2) TTE for Integrated Service Digital Network (ISDN) 
2.3) Digital communications devices directly connected to Channel Service Units 
("CSU") 

3- TTE directly connected to the demarcation point of a transmission network

All these 3 points are explained at the RRL website: 
http://approval.rrl.go.kr/eng/sec01_02_1.html
The text of the decrees are at: http://approval.rrl.go.kr/eng/erow1.html

So I believe the point of the dicussion is to precise at which point(s) only 
can your equipement be used (intentionally or unintentionally).
Hope this helps

Alain Sam-Lai
Gigabyte Technolgy
mailto:alain.sam...@gigabyte.com.tw



-Original Message-
From: colin_mcgeec...@agilent.com [mailto:colin_mcgeec...@agilent.com] 
Sent: Thursday, October 03, 2002 6:32 PM
To: t...@world.std.com; emc-p...@ieee.org; n...@world.std.com
Cc: colin_mcgeec...@agilent.com
Subject: RE: RTTE or LVD for Equipment with E1 SELV interface


Hi All,

I have some Network Equipment with DS1 and E1/T1 interfaces, it is for use 
within the Telco Central Office and while I believe it to be outwith the scope 
of the R&TTE I find that in Korea this type of interface requires a Telecom 
type approval (according to the Korean Test Lab - Estech Co,Ltd).

I am trying to argue the point, but have not read the regulations (I'm trying 
to get a translation) and therefore can't put this into context. Has anyone 
else experienced similar requirements for Korea?

Thanks and regards.

Colin McGeechan 
Product Regulations Specialist 
Telecomms Networks Test Division

Agilent Technologies UK Limited 
West Lothian 
Scotland EH30 9TG 

+44 (0)131 331 7196 Tel
3132196 TN 
+44 (0)131 331 6075 Fax
www.agilent.com

Registered Office: Eskdale Road, Winnersh Triangle, Wokingham, Berkshire, RG41 
5DZ. Registered Number: 03809903 England  

-Original Message-
From: Joe Finlayson [mailto:jfinlay...@telica.com]
Sent: 02 October 2002 19:56
To: TREG Newsgroup; 'EMC PSTC'; 'NEBS Newsgroup'
Subject: RE: RTTE or LVD for Equipment with E1 SELV interface


Roger,

Thanks for the contact.  I will do just that and post the response
from Mr. Bogers.  Anyone want to bet a beer on this one??   ;-)

Thx,


Joe

-Original Message-
From: Roger Magnuson [mailto:ro...@tgc.se]
Sent: Wednesday, October 02, 2002 2:07 PM
To: Joe Finlayson; 'Clement Dave-LDC009'; TREG Newsgroup; 'EMC PSTC'; 'NEBS 
Newsgroup'
Cc: Roger Magnuson
Subject: RE: RTTE or LVD for Equipment with E1 SELV interface


Joe et al,

It seems a little overambitious to declare it under R&TTE as Network Equipment 
did not even require type approval under the old TTE Directive. If you need a 
comment right from the source I suggest you contact Mark Bogers 
(mark.bog...@cec.eu.int), he is the contact point for R&TTE issues.

Roger Magnuson
TGC Communication AB

-Original Message-
From: treg-appro...@world.std.com [mailto:treg-appro...@world.std.com]On
Behalf Of Joe Finlayson
Sent: den 2 oktober 2002 19:09
To: 'Clement Dave-LDC009'; TREG Newsgroup; 'EMC PSTC'; 'NEBS Newsgroup'
Subject: RE: RTTE or LVD for Equipment with E1 SELV interface


Dave,

My position was based on my particular interface (in this case also E1) 
and, based on my interpretation, concluded that it does not fall under the 
scope of the R&TTE Directive.  Based on your examples below, I can see that 
apparently there are PSTN interfaces that can be classified as SELV.  We 
definitely seem to have a divided field here.  I've seen posts stating 
"Absolutely R&TTE" as well as "Absolutely not R&TTE".

Is there anyone out there who was involved in the draft of the R&TTE that 
can comment on the intent?

Thx,


Joe
-Original Message-
From: Clement Dave-LDC009 [mailto:dave.clem...@motorola.com]
Sent: Wednesday, October 02, 2002 11:47 AM
To: 'Joe Finlayson'; TREG Newsgroup; 'EMC PSTC'; 'NEBS Newsgroup'
Subject: RE: RTTE or LVD for Equipment with E1 SELV interface


Joe,

Maybe I have missed something here but how does the TNV-X vs SELV from a safety 
perspective define if the product falls under the R&TTE Directive?

Many telcom interfaces are SELV from a safety perspective and clearly fall 
under the R&TTE Directive. For example; V.11/V.24/V.35/X.21 when connected to 
WAN services via a CSU/DSU a

RE: RTTE or LVD for Equipment with E1 SELV interface

[Andre, Pierre-Marie]

Colin,
You have to be carefull about what Korea RRL is stating by "telecom" type 
approval.
We have experience with VPN product without connections to the Public Network 
and they have requested "telecom" approval tests.
Mainly the tests consist of  EMI/EMC tests 

I hope this help
Pierre-Marie Andre
Sophia Certification and Environmental Labs
Intel Corp.Senior Approval Engineer
Tel : +33 (0) 4 93 00 14 13   Fax : +33 (0) 4 93 00 14 01
> http://www.intel.fr/
> 


-Original Message-
From: colin_mcgeec...@agilent.com [mailto:colin_mcgeec...@agilent.com]
Sent: jeudi 3 octobre 2002 12:32
To: t...@world.std.com; emc-p...@ieee.org; n...@world.std.com
Cc: colin_mcgeec...@agilent.com
Subject: RE: RTTE or LVD for Equipment with E1 SELV interface


Hi All,

I have some Network Equipment with DS1 and E1/T1 interfaces, it is for use 
within the Telco Central Office and while I believe it to be outwith the scope 
of the R&TTE I find that in Korea this type of interface requires a Telecom 
type approval (according to the Korean Test Lab - Estech Co,Ltd).

I am trying to argue the point, but have not read the regulations (I'm trying 
to get a translation) and therefore can't put this into context. Has anyone 
else experienced similar requirements for Korea?

Thanks and regards.

Colin McGeechan 
Product Regulations Specialist 
Telecomms Networks Test Division

Agilent Technologies UK Limited 
West Lothian 
Scotland EH30 9TG 

+44 (0)131 331 7196 Tel
3132196 TN 
+44 (0)131 331 6075 Fax
www.agilent.com

Registered Office: Eskdale Road, Winnersh Triangle, Wokingham,
Berkshire, RG41 5DZ. Registered Number: 03809903 England  

-Original Message-
From: Joe Finlayson [mailto:jfinlay...@telica.com]
Sent: 02 October 2002 19:56
To: TREG Newsgroup; 'EMC PSTC'; 'NEBS Newsgroup'
Subject: RE: RTTE or LVD for Equipment with E1 SELV interface


Roger,

Thanks for the contact.  I will do just that and post the response
from Mr. Bogers.  Anyone want to bet a beer on this one??   ;-)

Thx,


Joe

-Original Message-
From: Roger Magnuson [mailto:ro...@tgc.se]
Sent: Wednesday, October 02, 2002 2:07 PM
To: Joe Finlayson; 'Clement Dave-LDC009'; TREG Newsgroup; 'EMC PSTC'; 'NEBS
Newsgroup'
Cc: Roger Magnuson
Subject: RE: RTTE or LVD for Equipment with E1 SELV interface


Joe et al,

It seems a little overambitious to declare it under R&TTE as Network
Equipment did not even require type approval under the old TTE Directive. If
you need a comment right from the source I suggest you contact Mark Bogers
(mark.bog...@cec.eu.int), he is the contact point for R&TTE issues.

Roger Magnuson
TGC Communication AB

-Original Message-
From: treg-appro...@world.std.com [mailto:treg-appro...@world.std.com]On
Behalf Of Joe Finlayson
Sent: den 2 oktober 2002 19:09
To: 'Clement Dave-LDC009'; TREG Newsgroup; 'EMC PSTC'; 'NEBS Newsgroup'
Subject: RE: RTTE or LVD for Equipment with E1 SELV interface


Dave,

My position was based on my particular interface (in this case also E1)
and, based on my interpretation, concluded that it does not fall under the
scope of the R&TTE Directive.  Based on your examples below, I can see that
apparently there are PSTN interfaces that can be classified as SELV.  We
definitely seem to have a divided field here.  I've seen posts stating
"Absolutely R&TTE" as well as "Absolutely not R&TTE".

Is there anyone out there who was involved in the draft of the R&TTE
that can comment on the intent?

Thx,


Joe
-Original Message-
From: Clement Dave-LDC009 [mailto:dave.clem...@motorola.com]
Sent: Wednesday, October 02, 2002 11:47 AM
To: 'Joe Finlayson'; TREG Newsgroup; 'EMC PSTC'; 'NEBS Newsgroup'
Subject: RE: RTTE or LVD for Equipment with E1 SELV interface


Joe,

Maybe I have missed something here but how does the TNV-X vs SELV from a
safety perspective define if the product falls under the R&TTE Directive?

Many telcom interfaces are SELV from a safety perspective and clearly fall
under the R&TTE Directive. For example; V.11/V.24/V.35/X.21 when connected
to WAN services via a CSU/DSU and ISDN Basic Rate S/T.

Also, I believe Peter's original post stated intrabuilding and did not state
it was CO equipment. In any case there are expectations and I believe you
are going to spend more time trying to justify why you did not declare to
the R&TTE than if you just do it. Again because of expectations I would have
a TBR12/13 test report to back up the declaration even if it's no longer
mandatory. NOTE: meeting the over voltage requirements of these standards
has nothing to do with the classification of the port from a safety
standpoint since the surges are applied to the AC mains (not even applicable
ifDC powered)

Dave Clement
Motorola Inc

Re: RTTE or LVD for Equipment with E1 SELV interface

[Martin Garwood]

Hi Colin,

In Sth Korea, Products incoprorating serial WAN, analog, digital, optical 
interfaces require telecom type approval and certification by the RRL, 
irrespective of location. 
By definition, telecom type approval requires telecom, EMC and safety testing 
to be performed by an accredited Korean lab (or those noted within the Sth 
Korea - Canada MRA). 

Telecom requirements and testing is largely based on FCC Part 68 (though as 
evident by the above definition of "telecom products" subject to approval, 
scope is significantly more expanded than FCC Part 68). EMC test requirements 
are essentially the Korean implementations of CISPR 22 and CISPR 24 standards. 
Safety is based on IEC 60950. For purposes of the MIC/RRL certification 
process, however, ALL 3 disciplines must be carried out in full by an 
accredited lab. 

Happy to quote or discuss further off line.

Best,
Martin.
Martin Garwood
Approval Specialists Pty. Limited
http://www.approvalspecialists.com


  - Original Message - 
  From: colin_mcgeec...@agilent.com 
  To: t...@world.std.com ; emc-p...@ieee.org ; n...@world.std.com 
  Cc: colin_mcgeec...@agilent.com 
  Sent: Thursday, October 03, 2002 3:31 AM
  Subject: RE: RTTE or LVD for Equipment with E1 SELV interface


  Hi All,

  I have some Network Equipment with DS1 and E1/T1 interfaces, it is for use 
within the Telco Central Office and while I believe it to be outwith the scope 
of the R&TTE I find that in Korea this type of interface requires a Telecom 
type approval (according to the Korean Test Lab - Estech Co,Ltd).

  I am trying to argue the point, but have not read the regulations (I'm trying 
to get a translation) and therefore can't put this into context. Has anyone 
else experienced similar requirements for Korea?

  Thanks and regards.

  Colin McGeechan 
  Product Regulations Specialist 
  Telecomms Networks Test Division

  Agilent Technologies UK Limited 
  West Lothian 
  Scotland EH30 9TG 

  +44 (0)131 331 7196 Tel
  3132196 TN 
  +44 (0)131 331 6075 Fax
  www.agilent.com

  Registered Office: Eskdale Road, Winnersh Triangle, Wokingham,
  Berkshire, RG41 5DZ. Registered Number: 03809903 England  

  -Original Message-
  From: Joe Finlayson [mailto:jfinlay...@telica.com]
  Sent: 02 October 2002 19:56
  To: TREG Newsgroup; 'EMC PSTC'; 'NEBS Newsgroup'
  Subject: RE: RTTE or LVD for Equipment with E1 SELV interface


  Roger,

  Thanks for the contact.  I will do just that and post the response
  from Mr. Bogers.  Anyone want to bet a beer on this one??   ;-)

  Thx,


  Joe

  -Original Message-
  From: Roger Magnuson [mailto:ro...@tgc.se]
  Sent: Wednesday, October 02, 2002 2:07 PM
  To: Joe Finlayson; 'Clement Dave-LDC009'; TREG Newsgroup; 'EMC PSTC'; 'NEBS
  Newsgroup'
  Cc: Roger Magnuson
  Subject: RE: RTTE or LVD for Equipment with E1 SELV interface


  Joe et al,

  It seems a little overambitious to declare it under R&TTE as Network
  Equipment did not even require type approval under the old TTE Directive. If
  you need a comment right from the source I suggest you contact Mark Bogers
  (mark.bog...@cec.eu.int), he is the contact point for R&TTE issues.

  Roger Magnuson
  TGC Communication AB

  -Original Message-
  From: treg-appro...@world.std.com [mailto:treg-appro...@world.std.com]On
  Behalf Of Joe Finlayson
  Sent: den 2 oktober 2002 19:09
  To: 'Clement Dave-LDC009'; TREG Newsgroup; 'EMC PSTC'; 'NEBS Newsgroup'
  Subject: RE: RTTE or LVD for Equipment with E1 SELV interface


  Dave,

  My position was based on my particular interface (in this case also E1)
  and, based on my interpretation, concluded that it does not fall under the
  scope of the R&TTE Directive.  Based on your examples below, I can see that
  apparently there are PSTN interfaces that can be classified as SELV.  We
  definitely seem to have a divided field here.  I've seen posts stating
  "Absolutely R&TTE" as well as "Absolutely not R&TTE".

  Is there anyone out there who was involved in the draft of the R&TTE
  that can comment on the intent?

  Thx,


  Joe
  -Original Message-
  From: Clement Dave-LDC009 [mailto:dave.clem...@motorola.com]
  Sent: Wednesday, October 02, 2002 11:47 AM
  To: 'Joe Finlayson'; TREG Newsgroup; 'EMC PSTC'; 'NEBS Newsgroup'
  Subject: RE: RTTE or LVD for Equipment with E1 SELV interface


  Joe,

  Maybe I have missed something here but how does the TNV-X vs SELV from a
  safety perspective define if the product falls under the R&TTE Directive?

  Many telcom interfaces are SELV from a safety perspective and clearly fall
  under the R&TTE Directive. For example; V.11/V.24/V.35/X.21 when connected
  to WAN services via a CSU/DSU and ISDN Basic Rate S/T.

  Also, I believe Peter's original post stated intrabuilding an

RE: RTTE or LVD for Equipment with E1 SELV interface

[colin_mcgeechan]

Hi All,

I have some Network Equipment with DS1 and E1/T1 interfaces, it is for use 
within the Telco Central Office and while I believe it to be outwith the scope 
of the R&TTE I find that in Korea this type of interface requires a Telecom 
type approval (according to the Korean Test Lab - Estech Co,Ltd).

I am trying to argue the point, but have not read the regulations (I'm trying 
to get a translation) and therefore can't put this into context. Has anyone 
else experienced similar requirements for Korea?

Thanks and regards.

Colin McGeechan 
Product Regulations Specialist 
Telecomms Networks Test Division

Agilent Technologies UK Limited 
West Lothian 
Scotland EH30 9TG 

+44 (0)131 331 7196 Tel
3132196 TN 
+44 (0)131 331 6075 Fax
www.agilent.com

Registered Office: Eskdale Road, Winnersh Triangle, Wokingham,
Berkshire, RG41 5DZ. Registered Number: 03809903 England  

-Original Message-
From: Joe Finlayson [mailto:jfinlay...@telica.com]
Sent: 02 October 2002 19:56
To: TREG Newsgroup; 'EMC PSTC'; 'NEBS Newsgroup'
Subject: RE: RTTE or LVD for Equipment with E1 SELV interface


Roger,

Thanks for the contact.  I will do just that and post the response
from Mr. Bogers.  Anyone want to bet a beer on this one??   ;-)

Thx,


Joe

-Original Message-
From: Roger Magnuson [mailto:ro...@tgc.se]
Sent: Wednesday, October 02, 2002 2:07 PM
To: Joe Finlayson; 'Clement Dave-LDC009'; TREG Newsgroup; 'EMC PSTC'; 'NEBS
Newsgroup'
Cc: Roger Magnuson
Subject: RE: RTTE or LVD for Equipment with E1 SELV interface


Joe et al,

It seems a little overambitious to declare it under R&TTE as Network
Equipment did not even require type approval under the old TTE Directive. If
you need a comment right from the source I suggest you contact Mark Bogers
(mark.bog...@cec.eu.int), he is the contact point for R&TTE issues.

Roger Magnuson
TGC Communication AB

-Original Message-
From: treg-appro...@world.std.com [mailto:treg-appro...@world.std.com]On
Behalf Of Joe Finlayson
Sent: den 2 oktober 2002 19:09
To: 'Clement Dave-LDC009'; TREG Newsgroup; 'EMC PSTC'; 'NEBS Newsgroup'
Subject: RE: RTTE or LVD for Equipment with E1 SELV interface


Dave,

My position was based on my particular interface (in this case also E1)
and, based on my interpretation, concluded that it does not fall under the
scope of the R&TTE Directive.  Based on your examples below, I can see that
apparently there are PSTN interfaces that can be classified as SELV.  We
definitely seem to have a divided field here.  I've seen posts stating
"Absolutely R&TTE" as well as "Absolutely not R&TTE".

Is there anyone out there who was involved in the draft of the R&TTE
that can comment on the intent?

Thx,


Joe
-Original Message-
From: Clement Dave-LDC009 [mailto:dave.clem...@motorola.com]
Sent: Wednesday, October 02, 2002 11:47 AM
To: 'Joe Finlayson'; TREG Newsgroup; 'EMC PSTC'; 'NEBS Newsgroup'
Subject: RE: RTTE or LVD for Equipment with E1 SELV interface


Joe,

Maybe I have missed something here but how does the TNV-X vs SELV from a
safety perspective define if the product falls under the R&TTE Directive?

Many telcom interfaces are SELV from a safety perspective and clearly fall
under the R&TTE Directive. For example; V.11/V.24/V.35/X.21 when connected
to WAN services via a CSU/DSU and ISDN Basic Rate S/T.

Also, I believe Peter's original post stated intrabuilding and did not state
it was CO equipment. In any case there are expectations and I believe you
are going to spend more time trying to justify why you did not declare to
the R&TTE than if you just do it. Again because of expectations I would have
a TBR12/13 test report to back up the declaration even if it's no longer
mandatory. NOTE: meeting the over voltage requirements of these standards
has nothing to do with the classification of the port from a safety
standpoint since the surges are applied to the AC mains (not even applicable
ifDC powered)

Dave Clement
Motorola Inc.
Test Lab Services
Homologation Engineering
20 Cabot Blvd.
Mansfield, MA 02048
P:508-851-8259
F:508-851-8512
C:508-725-9689
mailto:dave.clem...@motorola.com
http://www.motorola.com/globalcompliance/
-Original Message-
From: Joe Finlayson [mailto:jfinlay...@telica.com]
Sent: Wednesday, October 02, 2002 9:29 AM
To: Clement Dave-LDC009; TREG Newsgroup; 'EMC PSTC'; 'NEBS Newsgroup'
Subject: RE: RTTE or LVD for Equipment with E1 SELV interface


Dave,

Please reference the subject title of this thread.  My position is that
by declaring compliance to the R&TTE Directive, we would then be stating
that we have designed to and/or are capable of connecting to the PSTN.  This
would contradict our IEC 60950 SELV classification and would then change our
classification to TNV-X (depend

RE: RTTE or LVD for Equipment with E1 SELV interface

[Joe Finlayson]

Roger,

Thanks for the contact.  I will do just that and post the response
from Mr. Bogers.  Anyone want to bet a beer on this one??   ;-)

Thx,


Joe

-Original Message-
From: Roger Magnuson [mailto:ro...@tgc.se]
Sent: Wednesday, October 02, 2002 2:07 PM
To: Joe Finlayson; 'Clement Dave-LDC009'; TREG Newsgroup; 'EMC PSTC'; 'NEBS
Newsgroup'
Cc: Roger Magnuson
Subject: RE: RTTE or LVD for Equipment with E1 SELV interface


Joe et al,

It seems a little overambitious to declare it under R&TTE as Network
Equipment did not even require type approval under the old TTE Directive. If
you need a comment right from the source I suggest you contact Mark Bogers
(mark.bog...@cec.eu.int), he is the contact point for R&TTE issues.

Roger Magnuson
TGC Communication AB

-Original Message-
From: treg-appro...@world.std.com [mailto:treg-appro...@world.std.com]On
Behalf Of Joe Finlayson
Sent: den 2 oktober 2002 19:09
To: 'Clement Dave-LDC009'; TREG Newsgroup; 'EMC PSTC'; 'NEBS Newsgroup'
Subject: RE: RTTE or LVD for Equipment with E1 SELV interface


Dave,

My position was based on my particular interface (in this case also E1)
and, based on my interpretation, concluded that it does not fall under the
scope of the R&TTE Directive.  Based on your examples below, I can see that
apparently there are PSTN interfaces that can be classified as SELV.  We
definitely seem to have a divided field here.  I've seen posts stating
"Absolutely R&TTE" as well as "Absolutely not R&TTE".

Is there anyone out there who was involved in the draft of the R&TTE
that can comment on the intent?

Thx,


Joe
-Original Message-
From: Clement Dave-LDC009 [mailto:dave.clem...@motorola.com]
Sent: Wednesday, October 02, 2002 11:47 AM
To: 'Joe Finlayson'; TREG Newsgroup; 'EMC PSTC'; 'NEBS Newsgroup'
Subject: RE: RTTE or LVD for Equipment with E1 SELV interface


Joe,

Maybe I have missed something here but how does the TNV-X vs SELV from a
safety perspective define if the product falls under the R&TTE Directive?

Many telcom interfaces are SELV from a safety perspective and clearly fall
under the R&TTE Directive. For example; V.11/V.24/V.35/X.21 when connected
to WAN services via a CSU/DSU and ISDN Basic Rate S/T.

Also, I believe Peter's original post stated intrabuilding and did not state
it was CO equipment. In any case there are expectations and I believe you
are going to spend more time trying to justify why you did not declare to
the R&TTE than if you just do it. Again because of expectations I would have
a TBR12/13 test report to back up the declaration even if it's no longer
mandatory. NOTE: meeting the over voltage requirements of these standards
has nothing to do with the classification of the port from a safety
standpoint since the surges are applied to the AC mains (not even applicable
ifDC powered)

Dave Clement
Motorola Inc.
Test Lab Services
Homologation Engineering
20 Cabot Blvd.
Mansfield, MA 02048
P:508-851-8259
F:508-851-8512
C:508-725-9689
mailto:dave.clem...@motorola.com
http://www.motorola.com/globalcompliance/
-Original Message-
From: Joe Finlayson [mailto:jfinlay...@telica.com]
Sent: Wednesday, October 02, 2002 9:29 AM
To: Clement Dave-LDC009; TREG Newsgroup; 'EMC PSTC'; 'NEBS Newsgroup'
Subject: RE: RTTE or LVD for Equipment with E1 SELV interface


Dave,

Please reference the subject title of this thread.  My position is that
by declaring compliance to the R&TTE Directive, we would then be stating
that we have designed to and/or are capable of connecting to the PSTN.  This
would contradict our IEC 60950 SELV classification and would then change our
classification to TNV-X (depending on the interface).  That would open up a
whole new can of worms and is a good example of how declaring blindly could
leave you in an undesirable situation.

Thx,


Joe

 -Original Message-
From: Clement Dave-LDC009 [mailto:dave.clem...@motorola.com]
Sent: Wednesday, October 02, 2002 9:05 AM
To: 'Joe Finlayson'; TREG Newsgroup
Subject: RE: RTTE or LVD for Equipment with E1 SELV interface


This whole discussion is some what of a moot point. Under the R&TTE
directive there are no mandatory telecom standards anyway.

Dave Clement
Motorola Inc.
Test Lab Services
Homologation Engineering
20 Cabot Blvd.
Mansfield, MA 02048
P:508-851-8259
F:508-851-8512
C:508-725-9689
mailto:dave.clem...@motorola.com
http://www.motorola.com/globalcompliance/
-Original Message-
From: Joe Finlayson [mailto:jfinlay...@telica.com]
Sent: Wednesday, October 02, 2002 8:53 AM
To: 'Pausch, Robert'; TREG Newsgroup
Subject: RE: RTTE or LVD for Equipment with E1 SELV interface


Hi Robert,

I'm glad to see you're still in the game.  I think the issue here is
that "terminal equipment" i

RE: RTTE or LVD for Equipment with E1 SELV interface

[Richard Hughes]

Joe,
 
Perhaps Peter (who works for a test lab and not a manufacturer) could infer
that, because the interface on the product he is evaluating was designed to
be an SELV Circuit, it is not intended to connect to a network that extends
beyond a building and further that the R&TTED does not apply. But that would
presume that his customer knew what he was doing.
 
Peter may find out that his customer does intend to supply the product as an
item of CPE.  In this case he could then deduce that the equipment is
unlikely to be suitable for that purpose (certainly not universally so). 
 
That is why it is wrong to start off looking to see what standards and
aspects of a standard are complied with and then decide which regulations
apply.  
 
Rather, in my opinion, Peter should start by asking his customer what market
the equipment he is evaluating is intended to be supplied into.  He can then
see which standards and attributes of those standards are complied with.
Based on these two items of information he will then be in a position to
advise his client as to whether the product is likely to be suitable for the
intended market.  Always remembering of course that complying with a
Harmonised Standard is only one way of  demonstrating compliance with with
any directive (albeit the most common way).
 
As usual, my own opinions.
 
Regards,
 
Richard Hughes

-Original Message-
From: Joe Finlayson [mailto:jfinlay...@telica.com]
Sent: 02 October 2002 13:30
To: 'Paul Didcott'
Cc: Hughes, Richard [HAL02:GF00:EXCH]; 'EMC PSTC'; 'NEBS Newsgroup'; 'TREG
Newsgroup'
Subject: RE: RTTE or LVD for Equipment with E1 SELV interface


 
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 G

RE: RTTE or LVD for Equipment with E1 SELV interface

[Roger Magnuson]

Joe et al,

It seems a little overambitious to declare it under R&TTE as Network
Equipment did not even require type approval under the old TTE Directive. If
you need a comment right from the source I suggest you contact Mark Bogers
(mark.bog...@cec.eu.int), he is the contact point for R&TTE issues.

Roger Magnuson
TGC Communication AB

-Original Message-
From: treg-appro...@world.std.com [mailto:treg-appro...@world.std.com]On
Behalf Of Joe Finlayson
Sent: den 2 oktober 2002 19:09
To: 'Clement Dave-LDC009'; TREG Newsgroup; 'EMC PSTC'; 'NEBS Newsgroup'
Subject: RE: RTTE or LVD for Equipment with E1 SELV interface


Dave,

My position was based on my particular interface (in this case also E1)
and, based on my interpretation, concluded that it does not fall under the
scope of the R&TTE Directive.  Based on your examples below, I can see that
apparently there are PSTN interfaces that can be classified as SELV.  We
definitely seem to have a divided field here.  I've seen posts stating
"Absolutely R&TTE" as well as "Absolutely not R&TTE".

Is there anyone out there who was involved in the draft of the R&TTE
that can comment on the intent?

Thx,


Joe
-Original Message-
From: Clement Dave-LDC009 [mailto:dave.clem...@motorola.com]
Sent: Wednesday, October 02, 2002 11:47 AM
To: 'Joe Finlayson'; TREG Newsgroup; 'EMC PSTC'; 'NEBS Newsgroup'
Subject: RE: RTTE or LVD for Equipment with E1 SELV interface


Joe,

Maybe I have missed something here but how does the TNV-X vs SELV from a
safety perspective define if the product falls under the R&TTE Directive?

Many telcom interfaces are SELV from a safety perspective and clearly fall
under the R&TTE Directive. For example; V.11/V.24/V.35/X.21 when connected
to WAN services via a CSU/DSU and ISDN Basic Rate S/T.

Also, I believe Peter's original post stated intrabuilding and did not state
it was CO equipment. In any case there are expectations and I believe you
are going to spend more time trying to justify why you did not declare to
the R&TTE than if you just do it. Again because of expectations I would have
a TBR12/13 test report to back up the declaration even if it's no longer
mandatory. NOTE: meeting the over voltage requirements of these standards
has nothing to do with the classification of the port from a safety
standpoint since the surges are applied to the AC mains (not even applicable
ifDC powered)

Dave Clement
Motorola Inc.
Test Lab Services
Homologation Engineering
20 Cabot Blvd.
Mansfield, MA 02048
P:508-851-8259
F:508-851-8512
C:508-725-9689
mailto:dave.clem...@motorola.com
http://www.motorola.com/globalcompliance/
-Original Message-
From: Joe Finlayson [mailto:jfinlay...@telica.com]
Sent: Wednesday, October 02, 2002 9:29 AM
To: Clement Dave-LDC009; TREG Newsgroup; 'EMC PSTC'; 'NEBS Newsgroup'
Subject: RE: RTTE or LVD for Equipment with E1 SELV interface


Dave,

Please reference the subject title of this thread.  My position is that
by declaring compliance to the R&TTE Directive, we would then be stating
that we have designed to and/or are capable of connecting to the PSTN.  This
would contradict our IEC 60950 SELV classification and would then change our
classification to TNV-X (depending on the interface).  That would open up a
whole new can of worms and is a good example of how declaring blindly could
leave you in an undesirable situation.

Thx,


Joe

 -Original Message-----
From: Clement Dave-LDC009 [mailto:dave.clem...@motorola.com]
Sent: Wednesday, October 02, 2002 9:05 AM
To: 'Joe Finlayson'; TREG Newsgroup
Subject: RE: RTTE or LVD for Equipment with E1 SELV interface


This whole discussion is some what of a moot point. Under the R&TTE
directive there are no mandatory telecom standards anyway.

Dave Clement
Motorola Inc.
Test Lab Services
Homologation Engineering
20 Cabot Blvd.
Mansfield, MA 02048
P:508-851-8259
F:508-851-8512
C:508-725-9689
mailto:dave.clem...@motorola.com
http://www.motorola.com/globalcompliance/
-Original Message-
From: Joe Finlayson [mailto:jfinlay...@telica.com]
Sent: Wednesday, October 02, 2002 8:53 AM
To: 'Pausch, Robert'; TREG Newsgroup
Subject: RE: RTTE or LVD for Equipment with E1 SELV interface


Hi Robert,

I'm glad to see you're still in the game.  I think the issue here is
that "terminal equipment" is that which connects directly or indirectly to
the PSTN.  This type of product does neither as it installed in the Central
Office and is NOT in free circulation on the market in the EU (only
available to Network Operators).

Thx,


Joe
-Original Message-
From: Pausch, Robert [mailto:robert.pau...@hp.com]
Sent: Wednesday, October 02, 2002 4:05 AM
To: Joe Finlayson; TREG Newsgroup
Subject: RE: RTTE or LVD for Equipment with E1 SELV interface


Joe,

my position is 

RE: RTTE or LVD for Equipment with E1 SELV interface

[Joe Finlayson]

Dave,
 
My position was based on my particular interface (in this case also E1)
and, based on my interpretation, concluded that it does not fall under the
scope of the R&TTE Directive.  Based on your examples below, I can see that
apparently there are PSTN interfaces that can be classified as SELV.  We
definitely seem to have a divided field here.  I've seen posts stating
"Absolutely R&TTE" as well as "Absolutely not R&TTE".  
 
Is there anyone out there who was involved in the draft of the R&TTE
that can comment on the intent?
 
Thx,
 
 
Joe

-Original Message-
From: Clement Dave-LDC009 [mailto:dave.clem...@motorola.com]
Sent: Wednesday, October 02, 2002 11:47 AM
To: 'Joe Finlayson'; TREG Newsgroup; 'EMC PSTC'; 'NEBS Newsgroup'
Subject: RE: RTTE or LVD for Equipment with E1 SELV interface


Joe,
 
Maybe I have missed something here but how does the TNV-X vs SELV from a
safety perspective define if the product falls under the R&TTE Directive? 
 
Many telcom interfaces are SELV from a safety perspective and clearly fall
under the R&TTE Directive. For example; V.11/V.24/V.35/X.21 when connected
to WAN services via a CSU/DSU and ISDN Basic Rate S/T. 
 
Also, I believe Peter's original post stated intrabuilding and did not state
it was CO equipment. In any case there are expectations and I believe you
are going to spend more time trying to justify why you did not declare to
the R&TTE than if you just do it. Again because of expectations I would have
a TBR12/13 test report to back up the declaration even if it's no longer
mandatory. NOTE: meeting the over voltage requirements of these standards
has nothing to do with the classification of the port from a safety
standpoint since the surges are applied to the AC mains (not even applicable
ifDC powered)
 
Dave Clement 
Motorola Inc. 
Test Lab Services 
Homologation Engineering 
20 Cabot Blvd. 
Mansfield, MA 02048 

P:508-851-8259 
F:508-851-8512 
C:508-725-9689 
mailto:dave.clem...@motorola.com <mailto:dave.clem...@motorola.com>  
http://www.motorola.com/globalcompliance/
<http://www.motorola.com/globalcompliance/>  

-Original Message-
From: Joe Finlayson [mailto:jfinlay...@telica.com]
Sent: Wednesday, October 02, 2002 9:29 AM
To: Clement Dave-LDC009; TREG Newsgroup; 'EMC PSTC'; 'NEBS Newsgroup'
Subject: RE: RTTE or LVD for Equipment with E1 SELV interface


Dave,
 
Please reference the subject title of this thread.  My position is that
by declaring compliance to the R&TTE Directive, we would then be stating
that we have designed to and/or are capable of connecting to the PSTN.  This
would contradict our IEC 60950 SELV classification and would then change our
classification to TNV-X (depending on the interface).  That would open up a
whole new can of worms and is a good example of how declaring blindly could
leave you in an undesirable situation.
 
Thx,
 
 
Joe 
 
 -Original Message-
From: Clement Dave-LDC009 [mailto:dave.clem...@motorola.com]
Sent: Wednesday, October 02, 2002 9:05 AM
To: 'Joe Finlayson'; TREG Newsgroup
Subject: RE: RTTE or LVD for Equipment with E1 SELV interface



This whole discussion is some what of a moot point. Under the R&TTE
directive there are no mandatory telecom standards anyway.
 
Dave Clement 
Motorola Inc. 
Test Lab Services 
Homologation Engineering 
20 Cabot Blvd. 
Mansfield, MA 02048 

P:508-851-8259 
F:508-851-8512 
C:508-725-9689 
mailto:dave.clem...@motorola.com <mailto:dave.clem...@motorola.com>  
http://www.motorola.com/globalcompliance/
<http://www.motorola.com/globalcompliance/>  

-Original Message-
From: Joe Finlayson [mailto:jfinlay...@telica.com]
Sent: Wednesday, October 02, 2002 8:53 AM
To: 'Pausch, Robert'; TREG Newsgroup
Subject: RE: RTTE or LVD for Equipment with E1 SELV interface


Hi Robert,
 
I'm glad to see you're still in the game.  I think the issue here is
that "terminal equipment" is that which connects directly or indirectly to
the PSTN.  This type of product does neither as it installed in the Central
Office and is NOT in free circulation on the market in the EU (only
available to Network Operators).
 
Thx,
 
 
Joe

-Original Message-
From: Pausch, Robert [mailto:robert.pau...@hp.com]
Sent: Wednesday, October 02, 2002 4:05 AM
To: Joe Finlayson; TREG Newsgroup
Subject: RE: RTTE or LVD for Equipment with E1 SELV interface


Joe,
 
my position is that the RTTE directive does apply for all types of radio or
terminal equipment unless 
it has been excluded by article 1(2) or annex I and is in free circulation
on the market in the EU.
However, the RTTE does only specify the essential requirements in article 3
which equipment has to
comply with. It does not regard any specific standard like E1.
 
Peter,
I think You must declare conformity to the RTT directive. What is the po

RE: RTTE or LVD for Equipment with E1 SELV interface

[Clement Dave-LDC009]

Joe,
 
Maybe I have missed something here but how does the TNV-X vs SELV from a safety 
perspective define if the product falls under the R&TTE Directive? 
 
Many telcom interfaces are SELV from a safety perspective and clearly fall 
under the R&TTE Directive. For example; V.11/V.24/V.35/X.21 when connected to 
WAN services via a CSU/DSU and ISDN Basic Rate S/T. 
 
Also, I believe Peter's original post stated intrabuilding and did not state it 
was CO equipment. In any case there are expectations and I believe you are 
going to spend more time trying to justify why you did not declare to the R&TTE 
than if you just do it. Again because of expectations I would have a TBR12/13 
test report to back up the declaration even if it's no longer mandatory. NOTE: 
meeting the over voltage requirements of these standards has nothing to do with 
the classification of the port from a safety standpoint since the surges are 
applied to the AC mains (not even applicable ifDC powered)
 
Dave Clement 
Motorola Inc. 
Test Lab Services 
Homologation Engineering 
20 Cabot Blvd. 
Mansfield, MA 02048 

P:508-851-8259 
F:508-851-8512 
C:508-725-9689 
mailto:dave.clem...@motorola.com <mailto:dave.clem...@motorola.com>  
http://www.motorola.com/globalcompliance/ 
<http://www.motorola.com/globalcompliance/>  

-Original Message-
From: Joe Finlayson [mailto:jfinlay...@telica.com]
Sent: Wednesday, October 02, 2002 9:29 AM
To: Clement Dave-LDC009; TREG Newsgroup; 'EMC PSTC'; 'NEBS Newsgroup'
Subject: RE: RTTE or LVD for Equipment with E1 SELV interface


Dave,
 
Please reference the subject title of this thread.  My position is that by 
declaring compliance to the R&TTE Directive, we would then be stating that we 
have designed to and/or are capable of connecting to the PSTN.  This would 
contradict our IEC 60950 SELV classification and would then change our 
classification to TNV-X (depending on the interface).  That would open up a 
whole new can of worms and is a good example of how declaring blindly could 
leave you in an undesirable situation.
 
Thx,
 
 
Joe 
 
 -Original Message-
From: Clement Dave-LDC009 [mailto:dave.clem...@motorola.com]
Sent: Wednesday, October 02, 2002 9:05 AM
To: 'Joe Finlayson'; TREG Newsgroup
Subject: RE: RTTE or LVD for Equipment with E1 SELV interface



This whole discussion is some what of a moot point. Under the R&TTE directive 
there are no mandatory telecom standards anyway.
 
Dave Clement 
Motorola Inc. 
Test Lab Services 
Homologation Engineering 
20 Cabot Blvd. 
Mansfield, MA 02048 

P:508-851-8259 
F:508-851-8512 
C:508-725-9689 
mailto:dave.clem...@motorola.com <mailto:dave.clem...@motorola.com>  
http://www.motorola.com/globalcompliance/ 
<http://www.motorola.com/globalcompliance/>  

-Original Message-
From: Joe Finlayson [mailto:jfinlay...@telica.com]
Sent: Wednesday, October 02, 2002 8:53 AM
To: 'Pausch, Robert'; TREG Newsgroup
Subject: RE: RTTE or LVD for Equipment with E1 SELV interface


Hi Robert,
 
I'm glad to see you're still in the game.  I think the issue here is that 
"terminal equipment" is that which connects directly or indirectly to the PSTN. 
 This type of product does neither as it installed in the Central Office and is 
NOT in free circulation on the market in the EU (only available to Network 
Operators).
 
Thx,
 
 
Joe

-Original Message-
From: Pausch, Robert [mailto:robert.pau...@hp.com]
Sent: Wednesday, October 02, 2002 4:05 AM
To: Joe Finlayson; TREG Newsgroup
Subject: RE: RTTE or LVD for Equipment with E1 SELV interface


Joe,
 
my position is that the RTTE directive does apply for all types of radio or 
terminal equipment unless 
it has been excluded by article 1(2) or annex I and is in free circulation on 
the market in the EU.
However, the RTTE does only specify the essential requirements in article 3 
which equipment has to
comply with. It does not regard any specific standard like E1.
 
Peter,
I think You must declare conformity to the RTT directive. What is the point not 
to do it?
 
Regards
Robert

Robert Pausch, Regulatory Compliance Engineer 
and Compliance Project Manager
Hewlett-Packard EMEA, Einsteinring 30, 85609 Dornach, Germany 
Tel: +49 (89) 9392 2352, FAX: +49 (89) 9392 2336 
Mailto: robert.pau...@hp.com 


-Original Message-
From: Joe Finlayson [mailto:jfinlay...@telica.com]
Sent: Wednesday, October 02, 2002 12:15 AM
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.

RE: RTTE or LVD for Equipment with E1 SELV interface

[gary . raper]

Joe,

As Dave Clement explained, your product falls under the RTTE directive.
Your Declaration of Conformity to the RTTE directive, is not saying "we
designed to connect to the PSTN", (for connection outside the Central
Office, where the confusion seems to be).  To declare compliance to RTTE,
you look through the standards listed in the Official Journal at Europa for
the directive, 1999/5/EC.  What classification to use has no bearing on the
directive.  Under RTTE, EN 60950 has to be met, and when your compliance
test lab reviews your product to the IEC 60950, the Safety report simply
states the classification.






Joe Finlayson @world.std.com on 10/02/2002 09:28:40
AM

Please respond to n...@world.std.com

Sent by:nebs-appro...@world.std.com


To:"'Clement Dave-LDC009'" , TREG Newsgroup
, "'EMC PSTC'" , "'NEBS
   Newsgroup'"   
cc:
Subject:RE: RTTE or LVD for Equipment with E1 SELV interface



Dave,

    Please reference the subject title  of this thread.  My position is
that by declaring compliance to the  R&TTE Directive, we would then be
stating that we have designed to and/or  are capable of connecting to the
PSTN.  This would contradict our IEC 60950  SELV classification and would
then change our classification to TNV-X (depending  on the interface).
That would open up a whole new can of worms and is  a good example of how
declaring blindly could leave you in an undesirable  situation.

Thx,


Joe

 -Original Message-
From:  Clement Dave-LDC009 [mailto:dave.clem...@motorola.com]
Sent:  Wednesday, October 02, 2002 9:05 AM
To: 'Joe Finlayson'; TREG  Newsgroup
Subject: RE: RTTE or LVD for Equipment with E1 SELV  interface


This whole  discussion is some what of a moot point. Under the R&TTE
directive there  are no mandatory telecom standards anyway.



Dave Clement
Motorola Inc.
Test Lab Services
Homologation  Engineering
20 Cabot Blvd.
Mansfield, MA 02048

P:508-851-8259
F:508-851-8512
C:508-725-9689
mailto:dave.clem...@motorola.com
http://www.motorola.com/globalcompliance/

-Original Message-
From: Joe Finlayson  [mailto:jfinlay...@telica.com]
Sent: Wednesday, October 02, 2002  8:53 AM
To: 'Pausch, Robert'; TREG Newsgroup
Subject: RE:  RTTE or LVD for Equipment with E1 SELV interface


Hi Robert,

    I'm glad to see you're still in the  game.  I think the issue here is
that "terminal equipment" is that which  connects directly or indirectly to
the PSTN.  This type of product does  neither as it installed in the
Central Office and is NOT in free circulation  on the market in the EU
(only available to Network  Operators).

Thx,


Joe
-Original Message-
From: Pausch, Robert  [mailto:robert.pau...@hp.com]
Sent: Wednesday, October 02, 2002  4:05 AM
To: Joe Finlayson; TREG Newsgroup
Subject: RE:  RTTE or LVD for Equipment with E1 SELV interface


Joe,

my position  is that the RTTE directive does apply for all types of radio
or terminal  equipment unless
it  has been excluded by article 1(2) or annex I and is in free circulation
on the market in the EU.
However, the  RTTE does only specify the essential requirements in article
3 which  equipment has to
comply with.  It does not regard any specific standard like E1.

Peter,
I think You  must declare conformity to the RTT directive. What is the
point not to do  it?

Regards
Robert

Robert Pausch, Regulatory Compliance Engineer
and Compliance Project Manager
Hewlett-Packard EMEA,  Einsteinring 30, 85609 Dornach, Germany
Tel: +49  (89) 9392 2352, FAX: +49 (89) 9392 2336
Mailto:  robert.pau...@hp.com
-Original Message-
From: Joe Finlayson  [mailto:jfinlay...@telica.com]
Sent: Wednesday, October 02, 2002  12:15 AM
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&

RE: RTTE or LVD for Equipment with E1 SELV interface

[Gary McInturff]

It's been my interpretation for quiet some time and haven't had any 
repercussions. The "indirectly" is entirely too broad. I think I've used the 
music headphones example in the past. I have a set of headphones, that are 
electrically connected to my speaker. The speaker to the computer motherboard 
and the motherboard to all other systems inside of the computer. Inside the 
computer is a modem, the modem is electrically connected to the public 
telephone system, and the headphones indirectly connected to the modem so 
indirectly connected to the public telephone system. Does that mean my 
headphones fall under the RTT & E directive. I don't believe that is the intent 
of the standard, and the "indirectly" connected statement is an ill thought out 
catch-all phrase.
Gary

-Original Message-
From: Joe Finlayson [mailto:jfinlay...@telica.com]
Sent: Tuesday, October 01, 2002 3:15 PM
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

RE: RTTE or LVD for Equipment with E1 SELV interface

[Joe Finlayson]

Dave,
 
Please reference the subject title of this thread.  My position is that
by declaring compliance to the R&TTE Directive, we would then be stating
that we have designed to and/or are capable of connecting to the PSTN.  This
would contradict our IEC 60950 SELV classification and would then change our
classification to TNV-X (depending on the interface).  That would open up a
whole new can of worms and is a good example of how declaring blindly could
leave you in an undesirable situation.
 
Thx,
 
 
Joe 
 
 -Original Message-
From: Clement Dave-LDC009 [mailto:dave.clem...@motorola.com]
Sent: Wednesday, October 02, 2002 9:05 AM
To: 'Joe Finlayson'; TREG Newsgroup
Subject: RE: RTTE or LVD for Equipment with E1 SELV interface



This whole discussion is some what of a moot point. Under the R&TTE
directive there are no mandatory telecom standards anyway.
 
Dave Clement 
Motorola Inc. 
Test Lab Services 
Homologation Engineering 
20 Cabot Blvd. 
Mansfield, MA 02048 

P:508-851-8259 
F:508-851-8512 
C:508-725-9689 
mailto:dave.clem...@motorola.com <mailto:dave.clem...@motorola.com>  
http://www.motorola.com/globalcompliance/
<http://www.motorola.com/globalcompliance/>  

-Original Message-
From: Joe Finlayson [mailto:jfinlay...@telica.com]
Sent: Wednesday, October 02, 2002 8:53 AM
To: 'Pausch, Robert'; TREG Newsgroup
Subject: RE: RTTE or LVD for Equipment with E1 SELV interface


Hi Robert,
 
I'm glad to see you're still in the game.  I think the issue here is
that "terminal equipment" is that which connects directly or indirectly to
the PSTN.  This type of product does neither as it installed in the Central
Office and is NOT in free circulation on the market in the EU (only
available to Network Operators).
 
Thx,
 
 
Joe

-Original Message-
From: Pausch, Robert [mailto:robert.pau...@hp.com]
Sent: Wednesday, October 02, 2002 4:05 AM
To: Joe Finlayson; TREG Newsgroup
Subject: RE: RTTE or LVD for Equipment with E1 SELV interface


Joe,
 
my position is that the RTTE directive does apply for all types of radio or
terminal equipment unless 
it has been excluded by article 1(2) or annex I and is in free circulation
on the market in the EU.
However, the RTTE does only specify the essential requirements in article 3
which equipment has to
comply with. It does not regard any specific standard like E1.
 
Peter,
I think You must declare conformity to the RTT directive. What is the point
not to do it?
 
Regards
Robert

Robert Pausch, Regulatory Compliance Engineer 
and Compliance Project Manager
Hewlett-Packard EMEA, Einsteinring 30, 85609 Dornach, Germany 
Tel: +49 (89) 9392 2352, FAX: +49 (89) 9392 2336 
Mailto: robert.pau...@hp.com 


-Original Message-
From: Joe Finlayson [mailto:jfinlay...@telica.com]
Sent: Wednesday, October 02, 2002 12:15 AM
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 equip

RE: RTTE or LVD for Equipment with E1 SELV interface

[Joe Finlayson]

 
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 specifica

RE: RTTE or LVD for Equipment with E1 SELV interface

[Joe Finlayson]

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? 

This e-mail message may contain privileged or confidential information. If 
you are not the intended recipient, you may not disclose, use, disseminate, 
distribute, copy or rely upon this message or attachment in any way. If you 
received this e-mail message in error, please return by forwarding the 
message and its attachments to the sender. 






PETER S. MERGUERIAN 
Technical Director 
I.T.L. (Product Testing) Ltd. 
26 Hacharoshet St., POB 211 
O

RE: RTTE or LVD for Equipment with E1 SELV interface

[Richard Hughes]

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]
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]
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?

This e-mail message may contain privileged or confidential information. If
you are not the intended recipient, you may not disclose, use, disseminate,
distribute, copy or rely upon this message or attachment in any way. If you
received this e-mail message in error, please return by forwarding the
message and its attachments to the sender.






PETER S. MERGUERIAN
Technical Director
I.T.L. (Product Testing) Ltd.
26 Hacharoshet St., POB 211
Or Yehuda 60251, Israel
Tel: + 972-(0)3-5339022  Fax: + 972-(0)3-5339019
Mobile: + 972-(0)54-838175
http://www.itl.co.il
http://www.i-spec.com





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RE: RTTE or LVD for Equipment with E1 SELV interface

[Joe Finlayson]

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]
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?

This e-mail message may contain privileged or confidential information. If
you are not the intended recipient, you may not disclose, use, disseminate,
distribute, copy or rely upon this message or attachment in any way. If you
received this e-mail message in error, please return by forwarding the
message and its attachments to the sender.






PETER S. MERGUERIAN
Technical Director
I.T.L. (Product Testing) Ltd.
26 Hacharoshet St., POB 211
Or Yehuda 60251, Israel
Tel: + 972-(0)3-5339022  Fax: + 972-(0)3-5339019
Mobile: + 972-(0)54-838175
http://www.itl.co.il
http://www.i-spec.com





---
This message is from the IEEE EMC Society Product Safety
Technical Committee emc-pstc discussion list.

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RE: RTTE or LVD for Equipment with E1 SELV interface

[Gemma Paolo]

EN 60950 is a harmonized safety standard also for R&TTE.
For the R&TTE is a manufacturer choice to use the old LVD and EMCD rule
to certify the safety and EMC requirement or the new rule of R&TTE
(annex II, III, IV or IV).
Ciao
Paolo

 
_
Paolo Gemma
Siemens Mobile Communications  S.p.A.
PG MW ST EMC & Safety
SS Padana sup. KM 158 20060 Cassina de' Pecchi (MI) Italy
phone +39 02 9526 6587fax +39 02 9526 6203
mobile +39 348 3690185
e-mail paolo.ge...@icn.siemens.it
_
 

> -Original Message-
> From: Peter Merguerian [mailto:pmerguer...@itl.co.il]
> Sent: Tuesday, October 01, 2002 3:33 PM
> 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?
> 
> This e-mail message may contain privileged or confidential
information. If
> you are not the intended recipient, you may not disclose, use,
> disseminate,
> distribute, copy or rely upon this message or attachment in any way.
If
> you
> received this e-mail message in error, please return by forwarding the
> message and its attachments to the sender.
> 
> 
> 
> 
> 
> 
> PETER S. MERGUERIAN
> Technical Director
> I.T.L. (Product Testing) Ltd.
> 26 Hacharoshet St., POB 211
> Or Yehuda 60251, Israel
> Tel: + 972-(0)3-5339022  Fax: + 972-(0)3-5339019
> Mobile: + 972-(0)54-838175
> http://www.itl.co.il
> http://www.i-spec.com
> 
> 
> 
> 
> 
> ---
> This message is from the IEEE EMC Society Product Safety
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RE: RTTE EU notifications - fees

[Gert Gremmen]

Hi Amund,

Notifications are free in the EU. Switzerland is not
member of the EU , and in the guys there do not know exactly
-or don not want to comply- with the rest of Europe.
Both for the notification procedure, AND the
associated fees, but also for the full implications of the R&TTE directive.
In switzerland the principal of manufacturers responsability is not fully
accepted. The bakom still insists in verification before allowing
the equipment to be used. Other EC countries accept any notification (esp.
if supported by NB declarations) if not contradictory to the national
frequencies table, and verify afterwards steered by complaints.
Not switzerland. Try to contact Mr. Zulauf and ask him why
one should pay for them to note (listen); as that is the basic function of
a notification procedure. Other EC countries -fa the netherlands-
will never comment on any notification; some will reply by sending
a confirmation of receiption.

Gert Gremmen
ce-test

-Original Message-
From: owner-emc-p...@majordomo.ieee.org
[mailto:owner-emc-p...@majordomo.ieee.org]On Behalf Of
am...@westin-emission.no
Sent: Tuesday, July 02, 2002 10:31 AM
To: Forum Safety-emc
Subject: RTTE EU notifications - fees



Hi all,

We have recently send a lot of RTTE EU notifications to the European telecom
authorities. We did also include Switzerland, because the radios system
shall be put into the Swiss marked and in addition we have also thought that
Switzerland accept the RTTE directive.

Anyway, we have now received an invoice (CHF 200,-) from the Swiss
authorities for handling the EU notification. Is that correct ? Isn't this
EU notification service for free?

Best regards
Amund Westin,
Oslo, NORWAY



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RE: RTTE EU notifications - fees

[richwoods]

We receive the invoices too. 

Richard Woods
Sensormatic Electronics
Tyco International


-Original Message-
From: am...@westin-emission.no [mailto:am...@westin-emission.no]
Sent: Tuesday, July 02, 2002 4:31 AM
To: Forum Safety-emc
Subject: RTTE EU notifications - fees



Hi all,

We have recently send a lot of RTTE EU notifications to the European telecom
authorities. We did also include Switzerland, because the radios system
shall be put into the Swiss marked and in addition we have also thought that
Switzerland accept the RTTE directive.

Anyway, we have now received an invoice (CHF 200,-) from the Swiss
authorities for handling the EU notification. Is that correct ? Isn't this
EU notification service for free?

Best regards
Amund Westin,
Oslo, NORWAY



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RE: RTTE EU notifications - fees

[ari.honkala]

I have heard authorities saying that some companies notify everything, 
including receivers, etc. while only the equipment (=transmitters) which does 
operate in non-harmonised frequency bands should be notified.
I guess this fee is a way to make those notifying to consider if this is really 
needed.
Best regards,
Ari Honkala

-Original Message-
From: ext am...@westin-emission.no [mailto:am...@westin-emission.no]
Sent: Tuesday, July 02, 2002 11:31 AM
To: Forum Safety-emc
Subject: RTTE EU notifications - fees



Hi all,

We have recently send a lot of RTTE EU notifications to the European telecom
authorities. We did also include Switzerland, because the radios system
shall be put into the Swiss marked and in addition we have also thought that
Switzerland accept the RTTE directive.

Anyway, we have now received an invoice (CHF 200,-) from the Swiss
authorities for handling the EU notification. Is that correct ? Isn't this
EU notification service for free?

Best regards
Amund Westin,
Oslo, NORWAY



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Re: RTTE

[Kim Boll Jensen]

Hi I'm sorry if I have confused things a little. But I visited this page:

http://europa.eu.int/comm/enterprise/rtte/implem.htm

And was so naive to think that when it says Adopted there was no national
deviations, sorry.

Best regards,

Kim Boll Jensen
Bolls

"Andre, Pierre-Marie" skriver:

> I thought that Hungary and Czec Republic are "R&TTE" like,not 100% R&TTE
> according to the type of interface some minor difference may exist
> (label,DOC,...)
>
> Pierre-Marie Andre
> Intel Sophia Senior Approval Engineer
>
> -Original Message-
> From: Kim Boll Jensen [mailto:kimb...@post7.tele.dk]
> Sent: mercredi 6 mars 2002 11:44
> To: richwo...@tycoint.com
> Cc: emc-p...@majordomo.ieee.org
> Subject: Re: RTTE
>
> Hi all
>
> Here are a list of all countries which at the moment have implemented the
> R&TTE
> directive 100%:
> Belgium
> Denmark
> UK
> Finland
> France
> Greece
> Holland
> Italy
> Iceland
> Ireland
> Liechtenstein
> Luxembourg
> Norway
> Portugal
> Spain
> Sweden
> Switzerland
> Czech Republic
> Germany
> Hungary
> Austria
>
> richwo...@tycoint.com skriver:
>
> > Have any European states that are not EU or EFTA members adopted the RTTE
> > Directive and Notificaion process? In other words, will any other European
> > countries allow a radio product to be placed on their market if the
> > processes of the RTTE Directive are followed without the need for any
> other
> > special national process to be followed?
> >
> > Richard Woods
> > Sensormatic Electronics
> > Tyco International
> >
> > ---
> > This message is from the IEEE EMC Society Product Safety
> > Technical Committee emc-pstc discussion list.
> >
> > Visit our web site at:  http://www.ewh.ieee.org/soc/emcs/pstc/
> >
> > To cancel your subscription, send mail to:
> >  majord...@ieee.org
> > with the single line:
> >  unsubscribe emc-pstc
> >
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> >
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> >  Jim Bacher: j.bac...@ieee.org
> >
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> > http://ieeepstc.mindcruiser.com/
> > Click on "browse" and then "emc-pstc mailing list"
<>

RE: RTTE In Czech Republic

[richwoods]

After reading the document, I find that this is not anywhere near a
transposition of the RTTE Directive. Rather it is a very high level telcom
law. So, does know the reference of the actual document that transposes the
RTTE and where to find it?

Richard Woods
Sensormatic Electronics
Tyco International


-Original Message-
From: WOODS, RICHARD 
Sent: Thursday, March 07, 2002 8:30 AM
To: emc-p...@majordomo.ieee.org
Subject: RE: RTTE


I found the english document at 
http://www.mdcr.cz/english/index14.htm

Richard Woods
Sensormatic Electronics
Tyco International


-Original Message-
From: h.knud...@niros.com [mailto:h.knud...@niros.com]
Sent: Thursday, March 07, 2002 3:10 AM
To: richwo...@tycoint.com; emc-p...@majordomo.ieee.org
Subject: SV: RTTE


Hello Richard,

About Czech Republic, you may find the information in English on:

http://www.ctu.cz/index_a.htm

The Czech legislation "Act No. 151/2000 Coll. on telecommunication and
changes in other Acts"  may be found on http://www.mdcr.cz/tp1.htm (it is
not accessible at the moment).

Best regards

Helge Knudsen
Test & Approval manager
Niros Telecommunication
Hirsemarken 5
DK-3520 Farum
Denmark
Tel +45 44 34 22 51
Fax +45 44 99 28 08
email h.knud...@niros.com



-Oprindelig meddelelse-
Fra: richwo...@tycoint.com [mailto:richwo...@tycoint.com]
Sendt: 6. marts 2002 14:07
Til: emc-p...@majordomo.ieee.org
Emne: RE: RTTE



I just investigated Hungary and found the following variances for radio:

A Hungarian national (local manufacturer or importer) is responsible for
compliance including signing the Declaration of Conformity.

The user instuctions and DoC must be in the Hungarian language.

Annex VIII includes the harmonized bands in Hungary. For some bands, the use
of the alert symbol is not required and neither is notification.

Unfortunatuly, the Czec directive is not available in English on the
website, so I have not been able to determine if there are any deviations
from the EU RTTE.

Richard Woods
Sensormatic Electronics
Tyco International


-Original Message-
From: Andre, Pierre-Marie [mailto:pierre-marie.an...@intel.com]
Sent: Wednesday, March 06, 2002 6:13 AM
To: 'Kim Boll Jensen'; richwo...@tycoint.com
Cc: emc-p...@majordomo.ieee.org
Subject: RE: RTTE


I thought that Hungary and Czec Republic are "R&TTE" like,not 100% R&TTE
according to the type of interface some minor difference may exist
(label,DOC,...)



Pierre-Marie Andre
Intel Sophia Senior Approval Engineer


-Original Message-
From: Kim Boll Jensen [mailto:kimb...@post7.tele.dk]
Sent: mercredi 6 mars 2002 11:44
To: richwo...@tycoint.com
Cc: emc-p...@majordomo.ieee.org
Subject: Re: RTTE


Hi all

Here are a list of all countries which at the moment have implemented the
R&TTE
directive 100%:
Belgium
Denmark
UK
Finland
France
Greece
Holland
Italy
Iceland
Ireland
Liechtenstein
Luxembourg
Norway
Portugal
Spain
Sweden
Switzerland
Czech Republic
Germany
Hungary
Austria


richwo...@tycoint.com skriver:

> Have any European states that are not EU or EFTA members adopted the RTTE
> Directive and Notificaion process? In other words, will any other European
> countries allow a radio product to be placed on their market if the
> processes of the RTTE Directive are followed without the need for any
other
> special national process to be followed?
>
> Richard Woods
> Sensormatic Electronics
> Tyco International
>
> ---
> This message is from the IEEE EMC Society Product Safety
> Technical Committee emc-pstc discussion list.
>
> Visit our web site at:  http://www.ewh.ieee.org/soc/emcs/pstc/
>
> To cancel your subscription, send mail to:
>  majord...@ieee.org
> with the single line:
>  unsubscribe emc-pstc
>
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>  Ron Pickard:  emc-p...@hypercom.com
>  Dave Heald:   davehe...@mediaone.net
>
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>  Richard Nute:   ri...@ieee.org
>  Jim Bacher: j.bac...@ieee.org
>
> All emc-pstc postings are archived and searchable on the web at:
> http://ieeepstc.mindcruiser.com/
> Click on "browse" and then "emc-pstc mailing list"

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RE: RTTE

[richwoods]

I found the english document at 
http://www.mdcr.cz/english/index14.htm

Richard Woods
Sensormatic Electronics
Tyco International


-Original Message-
From: h.knud...@niros.com [mailto:h.knud...@niros.com]
Sent: Thursday, March 07, 2002 3:10 AM
To: richwo...@tycoint.com; emc-p...@majordomo.ieee.org
Subject: SV: RTTE


Hello Richard,

About Czech Republic, you may find the information in English on:

http://www.ctu.cz/index_a.htm

The Czech legislation "Act No. 151/2000 Coll. on telecommunication and
changes in other Acts"  may be found on http://www.mdcr.cz/tp1.htm (it is
not accessible at the moment).

Best regards

Helge Knudsen
Test & Approval manager
Niros Telecommunication
Hirsemarken 5
DK-3520 Farum
Denmark
Tel +45 44 34 22 51
Fax +45 44 99 28 08
email h.knud...@niros.com



-Oprindelig meddelelse-
Fra: richwo...@tycoint.com [mailto:richwo...@tycoint.com]
Sendt: 6. marts 2002 14:07
Til: emc-p...@majordomo.ieee.org
Emne: RE: RTTE



I just investigated Hungary and found the following variances for radio:

A Hungarian national (local manufacturer or importer) is responsible for
compliance including signing the Declaration of Conformity.

The user instuctions and DoC must be in the Hungarian language.

Annex VIII includes the harmonized bands in Hungary. For some bands, the use
of the alert symbol is not required and neither is notification.

Unfortunatuly, the Czec directive is not available in English on the
website, so I have not been able to determine if there are any deviations
from the EU RTTE.

Richard Woods
Sensormatic Electronics
Tyco International


-Original Message-
From: Andre, Pierre-Marie [mailto:pierre-marie.an...@intel.com]
Sent: Wednesday, March 06, 2002 6:13 AM
To: 'Kim Boll Jensen'; richwo...@tycoint.com
Cc: emc-p...@majordomo.ieee.org
Subject: RE: RTTE


I thought that Hungary and Czec Republic are "R&TTE" like,not 100% R&TTE
according to the type of interface some minor difference may exist
(label,DOC,...)



Pierre-Marie Andre
Intel Sophia Senior Approval Engineer


-Original Message-
From: Kim Boll Jensen [mailto:kimb...@post7.tele.dk]
Sent: mercredi 6 mars 2002 11:44
To: richwo...@tycoint.com
Cc: emc-p...@majordomo.ieee.org
Subject: Re: RTTE


Hi all

Here are a list of all countries which at the moment have implemented the
R&TTE
directive 100%:
Belgium
Denmark
UK
Finland
France
Greece
Holland
Italy
Iceland
Ireland
Liechtenstein
Luxembourg
Norway
Portugal
Spain
Sweden
Switzerland
Czech Republic
Germany
Hungary
Austria


richwo...@tycoint.com skriver:

> Have any European states that are not EU or EFTA members adopted the RTTE
> Directive and Notificaion process? In other words, will any other European
> countries allow a radio product to be placed on their market if the
> processes of the RTTE Directive are followed without the need for any
other
> special national process to be followed?
>
> Richard Woods
> Sensormatic Electronics
> Tyco International
>
> ---
> This message is from the IEEE EMC Society Product Safety
> Technical Committee emc-pstc discussion list.
>
> Visit our web site at:  http://www.ewh.ieee.org/soc/emcs/pstc/
>
> To cancel your subscription, send mail to:
>  majord...@ieee.org
> with the single line:
>  unsubscribe emc-pstc
>
> For help, send mail to the list administrators:
>  Ron Pickard:  emc-p...@hypercom.com
>  Dave Heald:   davehe...@mediaone.net
>
> For policy questions, send mail to:
>  Richard Nute:   ri...@ieee.org
>  Jim Bacher: j.bac...@ieee.org
>
> All emc-pstc postings are archived and searchable on the web at:
> http://ieeepstc.mindcruiser.com/
> Click on "browse" and then "emc-pstc mailing list"

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RE: RTTE

[richwoods]

I just investigated Hungary and found the following variances for radio:

A Hungarian national (local manufacturer or importer) is responsible for
compliance including signing the Declaration of Conformity.

The user instuctions and DoC must be in the Hungarian language.

Annex VIII includes the harmonized bands in Hungary. For some bands, the use
of the alert symbol is not required and neither is notification.

Unfortunatuly, the Czec directive is not available in English on the
website, so I have not been able to determine if there are any deviations
from the EU RTTE.

Richard Woods
Sensormatic Electronics
Tyco International


-Original Message-
From: Andre, Pierre-Marie [mailto:pierre-marie.an...@intel.com]
Sent: Wednesday, March 06, 2002 6:13 AM
To: 'Kim Boll Jensen'; richwo...@tycoint.com
Cc: emc-p...@majordomo.ieee.org
Subject: RE: RTTE


I thought that Hungary and Czec Republic are "R&TTE" like,not 100% R&TTE
according to the type of interface some minor difference may exist
(label,DOC,...)



Pierre-Marie Andre
Intel Sophia Senior Approval Engineer


-Original Message-
From: Kim Boll Jensen [mailto:kimb...@post7.tele.dk]
Sent: mercredi 6 mars 2002 11:44
To: richwo...@tycoint.com
Cc: emc-p...@majordomo.ieee.org
Subject: Re: RTTE


Hi all

Here are a list of all countries which at the moment have implemented the
R&TTE
directive 100%:
Belgium
Denmark
UK
Finland
France
Greece
Holland
Italy
Iceland
Ireland
Liechtenstein
Luxembourg
Norway
Portugal
Spain
Sweden
Switzerland
Czech Republic
Germany
Hungary
Austria


richwo...@tycoint.com skriver:

> Have any European states that are not EU or EFTA members adopted the RTTE
> Directive and Notificaion process? In other words, will any other European
> countries allow a radio product to be placed on their market if the
> processes of the RTTE Directive are followed without the need for any
other
> special national process to be followed?
>
> Richard Woods
> Sensormatic Electronics
> Tyco International
>
> ---
> This message is from the IEEE EMC Society Product Safety
> Technical Committee emc-pstc discussion list.
>
> Visit our web site at:  http://www.ewh.ieee.org/soc/emcs/pstc/
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RE: RTTE

[Andre, Pierre-Marie]

I thought that Hungary and Czec Republic are "R&TTE" like,not 100% R&TTE
according to the type of interface some minor difference may exist
(label,DOC,...)



Pierre-Marie Andre
Intel Sophia Senior Approval Engineer


-Original Message-
From: Kim Boll Jensen [mailto:kimb...@post7.tele.dk]
Sent: mercredi 6 mars 2002 11:44
To: richwo...@tycoint.com
Cc: emc-p...@majordomo.ieee.org
Subject: Re: RTTE


Hi all

Here are a list of all countries which at the moment have implemented the
R&TTE
directive 100%:
Belgium
Denmark
UK
Finland
France
Greece
Holland
Italy
Iceland
Ireland
Liechtenstein
Luxembourg
Norway
Portugal
Spain
Sweden
Switzerland
Czech Republic
Germany
Hungary
Austria


richwo...@tycoint.com skriver:

> Have any European states that are not EU or EFTA members adopted the RTTE
> Directive and Notificaion process? In other words, will any other European
> countries allow a radio product to be placed on their market if the
> processes of the RTTE Directive are followed without the need for any
ot
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Hi all

Here are a list of all countries which at the moment have implemented the R&TTE
directive 100%:
Belgium
Denmark
UK
Finland
France
Greece
Holland
Italy
Iceland
Ireland
Liechtenstein
Luxembourg
Norway
Portugal
Spain
Sweden
Switzerland
Czech Republic
Germany
Hungary
Austria


richwo...@tycoint.com skriver:

> Have any European states that are not EU or EFTA members adopted the RTTE
> Directive and Notificaion process? In other words, will any other European
> countries allow a radio product to be placed on their market if the
> processes of the RTTE Directive are followed without the need for any other
> special national process to be followed?
>
> Richard Woods
> Sensormatic Electronics
> Tyco International
>
> ---
> This message is from the IEEE EMC Society Product Safety
> Technical Committee emc-pstc discussion list.
>
> Visit our web site at:  http://www.ewh.ieee.org/soc/emcs/pstc/
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--EE982B8B8087C7659CE469C8--


-

RE: RTTE

[amund]

Richard,
I think you have to examine each East-European country about their status
regarding RTTE. This morning I checked Hungary and they have adopted the
RTTE.

Notification form:
http://www.hif.hu/english/menu4/m4_6/mell-9.pdf

FAQ:
http://www.hif.hu/english/menu4/m4_6/faq_ang3.pdf


I do not know any status about Poland, Estonia, Slovakia, Czech Republic and
all the other East European countries, but since they are in membership
negotiation with EU, I would assume for sure that they have adopted RTTE or
at least accept a RTTE certificated product. But we have to check it out
.

Amund




-Opprinnelig melding-
Fra: owner-emc-p...@majordomo.ieee.org
[mailto:owner-emc-p...@majordomo.ieee.org]På vegne av
richwo...@tycoint.com
Sendt: 4. mars 2002 17:01
Til: emc-p...@majordomo.ieee.org
Emne: RTTE



Have any European states that are not EU or EFTA members adopted the RTTE
Directive and Notificaion process? In other words, will any other European
countries allow a radio product to be placed on their market if the
processes of the RTTE Directive are followed without the need for any other
special national process to be followed?

Richard Woods
Sensormatic Electronics
Tyco International


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RE: RTTE

[Allen, John]

Rich

Possibly worth taking another look at my previous messages as attached.

Regards

John Allen
Thales
Bracknell



-Original Message-
From: richwo...@tycoint.com [mailto:richwo...@tycoint.com]
Sent: 04 March 2002 16:01
To: emc-p...@majordomo.ieee.org
Subject: RTTE



Have any European states that are not EU or EFTA members adopted the RTTE
Directive and Notificaion process? In other words, will any other European
countries allow a radio product to be placed on their market if the
processes of the RTTE Directive are followed without the need for any other
special national process to be followed?

Richard Woods
Sensormatic Electronics
Tyco International


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--- Begin Message ---
Hi folks

Further to Action 33..05, anyone interested in the progress of the
enlargement process should visit

http://europa.eu.int/comm/enlargement/

This has links to individual pages charting the progress and (relatively -
typically November 2000) current status for each of the following countries:
Bulgaria.,  Cyprus  Czech Republic  Estonia
Hungary
Latvia  Lithuania   Malta   Poland
Romania
SlovakiaSloveniaTurkey  
The Links on the page will take you to further pages which have lists of
reports on each country.
Find the section headed 
"Overview key political documents related to enlargement"
Then find the most recent Prohress report such as "Progress Report - 8
November 2000"
These documents are quite long (~ 100 pages), but look for the Section C
"CONCLUSION" - which gives a general description of the progress to date and
the prognostications for the progress of joining the EU.
Then return to the country page on the website and look at the "Press
Releases " section which has links to more up-to-date documents.
Regards
John 


--- End Message ---
--- Begin Message ---
Hi Folks

I have just come across a very useful page on the NEMKO UK Ltd site, at:

http://www.nemko.ltd.uk/cert/direct.htm

The site is essentially advertising for NEMKO services but has tables which
give thumbnail sketches of the requirements for electrical and electronic
equipment approvals (including the namesof the organisations and
illustrations of their approval marks), including EMC but not R&TTE, in the
following countries:

Central East Europe:
Poland, Czech Republic,  Slovak Republic,   
Hungary,Slovenia,   Croatia
Yugoslavia, Macedonia,  Albania
Romania,Bulgaria,   Turkey

Russia, CIS and Baltic States:
Russia  Ukraine Belarus
Lithuania   Estonia Latvia
Kazakhstan

South America:
Argentina   Mexico  Brazil
ColombiaChile

Middle East, Africa, Asia:
Saudi ArabiaIsrael  South Africa
India   Hong Kong   Australia
Japan   Korea   China (2 versions?)
Singapore   ThailandMalaysia

Regards

John Allen
Thales Defence Ltd.,
Bracknell, UK


-Original Message-
From: wo...@sensormatic.com [mailto:wo...@sensormatic.com]
Sent: 19 September 2001 20:43
To: emc-p...@majordomo.ieee.org
Subject: RE: Request for a Compliance Matrix



I generated and posted this document in 1999 and some parts are now out of
date. I will update and re-post it with any corrections, updates and
additions that anyone cares to send to me.

Richard Woods

--
From:  Dave Lorusso [SMTP:dave.loru...@genband.com]
Sent:  Wednesday, September 19, 2001 2:59 PM
To:  'emc-p...@majordomo.ieee.org'
Subject:  FW: Request for a Compliance Matrix

Thank you for the responses.  Dwight sent me a copy (attached).

Anyone one have a more up to date list?

Best regards,

Dave

-Original Message-
From:   Dwight Hunnicutt [mailto:dwight.hunnic...@vina-tech.com] 
Sent:   Wednesday, September 19, 2001 12:36 PM
To: 'Dave Lorusso'
Subject:RE: Request for a Compliance Matrix

 <> Dave-
Was this it?  Not too up to date, but this I what I have...
Dwight

-Original Message-
From:   Dave Lorusso [mailto:dave.loru...@genband.com]
Sent:   Wednesday, September 19, 20

RE: RTTE

[Alex McNeil]

Hi Richard,

Have you tried this website on "State of play of implementation of the
Directive"



Kind Regards
Alex McNeil
Principal Engineer
Tel: +44 (0)131 479 8375
Fax: +44 (0)131 479 8321
email: alex.mcn...@ingenicofortronic.com


-Original Message-
From: richwo...@tycoint.com [mailto:richwo...@tycoint.com]
Sent: Monday, March 04, 2002 4:01 PM
To: emc-p...@majordomo.ieee.org
Subject: RTTE



Have any European states that are not EU or EFTA members adopted the RTTE
Directive and Notificaion process? In other words, will any other European
countries allow a radio product to be placed on their market if the
processes of the RTTE Directive are followed without the need for any other
special national process to be followed?

Richard Woods
Sensormatic Electronics
Tyco International


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Re: RTTE Notification Forms

[Leslie Bai]

 Rich,
What we have been doing for these two countries was writing to them to request 
for Notifocation Form. I know it's annoying but if you have found a better way, 
please let me know.
For Greece, write to: Mrs. Mathiou, National Telecom & Post Commission, 60 
Kifissias Avenue, 151 25 Maroussi, Athens, Greece, Tel: 301 0610 5040, Fax: 301 
0610 5049.
For Portugal, write to: Sr.Manuel Barros, ICP-D.E.N., Instituto das 
Communicacoes de Portugal, Av.Jose Malhoa 12, 1099-017 Lisboa, Portugal, Tel: 
351-217212302, Fax: 351-217211001.
Good luck,
Leslie
 
  richwo...@tycoint.com wrote: 
Can someone provide me with the RTTE Notification forms for Portugal and
Greece or point me a web site where they can be found?

Richard Woods
Sensormatic Electronics
Tyco International


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-
Do You Yahoo!?
Yahoo! Auctions Great stuff seeking new owners! Bid now!

Re: RTTE Directive

[reheller]

Richard,

* If the test methods you are using are harmonized to the RTTE Directive
then you do not need a Notified Body.

* If the frequency you are using is harmonized by all EU countries then you
do not need the "Alert "symbol (exclamation point in a circle).

1. Harmonized test methods and frequency = CE marking
2. Harmonized test methods and non-harmonized frequency = CE marking and
"Alert" symbol
3. Non-harmonized test methods and non-harmonized frequency = CE marking
and Notified Body number and "Alert" symbol
4. Use of TCF (same as 3.)

At this point in time, most of the test methods you will use are harmonized
to the RTTE Directive so you do not have to use a Notified Body to verify
your test methods. However, there are virtually no harmonized frequencies
so you will have to notify all of the Telecommunication Authorities of the
frequency that you intend to use so that they can make a judgement as to
its authorization and restriction within its country.

Bob Heller
3M Product Safety, 76-1-01
St. Paul, MN 55107-1208
Tel:  651- 778-6336
Fax:  651-778-6252




   
richwoods@tycoi 
   
nt.com   To: emc-p...@majordomo.ieee.org
   
 cc: (bcc: Robert E. 
Heller/US-Corporate/3M/US)
12/13/2001   Subject: RTTE Directive
   
11:00 AM
   
Please respond  
   
to richwoods
   

   

   






I previously used a Notified Body in the conformity process to the RTTE
Directive since only a draft radio standard existed at the time. However, a
harmonized standard now exists. I understand that I have two choices:

1) Continue to use the existing Declaration of Conformity to the essential
requirements of the RTTE, or
2) Issue a new Declaration in which we declare compliance with the
harmonized radio standard and make no mention of the participation of the
Notified Body.

Is my understanting correct?


Richard Woods
Sensormatic Electronics
Tyco International


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Re: RTTE Directive

[Allan G. Carr]

-BEGIN PGP SIGNED MESSAGE-
Hash: SHA1

Courtland

The R&TTE Directive 1999/05/EEC states:-

Article 2  - Definitions

For the purpose of this Directive the following definitions
shall apply:

(b) "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);


So equipment connected to any line provided by a public
telecommunications operator (PTO) is within the scope of the R&TTE. 
Only safety & EMC specifications have been designated as mandatory for
wire-line modems.

If the modems are connected via wires which are also owned by the
modems' owner and not by a PTO then the R&TTE Directive does not apply
but in that case the Safety & EMC Directives still apply as the
equipment is classed as Information Technology Equipment.

The net effect is that the same (or very similar) specifications apply.



Allan Carr
Telecommunications Consultant
AGC-Tel Consultants Ltd
__

In article , Courtland
Thomas  writes
>
>Hello Group,
>
>I have a problem is deciphering the RTTE Directive as far as what equipment
>qualifies. We manufacture many types of modems and some are designated as
>point to point. I understand that anything that connects to the public
>network falls under the directive, but what about point to point modems over
>twisted pairs. I am not speaking of leased lines, as they also fall under
>the RTTE. My concern is modems that connect point to point and can only be
>connected to others of their kind over distances of up to 7 miles. Is the
>RTTE meant to cover any connections that are controlled via a Central
>Office, whether it be public or leased?
>
>Thanks,
>
>Courtland Thomas
>Patton Electronics

- -- 
 Allan G.Carr B.Sc.(Elec.Eng) AMIEE  |  AGC-Tel Consultants Ltd
 Telecommunications Consultant   |  Tel: +44(0)141-956-2506 
 62 Crawford Road,   Milngavie   |  Fax: +44(0)141-956-5347
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RE: RTTE & Harmonized Bands

[Dick Grobner]

Richard
In a FAQ RTTE document I pulled from
http://europa.eu.int/comm/enterprise/rtte/faq.htm page 11 it deals with this
issue, put give no source definitive source. There are some other
interesting comments to some of the questions posed in this document. This
is new for me so any bit of info is interesting! 
Take a look and enjoy the reading!

-Original Message-
From: wo...@sensormatic.com [mailto:wo...@sensormatic.com]
Sent: Friday, June 22, 2001 12:41 PM
To: emc-p...@majordomo.ieee.org
Subject: RTTE & Harmonized Bands



In reference to the RTTE Directive, what organization, if any, is
responsible for declaring a frequency band to be harmonized within the EU?
Where can one find a listing of harmonized bands?

Richard Woods

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RE: RTTE Directive

[CE-test - Ing. Gert Gremmen - ce-marking and more...]

We also recommend the use of an NB for many
European countries such as Germany [afraid to be not thorough enough ;<)] ,
Italy [don't understand new approach ;<0], and France [nationalistic reasons
:<(( ].
We at ce-test are no NB, but our test reports are in general accepted by a
our local NB, an option that is available to anyone that can do it's own
testing. The NB provides you with a Statement of Opinion, so no barriers
exist for notification
in all EC countries.

This system works great with products that use not (yet) harmonised
standards such as SRD's.

Regards,

Gert Gremmen, (Ing)

ce-test, qualified testing

===
Web presence  http://www.cetest.nl
CE-shop http://www.cetest.nl/ce_shop.htm
/-/ Compliance testing is our core business /-/
===


>>-Original Message-
>>From: owner-emc-p...@majordomo.ieee.org
>>[mailto:owner-emc-p...@majordomo.ieee.org]On Behalf Of
>>wo...@sensormatic.com
>>Sent: Friday, June 22, 2001 1:48 PM
>>To: emc-p...@majordomo.ieee.org
>>Subject: RE: RTTE Directive
>>
>>
>>
>>It can be confusing. Let's see if I can help. I will address the Directive
>>from the point of view of transmitters. The essential
>>requirements relate to
>>three areas: safety, EMC and the radio spectrum.
>>
>>For safety and EMC, you have a choice - continue to follow the
>>procedures in
>>the LV and EMC Directives or follow the procedures in the RTTE
>>Directive. If
>>you choose the RTTE Directive, you will need to use a Notified Body if and
>>only if the standards are not published in the OJ. Guess what? The safety
>>standard for human exposure is not published. Therefore, I recommend that
>>you choose to follow the procedures of the LVD. Under those procedures you
>>do not have to use a Notified Body.
>>
>>Now to the radio spectrum. There are three possible paths
>>
>>o It is a receiver product - follow Annex II and self declare
>>o A harmonized standard exists and it includes a test suite - follow
>>Annex III and self-declare
>>o A harmonized standard exists, but it does not include a test suite -
>>follow Annex III and use a Notified Body
>>o No spectrum standard exists - follow Annex IV and use a Notified
>>Body
>>
>>Having followed the appropriate procedure, you may now issue the DoC and
>>apply the CE marking to the product, DoC and container. Is your operating
>>band harmonized? If so, proceed to market; otherwise, you must follow the
>>country notification procedure prior to marketing.
>>
>>Good Luck! Richard Woods
>>
>>
>>
>>
>>
>>Richard Woods
>>
>>  --
>>  From:  Courtland Thomas [SMTP:ctho...@patton.com]
>>  Sent:  Thursday, June 21, 2001 4:09 PM
>>  To:  emcpost
>>  Subject:  RTTE Directive
>>
>>
>>  Hello group,
>>
>>  After reading through the RTTE Directive for the fifth or sixth
>>time, I am
>>  still not clear on the use of the notified/competent body and
>>European
>>  representative. It seems to me that I can get all my testing done,
>>whether
>>  it be my own internal testing or using an outside lab, and then just
>>file
>>  the test reports. There is some mention of the notified body and
>>  representative, but not enough for me to feel it necessary to have
>>either. I
>>  realize for equipment that doesn't fall under the RTTE Directive,
>>the
>>  notified/competent body performs the assessment of the equipment to
>>the
>>  particular standards, but isn't the intent of the RTTE Directive to
>>  eliminate this requirement and place that burden on the
>>manufacturer? For
>>  some reason I just don't see the requirement for those entities
>>after
>>  reading through the directive. Maybe someone else can give me their
>>  interpretation.
>>
>>  Thanks,
>>
>>  Courtland Thomas
>>  Patton Electronics
>>
>>
>>  ---
>>  This message is from the IEEE EMC Society Product Safety
>>  Technical Committee emc-pstc discussion list.
>>
>>  Visit our web site at:  http://www.ewh.ieee.org/soc/emcs/pstc/
>>
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>>   majord...@ieee.org
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>>
>>  For help, send mail to the list administrators:
>>   

RE: RTTE & Harmonized Bands

[CE-test - Ing. Gert Gremmen - ce-marking and more...]

Hi Richard,
Currently only the GSM and DECT bands are
harmonized. All other frequency allocations require verification with
national frequency
schemes and national notification with the 4 weeks time gap.

Progress information is available at ero.dk

Several ERC reports can be of great help such as
the one for short range devices ERC 70-03 and the one about European
frequency allocations ERC 25.

Regards,

Gert Gremmen, (Ing)

ce-test, qualified testing

===
Web presence  http://www.cetest.nl
CE-shop http://www.cetest.nl/ce_shop.htm
/-/ Compliance testing is our core business /-/
===


>>-Original Message-
>>From: owner-emc-p...@majordomo.ieee.org
>>[mailto:owner-emc-p...@majordomo.ieee.org]On Behalf Of
>>wo...@sensormatic.com
>>Sent: Friday, June 22, 2001 7:41 PM
>>To: emc-p...@majordomo.ieee.org
>>Subject: RTTE & Harmonized Bands
>>
>>
>>
>>In reference to the RTTE Directive, what organization, if any, is
>>responsible for declaring a frequency band to be harmonized within the EU?
>>Where can one find a listing of harmonized bands?
>>
>>Richard Woods
>>
>>---
>>This message is from the IEEE EMC Society Product Safety
>>Technical Committee emc-pstc discussion list.
>>
>>Visit our web site at:  http://www.ewh.ieee.org/soc/emcs/pstc/
>>
>>To cancel your subscription, send mail to:
>> majord...@ieee.org
>>with the single line:
>> unsubscribe emc-pstc
>>
>>For help, send mail to the list administrators:
>> Michael Garretson:pstc_ad...@garretson.org
>> Dave Healddavehe...@mediaone.net
>>
>>For policy questions, send mail to:
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>> Jim Bacher: j.bac...@ieee.org
>>
>>All emc-pstc postings are archived and searchable on the web at:
>>http://www.rcic.com/  click on "Virtual Conference Hall,"
>>
<>

RE: RTTE Directive

[WOODS]

It can be confusing. Let's see if I can help. I will address the Directive
from the point of view of transmitters. The essential requirements relate to
three areas: safety, EMC and the radio spectrum. 

For safety and EMC, you have a choice - continue to follow the procedures in
the LV and EMC Directives or follow the procedures in the RTTE Directive. If
you choose the RTTE Directive, you will need to use a Notified Body if and
only if the standards are not published in the OJ. Guess what? The safety
standard for human exposure is not published. Therefore, I recommend that
you choose to follow the procedures of the LVD. Under those procedures you
do not have to use a Notified Body. 

Now to the radio spectrum. There are three possible paths 

o   It is a receiver product - follow Annex II and self declare
o   A harmonized standard exists and it includes a test suite - follow
Annex III and self-declare
o   A harmonized standard exists, but it does not include a test suite -
follow Annex III and use a Notified Body
o   No spectrum standard exists - follow Annex IV and use a Notified
Body

Having followed the appropriate procedure, you may now issue the DoC and
apply the CE marking to the product, DoC and container. Is your operating
band harmonized? If so, proceed to market; otherwise, you must follow the
country notification procedure prior to marketing.

Good Luck! Richard Woods





Richard Woods

--
From:  Courtland Thomas [SMTP:ctho...@patton.com]
Sent:  Thursday, June 21, 2001 4:09 PM
To:  emcpost
Subject:  RTTE Directive


Hello group,

After reading through the RTTE Directive for the fifth or sixth
time, I am
still not clear on the use of the notified/competent body and
European
representative. It seems to me that I can get all my testing done,
whether
it be my own internal testing or using an outside lab, and then just
file
the test reports. There is some mention of the notified body and
representative, but not enough for me to feel it necessary to have
either. I
realize for equipment that doesn't fall under the RTTE Directive,
the
notified/competent body performs the assessment of the equipment to
the
particular standards, but isn't the intent of the RTTE Directive to
eliminate this requirement and place that burden on the
manufacturer? For
some reason I just don't see the requirement for those entities
after
reading through the directive. Maybe someone else can give me their
interpretation.

Thanks,

Courtland Thomas
Patton Electronics


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RE: RTTE Directive

[Barbara Judge]

Courtland,

For equipment covered by harmonized standards you are correct, no Notified
or Conformity Assessment Body involvement is needed.  This is the situation
that most terminal equipment manufacturers find themselves in currently.  On
the other hand, there are a number of RF standards that have not yet been
harmonized and there the involvement of a CAB or NB is necessary.

I hope that this is helpful

Best Regards,
Barbara
___
Barbara L. Judge
Vice President 
Compliance Certification Services
Designated TCB and CAB
561F Monterey Road
Morgan Hill, CA 95037
408-463-0885 ext.104   
Fax:  408-463-0888
e-mail:  bju...@ccsemc.com
http://www.ccsemc.com


-Original Message-
From: Courtland Thomas [mailto:ctho...@patton.com]
Sent: Thursday, June 21, 2001 1:09 PM
To: emcpost
Subject: RTTE Directive



Hello group,

After reading through the RTTE Directive for the fifth or sixth time, I am
still not clear on the use of the notified/competent body and European
representative. It seems to me that I can get all my testing done, whether
it be my own internal testing or using an outside lab, and then just file
the test reports. There is some mention of the notified body and
representative, but not enough for me to feel it necessary to have either. I
realize for equipment that doesn't fall under the RTTE Directive, the
notified/competent body performs the assessment of the equipment to the
particular standards, but isn't the intent of the RTTE Directive to
eliminate this requirement and place that burden on the manufacturer? For
some reason I just don't see the requirement for those entities after
reading through the directive. Maybe someone else can give me their
interpretation.

Thanks,

Courtland Thomas
Patton Electronics


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RE: RTTE Notification

[Wismer, Sam]

Hi Richard, 
There could be several ways to go depending on if harmonized standards exist
for your device or not.  I will assume that at the time you had it tested
originally, they did not since you used Annex IV and not Annex III.
Somewhat relevant to this topic, we had used Annex IV on a radio device last
year(Harmonized standards did not exist), and this year with a new radio of
the very same type we were able to apply annex III(all of the standards were
harmonized recently.  Lucky me!).  Anyway, we have 2 of the same type
radios, one that carries a NB number and one that does not(You can imagine
the questions I get from our manufacturing folks).  The reason I bring this
up is, you could possibly convert to Annex III with the new model if the
standards that apply to it have been harmonized and draw up a DoC that
includes both models, if you feel no new testing is warranted.  If harmonize
standards still do not exist, then disregard all of the above and contact
your notified body.

Regarding your second question, yes I believe you need to Notify the
spectrum authorities of the new model and I have a story to tell on this
issue also.  Basically, we sell a radio to a customer of ours however they
wanted to give it there own model number.  I contacted my Notified Body and
for a small fee of course, they re-issued the statement of opinion including
the new variant and advised us(or the OEM) to notify all of the member
states of this new model.  They did nothing to the TCF which I found to be
interesting since that is the ultimate way to show compliance of a device.
I suppose the SoO(New Acronym for Statement of Opinion) is sufficient
enough.

Hope this helps.




~
Sam Wismer
Lead Regulatory Engineer/
Radio Approvals Engineer
LXE, Inc.
(770) 447-4224 Ext. 3654

Visit Our Website at:
http://www.ems-t.com



-Original Message-
From: wo...@sensormatic.com [mailto:wo...@sensormatic.com]
Sent: Thursday, June 14, 2001 11:35 AM
To: emc-p...@majordomo.ieee.org
Subject: RTTE Notification



A radio product subject to the RTTE Directive was assessed by a Notified
Body under Annex IV, was notified to the national spectrum authorities and
is currently being marketed. Design changes are being made to the product
that do not affect the spectrum parameters, but the model number will be
changed to distinguish the two products. Is it necessary to communicate the
new model number to the Notified Body and/or the spectrum authorities?

Richard Woods

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<>

RE: RTTE Directive

[Wagner, John P (John)]

I would not interpret the R&TTE Directive that way.  Its intent is for
equipment directly or indirectly connected to the public switched
network.  If ther is no network connection, there is no requirement.
Furthermore, it is the interface to the network that applies.  For
instance, PC's on an Ethernet LAN with connectivity to the Internet via
telecommunications lines do not need to meet the RTTE.  But, the router
or server connected to the network does -- or at least its interface to
the network.
John P. Wagner
AVAYA Communication
1300 W. 120th Ave, Room B3-D16
Phone/Fax: (303) 538-4241
johnwag...@avaya.com




> --
> From: Allan, James[SMTP:james_al...@milgo.com]
> Reply To: Allan, James
> Sent: Friday, March 16, 2001 6:27 AM
> To:   emc-p...@majordomo.ieee.org
> Subject:  RE: RTTE Directive
> 
> 
> Amund has opened my eyes to the literal meaning of R&TTE equipment by
> pointing me to the equipment list.  I thought I had a good idea of
> what is
> covered but now I am not sure.
> 
> Item 4 under terminal equipment states
> Wired data equipment (X.21, X.25, Ethernet, token ring, token bus,
> TCP/IP,
> frame relay) 
> This appears to me that any device with an Ethernet port, no matter
> what its
> function, must comply with the R&TTE Directive. Just to cite one of
> many
> examples, since almost all PC's have Ethernet ports does this now mean
> that
> they are no longer ITE but are now R&TTE ?
> 
> What says the rest of the group??
> 
> Jim Allan
> Manager, Engineering Services
> Milgo Solutions LLC
> 1619 N Harrison Parkway
> Sunrise, FL, 33323
> E-mail james_al...@milgo.com
> Phone (954) 846-3720
> Fax (954) 846-5693
> 
> > -Original Message-
> > From:   am...@westin.org [SMTP:am...@westin.org]
> > Sent:   Thursday, March 15, 2001 4:16 PM
> > To: ctho...@patton.com; emc-p...@majordomo.ieee.org
> > Subject:Re: RTTE Directive
> > 
> > 
> > Thomas,
> > 
> > Check the equipment list on
> > http://europa.eu.int/comm/enterprise/rtte/listeq.htm
> > 
> > Amund, Oslo/Norway
> > 
> > 
> > On Thu, 15 Mar 2001 09:52:11 -0500 "Courtland Thomas"
> 
> > 
> > wrote:
> > >
> > >Hello Group,
> > >
> > >I would like to know if there is a list of equipment that falls
> under the
> > >RTTE Directive. My area of concern is converters, such as RS-232 to
> > RS-485,
> > >V.35 to G.704, etc..
> > >
> > >Any help would be appreciated.
> > >
> > >Thanks,
> > >
> > >Courtland Thomas
> > >Patton Electronics
> > >
> > >
> > >---
> > >This message is from the IEEE EMC Society Product Safety
> > >Technical Committee emc-pstc discussion list.
> > >
> > >Visit our web site at:  http://www.ewh.ieee.org/soc/emcs/pstc/
> > >
> > >To cancel your subscription, send mail to:
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> > >with the single line:
> > > unsubscribe emc-pstc
> > >
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> > > Michael Garretson:pstc_ad...@garretson.org
> > > Dave Healddavehe...@mediaone.net
> > >
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> > > Jim Bacher: j.bac...@ieee.org
> > >
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> > >http://www.rcic.com/  click on "Virtual Conference Hall,"
> > >
> > >
> > 
> > 
> > -- 
> > Get your firstname@lastname email for FREE at
> http://Nameplanet.com/?su
> > 
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> > 
> > All emc-pstc postings are archived and searchable on the web at:
> >  

RE: RTTE Directive

[Allan, James]

Amund has opened my eyes to the literal meaning of R&TTE equipment by
pointing me to the equipment list.  I thought I had a good idea of what is
covered but now I am not sure.

Item 4 under terminal equipment states
Wired data equipment (X.21, X.25, Ethernet, token ring, token bus, TCP/IP,
frame relay) 
This appears to me that any device with an Ethernet port, no matter what its
function, must comply with the R&TTE Directive. Just to cite one of many
examples, since almost all PC's have Ethernet ports does this now mean that
they are no longer ITE but are now R&TTE ?

What says the rest of the group??

Jim Allan
Manager, Engineering Services
Milgo Solutions LLC
1619 N Harrison Parkway
Sunrise, FL, 33323
E-mail james_al...@milgo.com
Phone (954) 846-3720
Fax (954) 846-5693

> -Original Message-
> From: am...@westin.org [SMTP:am...@westin.org]
> Sent: Thursday, March 15, 2001 4:16 PM
> To:   ctho...@patton.com; emc-p...@majordomo.ieee.org
> Subject:  Re: RTTE Directive
> 
> 
> Thomas,
> 
> Check the equipment list on
> http://europa.eu.int/comm/enterprise/rtte/listeq.htm
> 
> Amund, Oslo/Norway
> 
> 
> On Thu, 15 Mar 2001 09:52:11 -0500 "Courtland Thomas" 
> 
> wrote:
> >
> >Hello Group,
> >
> >I would like to know if there is a list of equipment that falls under the
> >RTTE Directive. My area of concern is converters, such as RS-232 to
> RS-485,
> >V.35 to G.704, etc..
> >
> >Any help would be appreciated.
> >
> >Thanks,
> >
> >Courtland Thomas
> >Patton Electronics
> >
> >
> >---
> >This message is from the IEEE EMC Society Product Safety
> >Technical Committee emc-pstc discussion list.
> >
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Re: RTTE Directive

[amund]

Thomas,

Check the equipment list on http://europa.eu.int/comm/enterprise/rtte/listeq.htm

Amund, Oslo/Norway


On Thu, 15 Mar 2001 09:52:11 -0500 "Courtland Thomas"  
wrote:
>
>Hello Group,
>
>I would like to know if there is a list of equipment that falls under the
>RTTE Directive. My area of concern is converters, such as RS-232 to  RS-485,
>V.35 to G.704, etc..
>
>Any help would be appreciated.
>
>Thanks,
>
>Courtland Thomas
>Patton Electronics
>
>
>---
>This message is from the IEEE EMC Society Product Safety
>Technical Committee emc-pstc discussion list.
>
>Visit our web site at:  http://www.ewh.ieee.org/soc/emcs/pstc/
>
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>


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RE: RTTE Packaging

[WOODS]

Bob, the Directive does required markings on the packaging, but it does not
define the type of packaging. It is my opinion that the sales package was
intended and not the shipping package. In my case, I only have a shipping
package, so I have applied the markings there. The CE mark must be followed
by the 4 digit Notified Body number if a NB was required to be used
according to Annex III or IV. If the product is a radio device and the band
is not harmonized, the Alert symbol must follow the NB number. Also, in that
case, information must be on the packaging to inform the user as to the
intended geographical areas where the equipment may be used. We apply the
2-letter ISO country codes. The extended CE marking must also appear on the
Declaration of Conformity. 

Richard Woods

--
From:  rehel...@mmm.com [SMTP:rehel...@mmm.com]
Sent:  Thursday, March 15, 2001 8:00 AM
To:  emc-p...@majordomo.ieee.org
Subject:  RTTE Packaging


I saw some postings recently to the following question but I was not able
to "browse the recent archives" so I will ask the question again.

Under the RTTE Directive is there any labeling requirements for the product
packaging or shipping packaging? If so, what is required?

Thanks,
Bob




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Re: RTTE Directive

[jerry.rober...@btinternet.com]

Amund
You could check out the useful links page on the  R&TTE Compliance  Association
web site.   .   This  association is  focussed upon
understanding  and  effectively  using   EU  Directives  ( particularly  99/5)
in a manufacturing,  testing and marketing context.

Jerry Roberton
Secretary  R&TTE CA

Tel +44-1932-260808
Fax +44-1932-260809
Email: jerry.rober...@btinternet.com


aka
Roberton Associates Ltd
Walton-on-Thames  UK



am...@westin.org wrote:

> Hi all,
>
> Regarding RTTE and the NB role, we have this case:
>
> 1. Product: Satellite transmitter/reveicer, KU-band (10-14GHz)
> 2. Harmonized standards exist
>
> As far as I understand, we do not need a NB for certification. Apply annex III
> and issue a DoC.
> If the product shall be put into marked in EU countries, which the KU-band
> is "not harmonized", a statement must be forwarded to the national authorities
> that the product soon will be introduced to the marked.
> Wait 4 weeks, no responds, you can go on selling.
>
> Am I right or am I totally  ?
>
> The last one, any WEB-site that describes the Harmonized Frequency bands ?
>
> Best regards
> Amund Westin
>
> On Tue, 27 Feb 2001 15:55:15 -0500 wo...@sensormatic.com wrote:
> >
> >A representative is necessary if the manufacture is not resident in the EU.
> >That entity keeps the technical file and performs any other duties expressly
> >assigned by the manufacturer. This procedure is not related to any
> >procedural requirements to use or not use a Notified Body. A Notified Body
> >is needed if Annex III, IV or V applies. For example, our product is a short
> >range device where the spectrum standard has not been published; so we must
> >follow Annex IV and use a Notified Body. However, once the standard is
> >harmonized, we will switch to following Annex III and a Notified Body will
> >not be required.
> >
> >Richard Woods
> >
> >--
> >From:  Courtland Thomas [SMTP:ctho...@patton.com]
> >Sent:  Tuesday, February 27, 2001 5:07 PM
> >To:  emcpost
> >Subject:  RTTE Directive
> >
> >
> >Hello group,
> >
> >I have been reading through different articles on the RTTE Directive and
> >getting somewhat confused. I have concluded that there is no requirement for
> >an authorized representative within the Community any longer. This may have
> >been the case all along, but it was good to have that person to submit the
> >technical files to a notified body. I believe the notified body requirement
> >goes away with the RTTE directive also. Now all that is required is for the
> >manufacturer to maintain the technical file and produce the Declaration of
> >Conformity. Am I on the right page?
> >
> >Thanks,
> >
> >Courtland Thomas
> >Patton Electronics
> >
> >
> >---
> >This message is from the IEEE EMC Society Product Safety
> >Technical Committee emc-pstc discussion list.
> >
> >Visit our web site at:  http://www.ewh.ieee.org/soc/emcs/pstc/
> >
> >To cancel your subscription, send mail to:
> > majord...@ieee.org
> >with the single line:
> > unsubscribe emc-pstc
> >
> >For help, send mail to the list administrators:
> > Michael Garretson:pstc_ad...@garretson.org
> > Dave Healddavehe...@mediaone.net
> >
> >For policy questions, send mail to:
> > Richard Nute:   ri...@ieee.org
> > Jim Bacher: j.bac...@ieee.org
> >
> >All emc-pstc postings are archived and searchable on the web at:
> >http://www.rcic.com/  click on "Virtual Conference Hall,"
> >
> >---
> >This message is from the IEEE EMC Society Product Safety
> >Technical Committee emc-pstc discussion list.
> >
> >Visit our web site at:  http://www.ewh.ieee.org/soc/emcs/pstc/
> >
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> > Jim Bacher: j.bac...@ieee.org
> >
> >All emc-pstc postings are archived and searchable on the web at:
> >http://www.rcic.com/  click on "Virtual Conference Hall,"
> >
> >
>
> --
> Get your firstname@lastname email for FREE at http://Nameplanet.com/?su
>
> ---
> This message is from the IEEE EMC Society Product Safety
> Technical Committee emc-pstc discussion list.
>
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>  Ri

RE: RTTE Directive

[Wismer, Sam]

Hi Amund,
I am not familiar with this type of device, however if you have confirmed
that all standards that apply to the device are harmonized under the
directive, you are correct that you can apply Annex III of the directive
without the assistance of a NB.  You are correct again that since the
frequency band is not harmonized throughout the EU, you must Notify each
member state of your intention to place the product on their market.  Since
you are using non-harmonized frequency bands, you must also apply the alert
symbol on your device alerting the user that there are restrictions to the
use of this device in some countries.  Those restrictions should be placed
on your label and in the operators guide.



~
Sam Wismer
Lead Regulatory Engineer/
Radio Approvals Engineer
LXE, Inc.
(770) 447-4224 Ext. 3654

Visit Our Website at:
http://www.lxe.com



-Original Message-
From: am...@westin.org [mailto:am...@westin.org]
Sent: Thursday, March 01, 2001 4:29 AM
To: emc-p...@majordomo.ieee.org
Cc: wo...@sensormatic.com
Subject: RE: RTTE Directive



Hi all,

Regarding RTTE and the NB role, we have this case: 

1. Product: Satellite transmitter/reveicer, KU-band (10-14GHz)
2. Harmonized standards exist

As far as I understand, we do not need a NB for certification. Apply annex
III 
and issue a DoC.
If the product shall be put into marked in EU countries, which the KU-band 
is "not harmonized", a statement must be forwarded to the national
authorities 
that the product soon will be introduced to the marked.
Wait 4 weeks, no responds, you can go on selling.

Am I right or am I totally  ?

The last one, any WEB-site that describes the Harmonized Frequency bands ?

Best regards
Amund Westin 



On Tue, 27 Feb 2001 15:55:15 -0500 wo...@sensormatic.com wrote:
>
>A representative is necessary if the manufacture is not resident in the EU.
>That entity keeps the technical file and performs any other duties
expressly
>assigned by the manufacturer. This procedure is not related to any
>procedural requirements to use or not use a Notified Body. A Notified Body
>is needed if Annex III, IV or V applies. For example, our product is a
short
>range device where the spectrum standard has not been published; so we must
>follow Annex IV and use a Notified Body. However, once the standard is
>harmonized, we will switch to following Annex III and a Notified Body will
>not be required.
>
>Richard Woods
>
>--
>From:  Courtland Thomas [SMTP:ctho...@patton.com]
>Sent:  Tuesday, February 27, 2001 5:07 PM
>To:  emcpost
>Subject:  RTTE Directive
>
>
>Hello group,
>
>I have been reading through different articles on the RTTE Directive and
>getting somewhat confused. I have concluded that there is no requirement
for
>an authorized representative within the Community any longer. This may have
>been the case all along, but it was good to have that person to submit the
>technical files to a notified body. I believe the notified body requirement
>goes away with the RTTE directive also. Now all that is required is for the
>manufacturer to maintain the technical file and produce the Declaration of
>Conformity. Am I on the right page?
>
>Thanks,
>
>Courtland Thomas
>Patton Electronics
>
>
>---
>This message is from the IEEE EMC Society Product Safety
>Technical Committee emc-pstc discussion list.
>
>Visit our web site at:  http://www.ewh.ieee.org/soc/emcs/pstc/
>
>To cancel your subscription, send mail to:
> majord...@ieee.org
>with the single line:
> unsubscribe emc-pstc
>
>For help, send mail to the list administrators:
> Michael Garretson:pstc_ad...@garretson.org
> Dave Healddavehe...@mediaone.net
>
>For policy questions, send mail to:
> Richard Nute:   ri...@ieee.org
> Jim Bacher: j.bac...@ieee.org
>
>All emc-pstc postings are archived and searchable on the web at:
>http://www.rcic.com/  click on "Virtual Conference Hall,"
>
>---
>This message is from the IEEE EMC Society Product Safety
>Technical Committee emc-pstc discussion list.
>
>Visit our web site at:  http://www.ewh.ieee.org/soc/emcs/pstc/
>
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> Jim Bacher: j.bac...@ieee.org
>
>All emc-pstc postings are archived and searchable on the web at:
>http://www.rci

RE: RTTE Directive

[amund]

Hi all,

Regarding RTTE and the NB role, we have this case: 

1. Product: Satellite transmitter/reveicer, KU-band (10-14GHz)
2. Harmonized standards exist

As far as I understand, we do not need a NB for certification. Apply annex III 
and issue a DoC.
If the product shall be put into marked in EU countries, which the KU-band 
is "not harmonized", a statement must be forwarded to the national authorities 
that the product soon will be introduced to the marked.
Wait 4 weeks, no responds, you can go on selling.

Am I right or am I totally  ?

The last one, any WEB-site that describes the Harmonized Frequency bands ?

Best regards
Amund Westin 



On Tue, 27 Feb 2001 15:55:15 -0500 wo...@sensormatic.com wrote:
>
>A representative is necessary if the manufacture is not resident in the EU.
>That entity keeps the technical file and performs any other duties expressly
>assigned by the manufacturer. This procedure is not related to any
>procedural requirements to use or not use a Notified Body. A Notified Body
>is needed if Annex III, IV or V applies. For example, our product is a short
>range device where the spectrum standard has not been published; so we must
>follow Annex IV and use a Notified Body. However, once the standard is
>harmonized, we will switch to following Annex III and a Notified Body will
>not be required.
>
>Richard Woods
>
>--
>From:  Courtland Thomas [SMTP:ctho...@patton.com]
>Sent:  Tuesday, February 27, 2001 5:07 PM
>To:  emcpost
>Subject:  RTTE Directive
>
>
>Hello group,
>
>I have been reading through different articles on the RTTE Directive and
>getting somewhat confused. I have concluded that there is no requirement for
>an authorized representative within the Community any longer. This may have
>been the case all along, but it was good to have that person to submit the
>technical files to a notified body. I believe the notified body requirement
>goes away with the RTTE directive also. Now all that is required is for the
>manufacturer to maintain the technical file and produce the Declaration of
>Conformity. Am I on the right page?
>
>Thanks,
>
>Courtland Thomas
>Patton Electronics
>
>
>---
>This message is from the IEEE EMC Society Product Safety
>Technical Committee emc-pstc discussion list.
>
>Visit our web site at:  http://www.ewh.ieee.org/soc/emcs/pstc/
>
>To cancel your subscription, send mail to:
> majord...@ieee.org
>with the single line:
> unsubscribe emc-pstc
>
>For help, send mail to the list administrators:
> Michael Garretson:pstc_ad...@garretson.org
> Dave Healddavehe...@mediaone.net
>
>For policy questions, send mail to:
> Richard Nute:   ri...@ieee.org
> Jim Bacher: j.bac...@ieee.org
>
>All emc-pstc postings are archived and searchable on the web at:
>http://www.rcic.com/  click on "Virtual Conference Hall,"
>
>---
>This message is from the IEEE EMC Society Product Safety
>Technical Committee emc-pstc discussion list.
>
>Visit our web site at:  http://www.ewh.ieee.org/soc/emcs/pstc/
>
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> Jim Bacher: j.bac...@ieee.org
>
>All emc-pstc postings are archived and searchable on the web at:
>http://www.rcic.com/  click on "Virtual Conference Hall,"
>
>


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Re: RTTE Directive

[John Woodgate]

<91f59c34502abee3f414a3dbc8e164923a9cf...@lxe.com>, Wismer, Sam
 inimitably wrote:
>No disrespect to the test labs out there because I have gotten a lot of good
>information from some, but I encourage folks to get there information from
>multiple sources and include the actual regulating agencies. I find that
>this is the best way to weigh the opinions of others and the sales spin of
>the test labs.  After all, it is the regulating agencies who can throw you
>out of their country.

That's VERY good advice.
-- 
Regards, John Woodgate, OOO - Own Opinions Only. Phone +44 (0)1268 747839
Fax +44 (0)1268 777124. http://www.jmwa.demon.co.uk Foxhunters suffer from 
tallyhosis. PLEASE do not mail copies of newsgroup posts to me.

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RE: RTTE Directive

[Wismer, Sam]

All;
It is my opinion that if Annex III is applied, that a notified body is not
required.  Take for example 2.4GHz ISM equipment, although the frequency
band is not harmonized, the standards are(as of 14/2/2001), and according to
the Annex III, a notified body is not required.  There is nothing in the
directive that states a NB is needed if the frequency band is not
harmonized.  Notifications, however, are required and the alert symbol must
be used, but there is no requirement to use a NB.

I confirmed this with one of the member states regulating agencies during
some recent notifications I made for an 2.4GHz ISM device.  I applied the
newly harmonized standards in accordance with annex III and made my
notifications throughout the EU.  At first I was challenged why I did not
declare a NB.  Apparently(not sure how or why), they were not aware that all
of the standards that apply to ISM have been harmonized.  After explaining
and offering the evidence, they agreed that my notification was valid and
that I had correctly applied the directive.

No disrespect to the test labs out there because I have gotten a lot of good
information from some, but I encourage folks to get there information from
multiple sources and include the actual regulating agencies. I find that
this is the best way to weigh the opinions of others and the sales spin of
the test labs.  After all, it is the regulating agencies who can throw you
out of their country.


~
Sam Wismer
Lead Regulatory Engineer/
Radio Approvals Engineer
LXE, Inc.
(770) 447-4224 Ext. 3654

Visit Our Website at:
http://www.lxe.com



-Original Message-
From: CE-test - Ing. Gert Gremmen - ce-marking and more...
[mailto:cet...@cetest.nl]
Sent: Wednesday, February 28, 2001 1:57 AM
To: Courtland Thomas; emcpost
Subject: RE: RTTE Directive


There is some confusion over this subject:

1/  the ce marking directive still requires a rep "on-board" so resident on
European soil.
All New Approach directives under ce comply to this.

2/  The notified body (NB) is still required for R&TTE not harmonized
standards
to prescribe a test suite.
R&TTE harmonized standards do have a suitable test suite of their own.
3/  the notified body is still required for the frequency allocation per
country, unless
   a European harmonized frequency is used (currently just GSM and DECT).
   It's a good idea to comply to ERC freq. all. documents such as ERC 70-03
for short range devices.
   This one is a proposal for frequency harmonization for SRD in Europe.
   Be prepared for exceptions however.

So the key is:
Use a NB if Not Harmonized, otherwise do it yourself (or with our help).

All network related standards such as TBR21, are voluntarily.

Any way, selling devices is not forbidden at all as long as EMC and LVD
requirements are met.
You just should use the alert sign (and CE) including a list of ALL EC
counties that utilization is
not allowed.

Conclusion:

R&TTE is just as other electronics. The manufacturer should consult an NB
for not harmonized frequencies and not harmonized (radio) standards. In the
end all not harmonized frequencies usages need a notification to the
authorities.


Regards,

Gert Gremmen, (Ing)

ce-test, qualified testing

===
Web presence  http://www.cetest.nl
CE-shop http://www.cetest.nl/ce_shop.htm
/-/ Compliance testing is our core business /-/
===


>>-Original Message-
>>From: owner-emc-p...@ieee.org [mailto:owner-emc-p...@ieee.org]On Behalf
>>Of Courtland Thomas
>>Sent: Tuesday, February 27, 2001 11:07 PM
>>To: emcpost
>>Subject: RTTE Directive
>>
>>
>>
>>Hello group,
>>
>>I have been reading through different articles on the RTTE Directive and
>>getting somewhat confused. I have concluded that there is no
>>requirement for
>>an authorized representative within the Community any longer.
>>This may have
>>been the case all along, but it was good to have that person to submit the
>>technical files to a notified body. I believe the notified body
>>requirement
>>goes away with the RTTE directive also. Now all that is required
>>is for the
>>manufacturer to maintain the technical file and produce the Declaration of
>>Conformity. Am I on the right page?
>>
>>Thanks,
>>
>>Courtland Thomas
>>Patton Electronics
>>
>>
>>---
>>This message is from the IEEE EMC Society Product Safety
>>Technical Committee emc-pstc discussion list.
>>
>>Visit our web site at:  http://www.ewh.ieee.org/soc/emcs/pstc/
>>
>>To cancel your subscription, send mail to:
>> majord...@ieee.org
>>with the single line:
>> unsubscribe emc-pstc
>

RE: RTTE Directive

[CE-test - Ing. Gert Gremmen - ce-marking and more...]

There is some confusion over this subject:

1/  the ce marking directive still requires a rep "on-board" so resident on
European soil.
All New Approach directives under ce comply to this.

2/  The notified body (NB) is still required for R&TTE not harmonized
standards
to prescribe a test suite.
R&TTE harmonized standards do have a suitable test suite of their own.
3/  the notified body is still required for the frequency allocation per
country, unless
   a European harmonized frequency is used (currently just GSM and DECT).
   It's a good idea to comply to ERC freq. all. documents such as ERC 70-03
for short range devices.
   This one is a proposal for frequency harmonization for SRD in Europe.
   Be prepared for exceptions however.

So the key is:
Use a NB if Not Harmonized, otherwise do it yourself (or with our help).

All network related standards such as TBR21, are voluntarily.

Any way, selling devices is not forbidden at all as long as EMC and LVD
requirements are met.
You just should use the alert sign (and CE) including a list of ALL EC
counties that utilization is
not allowed.

Conclusion:

R&TTE is just as other electronics. The manufacturer should consult an NB
for not harmonized frequencies and not harmonized (radio) standards. In the
end all not harmonized frequencies usages need a notification to the
authorities.


Regards,

Gert Gremmen, (Ing)

ce-test, qualified testing

===
Web presence  http://www.cetest.nl
CE-shop http://www.cetest.nl/ce_shop.htm
/-/ Compliance testing is our core business /-/
===


>>-Original Message-
>>From: owner-emc-p...@ieee.org [mailto:owner-emc-p...@ieee.org]On Behalf
>>Of Courtland Thomas
>>Sent: Tuesday, February 27, 2001 11:07 PM
>>To: emcpost
>>Subject: RTTE Directive
>>
>>
>>
>>Hello group,
>>
>>I have been reading through different articles on the RTTE Directive and
>>getting somewhat confused. I have concluded that there is no
>>requirement for
>>an authorized representative within the Community any longer.
>>This may have
>>been the case all along, but it was good to have that person to submit the
>>technical files to a notified body. I believe the notified body
>>requirement
>>goes away with the RTTE directive also. Now all that is required
>>is for the
>>manufacturer to maintain the technical file and produce the Declaration of
>>Conformity. Am I on the right page?
>>
>>Thanks,
>>
>>Courtland Thomas
>>Patton Electronics
>>
>>
>>---
>>This message is from the IEEE EMC Society Product Safety
>>Technical Committee emc-pstc discussion list.
>>
>>Visit our web site at:  http://www.ewh.ieee.org/soc/emcs/pstc/
>>
>>To cancel your subscription, send mail to:
>> majord...@ieee.org
>>with the single line:
>> unsubscribe emc-pstc
>>
>>For help, send mail to the list administrators:
>> Michael Garretson:pstc_ad...@garretson.org
>> Dave Healddavehe...@mediaone.net
>>
>>For policy questions, send mail to:
>> Richard Nute:   ri...@ieee.org
>> Jim Bacher: j.bac...@ieee.org
>>
>>All emc-pstc postings are archived and searchable on the web at:
>>http://www.rcic.com/  click on "Virtual Conference Hall,"
>>
>>
<>

RE: RTTE Directive

[Wismer, Sam]

Courtland,
Assuming all of the standards that apply to your equipment are harmonised,
you are correct there is no need for a Notified Body.  Not a bad idea
however to have them do your testing.  As far as the authorized
representative within the community, I have long believed that this was not
necessary.  In fact the RTTE and the EMC directive use the same language:
"Where neither the mfg. nor his authorized representative is established
within the community, the obligation to keep the DoC and the technical
documentation at the disposal of the competent authority shall be the
responsibility of the person who places the product on the Community
market".  9 times out of 10 that person will be the mfg. or the authorized
rep, but clearly, it does not have to be.

  

~
Sam Wismer
Lead Regulatory Engineer/
Radio Approvals Engineer
LXE, Inc.
(770) 447-4224 Ext. 3654

Visit Our Website at:
http://www.lxe.com



-Original Message-
From: Courtland Thomas [mailto:ctho...@patton.com]
Sent: Tuesday, February 27, 2001 5:07 PM
To: emcpost
Subject: RTTE Directive



Hello group,

I have been reading through different articles on the RTTE Directive and
getting somewhat confused. I have concluded that there is no requirement for
an authorized representative within the Community any longer. This may have
been the case all along, but it was good to have that person to submit the
technical files to a notified body. I believe the notified body requirement
goes away with the RTTE directive also. Now all that is required is for the
manufacturer to maintain the technical file and produce the Declaration of
Conformity. Am I on the right page?

Thanks,

Courtland Thomas
Patton Electronics


---
This message is from the IEEE EMC Society Product Safety
Technical Committee emc-pstc discussion list.

Visit our web site at:  http://www.ewh.ieee.org/soc/emcs/pstc/

To cancel your subscription, send mail to:
 majord...@ieee.org
with the single line:
 unsubscribe emc-pstc

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 Michael Garretson:pstc_ad...@garretson.org
 Dave Healddavehe...@mediaone.net

For policy questions, send mail to:
 Richard Nute:   ri...@ieee.org
 Jim Bacher: j.bac...@ieee.org

All emc-pstc postings are archived and searchable on the web at:
http://www.rcic.com/  click on "Virtual Conference Hall,"

---
This message is from the IEEE EMC Society Product Safety
Technical Committee emc-pstc discussion list.

Visit our web site at:  http://www.ewh.ieee.org/soc/emcs/pstc/

To cancel your subscription, send mail to:
 majord...@ieee.org
with the single line:
 unsubscribe emc-pstc

For help, send mail to the list administrators:
 Michael Garretson:pstc_ad...@garretson.org
 Dave Healddavehe...@mediaone.net

For policy questions, send mail to:
 Richard Nute:   ri...@ieee.org
 Jim Bacher: j.bac...@ieee.org

All emc-pstc postings are archived and searchable on the web at:
http://www.rcic.com/  click on "Virtual Conference Hall,"

RE: RTTE Directive

[WOODS]

A representative is necessary if the manufacture is not resident in the EU.
That entity keeps the technical file and performs any other duties expressly
assigned by the manufacturer. This procedure is not related to any
procedural requirements to use or not use a Notified Body. A Notified Body
is needed if Annex III, IV or V applies. For example, our product is a short
range device where the spectrum standard has not been published; so we must
follow Annex IV and use a Notified Body. However, once the standard is
harmonized, we will switch to following Annex III and a Notified Body will
not be required.

Richard Woods

--
From:  Courtland Thomas [SMTP:ctho...@patton.com]
Sent:  Tuesday, February 27, 2001 5:07 PM
To:  emcpost
Subject:  RTTE Directive


Hello group,

I have been reading through different articles on the RTTE Directive and
getting somewhat confused. I have concluded that there is no requirement for
an authorized representative within the Community any longer. This may have
been the case all along, but it was good to have that person to submit the
technical files to a notified body. I believe the notified body requirement
goes away with the RTTE directive also. Now all that is required is for the
manufacturer to maintain the technical file and produce the Declaration of
Conformity. Am I on the right page?

Thanks,

Courtland Thomas
Patton Electronics


---
This message is from the IEEE EMC Society Product Safety
Technical Committee emc-pstc discussion list.

Visit our web site at:  http://www.ewh.ieee.org/soc/emcs/pstc/

To cancel your subscription, send mail to:
 majord...@ieee.org
with the single line:
 unsubscribe emc-pstc

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 Michael Garretson:pstc_ad...@garretson.org
 Dave Healddavehe...@mediaone.net

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 Richard Nute:   ri...@ieee.org
 Jim Bacher: j.bac...@ieee.org

All emc-pstc postings are archived and searchable on the web at:
http://www.rcic.com/  click on "Virtual Conference Hall,"

---
This message is from the IEEE EMC Society Product Safety
Technical Committee emc-pstc discussion list.

Visit our web site at:  http://www.ewh.ieee.org/soc/emcs/pstc/

To cancel your subscription, send mail to:
 majord...@ieee.org
with the single line:
 unsubscribe emc-pstc

For help, send mail to the list administrators:
 Michael Garretson:pstc_ad...@garretson.org
 Dave Healddavehe...@mediaone.net

For policy questions, send mail to:
 Richard Nute:   ri...@ieee.org
 Jim Bacher: j.bac...@ieee.org

All emc-pstc postings are archived and searchable on the web at:
http://www.rcic.com/  click on "Virtual Conference Hall,"

RE: RTTE DoC Languages

[WOODS]

One of TCAM's options, as you mention, is not to include the actual DoC, but
include a web site link where the DoC can be found. What was not clear is if
that web link statement needs to be in the official languages.

Richard Woods

--
From:  Wismer, Sam [SMTP:wisme...@ems-t.com]
Sent:  Friday, February 09, 2001 2:44 PM
To:  wo...@sensormatic.com; emc-p...@majordomo.ieee.org
Subject:  RE: RTTE DoC Languages

Hi Richard,
According to the January 2001 issue of Conformity, TCAM says that a DoC need
not be provided with the product.  This is good news for me, since our
terminal devices can use many different radios and the manuals for these
devices are starting to look a bit ridiculous with the first five or six
pages being full size images of our DoC's for each radio.  


~
Sam Wismer
Lead Regulatory Engineer/
Radio Approvals Engineer
LXE, Inc.
(770) 447-4224 Ext. 3654

Visit Our Website at:
http://www.lxe.com <http://www.lxe.com> 



-Original Message-
From: wo...@sensormatic.com [ mailto:wo...@sensormatic.com
<mailto:wo...@sensormatic.com> ]
Sent: Friday, February 09, 2001 10:54 AM
To: emc-p...@majordomo.ieee.org
Subject: RTTE DoC Languages


As you may have heard, TCAM has decided that it is not necessary for the DoC
provided with RTTE to be translated into the official languages. One
acceptable method is to include a simple declaration statement in the
official language along with a copy of the original DoC.  I have decided to
take this approach and include the following text in the official languages
of the EU and EFTA member states.

"Sensormatic Electronics declares that this equipment is in compliance with
the essential requirements and other relevant provisions of Directive
1999/5/EC. The equipment is intended for use in all EU and EFTA member
states."

The translations are in the attached PDF file. The country codes are per
ISO. No representations of accuracy or fitness are made by me or Sensormatic
Electronics. Use them at your own risk.


Richard Woods


 <> 




---
This message is from the IEEE EMC Society Product Safety
Technical Committee emc-pstc discussion list.

To cancel your subscription, send mail to:
 majord...@ieee.org
with the single line:
 unsubscribe emc-pstc

For help, send mail to the list administrators:
 Jim Bacher:  jim_bac...@mail.monarch.com
 Michael Garretson:pstc_ad...@garretson.org

For policy questions, send mail to:
 Richard Nute:   ri...@ieee.org

RE: RTTE DoC Languages

[Wismer, Sam]

Hi Richard,
According to the January 2001 issue of Conformity, TCAM says that a DoC need
not be provided with the product.  This is good news for me, since our
terminal devices can use many different radios and the manuals for these
devices are starting to look a bit ridiculous with the first five or six
pages being full size images of our DoC's for each radio.  


~
Sam Wismer
Lead Regulatory Engineer/
Radio Approvals Engineer
LXE, Inc.
(770) 447-4224 Ext. 3654

Visit Our Website at:
http://www.lxe.com  



-Original Message-
From: wo...@sensormatic.com [ mailto:wo...@sensormatic.com
 ]
Sent: Friday, February 09, 2001 10:54 AM
To: emc-p...@majordomo.ieee.org
Subject: RTTE DoC Languages


As you may have heard, TCAM has decided that it is not necessary for the DoC
provided with RTTE to be translated into the official languages. One
acceptable method is to include a simple declaration statement in the
official language along with a copy of the original DoC.  I have decided to
take this approach and include the following text in the official languages
of the EU and EFTA member states.

"Sensormatic Electronics declares that this equipment is in compliance with
the essential requirements and other relevant provisions of Directive
1999/5/EC. The equipment is intended for use in all EU and EFTA member
states."

The translations are in the attached PDF file. The country codes are per
ISO. No representations of accuracy or fitness are made by me or Sensormatic
Electronics. Use them at your own risk.


Richard Woods


 <> 

RE: RTTE & Placing in Service

[rbusche]

I had to alter the address slightly to access the site. I used
http://europa.eu.int/comm/enterprise/newapproach/legislation/guide/legislati
on.htm and then selected the EN (PDF) file.

RIck

Thanks for the info...


-Original Message-
From: wo...@sensormatic.com [mailto:wo...@sensormatic.com]
Sent: Thursday, February 01, 2001 6:31 AM
To: emc-p...@majordomo.ieee.org
Subject: RE: RTTE & Placing in Service



The Commission's guide to the implementation of directives ("blue book")
indicates that a device placed into service for the manufacturer's own use
is not placed on the market. In the link below, see section 2.3.1 for
Placing on the Market and 2.3.2 for placing in service. Specifically note
the third bullet in section 2.3.2. 

http://europa.eu.int/comm/enterprise/newapproach/legislation/guide/document/
chap02.pdf
<http://europa.eu.int/comm/enterprise/newapproach/legislation/guide/document
/chap02.pdf> 

Richard Woods

--
From:  Kevin Harris [SMTP:harr...@dscltd.com]
Sent:  Wednesday, January 31, 2001 3:58 PM
To:  'wo...@sensormatic.com'; emc-p...@majordomo.ieee.org
Subject:  RE: RTTE & Placing in Service

You are right Richard. 

More directly to your point here is a quote taken from 

http://europa.eu.int/comm/enterprise/rtte/interp.htm 

and then click on question 12

In the context of the new approach "placing on the market" is defined as: «
A product is placed on the Community market when it is made available for
the first time. This is considered to take place when a product is
transferred from the stage of manufacture with the intention of distribution
and/or use on the Community market . Moreover, the concept of placing on the
market refers to each individual product, not to a type of product, and
whether it was manufactured as an individual unit or in series".

Now the quote is in the middle of a fairly muddled analysis and perhaps
should be taken with a grain of salt  but what I get from that is it seems
like a sale need not take place to be taken into service and therefor you
would have to notify.


Best Regards,


Kevin Harris
Manager, Approval Services
Digital Security Controls
3301 Langstaff Road
Concord, Ontario
CANADA
L4K 4L2

Tel: +1 905 760 3000 Ext. 2378
Fax +1 905 760 3020

Email: harr...@dscltd.com <mailto:harr...@dscltd.com> 

-Original Message-
From:   wo...@sensormatic.com [mailto:wo...@sensormatic.com]
Sent:   Wednesday, January 31, 2001 2:04 PM
To:     emc-p...@majordomo.ieee.org
Subject:RE: RTTE & Placing in Service


Thanks for that info Kevin. I think that publication only
affects needing a
Notified Body per Annex III. The -3  lists the essential
test suites, so it
is no longer necessary to ask a Notified Body to identify
them.

Richard Woods

--
From:  Kevin Harris [SMTP:harr...@dscltd.com]
Sent:  Wednesday, January 31, 2001 2:07 PM
To:  'wo...@sensormatic.com'; emc-p...@majordomo.ieee.org
Subject:  RE: RTTE & Placing in Service

Hi Richard,

I think it all becomes a moot point on Feb 7. I was looking
at the ETSI site
yesterday and they indicate there that EN 300-220-3 will be
published in the
OJ  for the R&TTE directive on that date. EN 300-220-3 is
the harmonised EN
covering the essential requirements under Article 3.2 of the
directive

 Best Regards,


Kevin Harris
Manager, Approval Services
Digital Security Controls
3301 Langstaff Road
Concord, Ontario
CANADA
L4K 4L2

Tel: +1 905 760 3000 Ext. 2378
Fax +1 905 760 3020

Email: harr...@dscltd.com <mailto:harr...@dscltd.com> 

-Original Message-
From:   wo...@sensormatic.com
[mailto:wo...@sensormatic.com]
Sent:   Wednesday, January 31, 2001 12:43 PM
To: emc-p...@majordomo.ieee.org
Subject:RTTE & Placing in Service


Consider a low power radio transmitter
subject to EN 300 220
that is to be
used only by the manufacturer's service
organization and
will not be placed
on the market for sale. EN 300 220 is a
harmonized standard,
but the
operating frequency is not harmonized.

It appears that the provisions in Article 6
do not ap

RE: RTTE & Placing in Service

[WOODS]

The Commission's guide to the implementation of directives ("blue book")
indicates that a device placed into service for the manufacturer's own use
is not placed on the market. In the link below, see section 2.3.1 for
Placing on the Market and 2.3.2 for placing in service. Specifically note
the third bullet in section 2.3.2. 

http://europa.eu.int/comm/enterprise/newapproach/legislation/guide/document/
chap02.pdf
<http://europa.eu.int/comm/enterprise/newapproach/legislation/guide/document
/chap02.pdf> 

Richard Woods

--
From:  Kevin Harris [SMTP:harr...@dscltd.com]
Sent:  Wednesday, January 31, 2001 3:58 PM
To:  'wo...@sensormatic.com'; emc-p...@majordomo.ieee.org
Subject:  RE: RTTE & Placing in Service

You are right Richard. 

More directly to your point here is a quote taken from 

http://europa.eu.int/comm/enterprise/rtte/interp.htm 

and then click on question 12

In the context of the new approach "placing on the market" is defined as: «
A product is placed on the Community market when it is made available for
the first time. This is considered to take place when a product is
transferred from the stage of manufacture with the intention of distribution
and/or use on the Community market . Moreover, the concept of placing on the
market refers to each individual product, not to a type of product, and
whether it was manufactured as an individual unit or in series".

Now the quote is in the middle of a fairly muddled analysis and perhaps
should be taken with a grain of salt  but what I get from that is it seems
like a sale need not take place to be taken into service and therefor you
would have to notify.


Best Regards,


Kevin Harris
Manager, Approval Services
Digital Security Controls
3301 Langstaff Road
Concord, Ontario
CANADA
L4K 4L2

Tel: +1 905 760 3000 Ext. 2378
Fax +1 905 760 3020

Email: harr...@dscltd.com <mailto:harr...@dscltd.com> 

-Original Message-
From:   wo...@sensormatic.com [mailto:wo...@sensormatic.com]
Sent:   Wednesday, January 31, 2001 2:04 PM
To: emc-p...@majordomo.ieee.org
Subject:RE: RTTE & Placing in Service


Thanks for that info Kevin. I think that publication only
affects needing a
Notified Body per Annex III. The -3  lists the essential
test suites, so it
is no longer necessary to ask a Notified Body to identify
them.

Richard Woods

--
From:  Kevin Harris [SMTP:harr...@dscltd.com]
Sent:  Wednesday, January 31, 2001 2:07 PM
To:  'wo...@sensormatic.com'; emc-p...@majordomo.ieee.org
Subject:  RE: RTTE & Placing in Service

Hi Richard,

I think it all becomes a moot point on Feb 7. I was looking
at the ETSI site
yesterday and they indicate there that EN 300-220-3 will be
published in the
OJ  for the R&TTE directive on that date. EN 300-220-3 is
the harmonised EN
covering the essential requirements under Article 3.2 of the
directive

 Best Regards,


Kevin Harris
Manager, Approval Services
Digital Security Controls
3301 Langstaff Road
Concord, Ontario
CANADA
L4K 4L2

Tel: +1 905 760 3000 Ext. 2378
Fax +1 905 760 3020

Email: harr...@dscltd.com <mailto:harr...@dscltd.com> 

-Original Message-
From:   wo...@sensormatic.com
[mailto:wo...@sensormatic.com]
Sent:   Wednesday, January 31, 2001 12:43 PM
To: emc-p...@majordomo.ieee.org
Subject:RTTE & Placing in Service


Consider a low power radio transmitter
subject to EN 300 220
that is to be
used only by the manufacturer's service
organization and
will not be placed
on the market for sale. EN 300 220 is a
harmonized standard,
but the
operating frequency is not harmonized.

It appears that the provisions in Article 6
do not apply
since the product
will not be placed on the market. Article 7
contains the
provisions for
putting into service. Notification to the
spectrum
authorities (from Article
6) does not appear to be a requirement even
though the
frequency is not
   

RE: RTTE & Placing in Service

[Kevin Harris]

You are right Richard. 

More directly to your point here is a quote taken from 

http://europa.eu.int/comm/enterprise/rtte/interp.htm 

and then click on question 12

In the context of the new approach "placing on the market" is defined as: «
A product is placed on the Community market when it is made available for
the first time. This is considered to take place when a product is
transferred from the stage of manufacture with the intention of distribution
and/or use on the Community market . Moreover, the concept of placing on the
market refers to each individual product, not to a type of product, and
whether it was manufactured as an individual unit or in series".

Now the quote is in the middle of a fairly muddled analysis and perhaps
should be taken with a grain of salt  but what I get from that is it seems
like a sale need not take place to be taken into service and therefor you
would have to notify.


Best Regards,


Kevin Harris
Manager, Approval Services
Digital Security Controls
3301 Langstaff Road
Concord, Ontario
CANADA
L4K 4L2

Tel: +1 905 760 3000 Ext. 2378
Fax +1 905 760 3020

Email: harr...@dscltd.com <mailto:harr...@dscltd.com> 

-Original Message-
From:   wo...@sensormatic.com [mailto:wo...@sensormatic.com]
Sent:   Wednesday, January 31, 2001 2:04 PM
To: emc-p...@majordomo.ieee.org
        Subject:RE: RTTE & Placing in Service


Thanks for that info Kevin. I think that publication only
affects needing a
Notified Body per Annex III. The -3  lists the essential
test suites, so it
is no longer necessary to ask a Notified Body to identify
them.

Richard Woods

--
From:  Kevin Harris [SMTP:harr...@dscltd.com]
Sent:  Wednesday, January 31, 2001 2:07 PM
To:  'wo...@sensormatic.com'; emc-p...@majordomo.ieee.org
Subject:  RE: RTTE & Placing in Service

Hi Richard,

I think it all becomes a moot point on Feb 7. I was looking
at the ETSI site
yesterday and they indicate there that EN 300-220-3 will be
published in the
OJ  for the R&TTE directive on that date. EN 300-220-3 is
the harmonised EN
covering the essential requirements under Article 3.2 of the
directive

 Best Regards,


Kevin Harris
Manager, Approval Services
Digital Security Controls
3301 Langstaff Road
Concord, Ontario
CANADA
L4K 4L2

Tel: +1 905 760 3000 Ext. 2378
Fax +1 905 760 3020

Email: harr...@dscltd.com <mailto:harr...@dscltd.com> 

-Original Message-
From:   wo...@sensormatic.com
[mailto:wo...@sensormatic.com]
Sent:   Wednesday, January 31, 2001 12:43 PM
To: emc-p...@majordomo.ieee.org
Subject:RTTE & Placing in Service


Consider a low power radio transmitter
subject to EN 300 220
that is to be
used only by the manufacturer's service
organization and
will not be placed
on the market for sale. EN 300 220 is a
harmonized standard,
but the
operating frequency is not harmonized.

It appears that the provisions in Article 6
do not apply
since the product
will not be placed on the market. Article 7
contains the
provisions for
putting into service. Notification to the
spectrum
authorities (from Article
6) does not appear to be a requirement even
though the
frequency is not
harmonized. It appears that it is sufficient
to comply with
the essential
requirements and apply the CE marking which
must include the
alert symbol
per Annex VII since the frequency is not
harmonized. 

A member state may restrict the placing in
service, but only
for the three
reasons specified in Article 7.2: efficient
use of the
spectrum,
interference and public health.  It appears
there is no
legal requirement to
notify the state prior to placi

RE: RTTE & Placing in Service

[WOODS]

Thanks for that info Kevin. I think that publication only affects needing a
Notified Body per Annex III. The -3  lists the essential test suites, so it
is no longer necessary to ask a Notified Body to identify them.

Richard Woods

--
From:  Kevin Harris [SMTP:harr...@dscltd.com]
Sent:  Wednesday, January 31, 2001 2:07 PM
To:  'wo...@sensormatic.com'; emc-p...@majordomo.ieee.org
Subject:  RE: RTTE & Placing in Service

Hi Richard,

I think it all becomes a moot point on Feb 7. I was looking at the ETSI site
yesterday and they indicate there that EN 300-220-3 will be published in the
OJ  for the R&TTE directive on that date. EN 300-220-3 is the harmonised EN
covering the essential requirements under Article 3.2 of the directive

 Best Regards,


Kevin Harris
Manager, Approval Services
Digital Security Controls
3301 Langstaff Road
Concord, Ontario
CANADA
L4K 4L2

Tel: +1 905 760 3000 Ext. 2378
Fax +1 905 760 3020

Email: harr...@dscltd.com <mailto:harr...@dscltd.com> 

-Original Message-
From:   wo...@sensormatic.com [mailto:wo...@sensormatic.com]
Sent:   Wednesday, January 31, 2001 12:43 PM
To: emc-p...@majordomo.ieee.org
Subject:RTTE & Placing in Service


Consider a low power radio transmitter subject to EN 300 220
that is to be
used only by the manufacturer's service organization and
will not be placed
on the market for sale. EN 300 220 is a harmonized standard,
but the
operating frequency is not harmonized.

It appears that the provisions in Article 6 do not apply
since the product
will not be placed on the market. Article 7 contains the
provisions for
putting into service. Notification to the spectrum
authorities (from Article
6) does not appear to be a requirement even though the
frequency is not
harmonized. It appears that it is sufficient to comply with
the essential
requirements and apply the CE marking which must include the
alert symbol
per Annex VII since the frequency is not harmonized. 

A member state may restrict the placing in service, but only
for the three
reasons specified in Article 7.2: efficient use of the
spectrum,
interference and public health.  It appears there is no
legal requirement to
notify the state prior to placing in service. Thus, any
restriction would
occur due to the state determining that one of the three
reasons apply to
one or more devices after it being placed in service. While
it may be argued
that it is a good idea to notify the states anyway, it does
not appear to be
a legal requirement.

Comments?

Richard Woods

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RE: RTTE & Placing in Service

[Kevin Harris]

Hi Richard,

I think it all becomes a moot point on Feb 7. I was looking at the ETSI site
yesterday and they indicate there that EN 300-220-3 will be published in the
OJ  for the R&TTE directive on that date. EN 300-220-3 is the harmonised EN
covering the essential requirements under Article 3.2 of the directive

 Best Regards,


Kevin Harris
Manager, Approval Services
Digital Security Controls
3301 Langstaff Road
Concord, Ontario
CANADA
L4K 4L2

Tel: +1 905 760 3000 Ext. 2378
Fax +1 905 760 3020

Email: harr...@dscltd.com  

-Original Message-
From:   wo...@sensormatic.com [mailto:wo...@sensormatic.com]
Sent:   Wednesday, January 31, 2001 12:43 PM
To: emc-p...@majordomo.ieee.org
Subject:RTTE & Placing in Service


Consider a low power radio transmitter subject to EN 300 220
that is to be
used only by the manufacturer's service organization and
will not be placed
on the market for sale. EN 300 220 is a harmonized standard,
but the
operating frequency is not harmonized.

It appears that the provisions in Article 6 do not apply
since the product
will not be placed on the market. Article 7 contains the
provisions for
putting into service. Notification to the spectrum
authorities (from Article
6) does not appear to be a requirement even though the
frequency is not
harmonized. It appears that it is sufficient to comply with
the essential
requirements and apply the CE marking which must include the
alert symbol
per Annex VII since the frequency is not harmonized. 

A member state may restrict the placing in service, but only
for the three
reasons specified in Article 7.2: efficient use of the
spectrum,
interference and public health.  It appears there is no
legal requirement to
notify the state prior to placing in service. Thus, any
restriction would
occur due to the state determining that one of the three
reasons apply to
one or more devices after it being placed in service. While
it may be argued
that it is a good idea to notify the states anyway, it does
not appear to be
a legal requirement.

Comments?

Richard Woods

---
This message is from the IEEE EMC Society Product Safety
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 Richard Nute:   ri...@ieee.org


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FW: RE: RTTE & PTT Notification

[Jon Bond]

Several people have requested the information on the R&TTE notification 
process we just went through. I tried to post it to the group, but as the 
message says below, the zip file was too big (~315K zipped). If anyone is 
interested in the forms mentioned below please contact me via email and 
I'll send you the zip file.

Jon Bond
Senior Compliance Engineer
Zoom Telephonics

-Original Message-
From:   Jim Bacher [SMTP:jim_bac...@mail.monarch.com]
Sent:   Friday, October 06, 2000 2:17 PM
To: Jon Bond
Cc: pstc_ad...@garretson.org
Subject:Re:RE: RTTE & PTT Notification

Jon, the listserver will not let a e-mail greater than 100K go through, so 
it
bounced your message.  Best bet is to find a ftp site or website where you 
can
post it, then send an e-mail out with a link on it.  Jim
Reply Separator
Subject:    RE: RTTE & PTT Notification
Author: Jon Bond 
List-Post: emc-pstc@listserv.ieee.org
Date:   10/6/00 10:38 AM

Richard,
Several people have also asked so the info is enclosed in a zip file below. 
 Since most of this info was generously provided to me by Sam Wismer, I 
wanted to check with him before forwarding it. Sam of course agreed that it 
could be provided to the forum. In the zip file, there are notification 
forms specifically for UK, Sweden, Spain, Norway, Ireland, Germany, 
Finland, Denmark, Belgium, and Luxembourg. There is also a generic form 
that we used for Italy, Austria, Iceland, and Greece. An Excel spreadsheet 
(again thanks to Sam) gives some contacts, email addresses, and web pages. 
 France, The Netherlands, and Switzerland on-line submittal forms can be 
found from this info. We used a notified body (NMI) to notify France, 
Germany, Portugal, and Spain. NMi provided me with DOC forms, Quality 
Declaration forms, Packaging info forms, a standards list to declare to, 
and TCF Annex II & IV forms to fill out for the TCF review and "statement 
of opinion". Please let me know if you're also interested in that info or 
if you have a problem opening anything that I'm trying to forward.
Regards,
Jon




---
This message is from the IEEE EMC Society Product Safety
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 Richard Nute:   ri...@ieee.org

RE: RTTE & PTT Notification

[Kevin Harris]

The following link from the Low Power Radio Association may prove useful

http://www.lpra.org/html/era.htm <http://www.lpra.org/html/era.htm> 



Best Regards,


Kevin Harris
Manager, Approval Services
Digital Security Controls
3301 Langstaff Road
Concord, Ontario
CANADA
L4K 4L2

Tel: +1 905 760 3000 Ext. 2378
Fax +1 905 760 3020

Email: harr...@dscltd.com <mailto:harr...@dscltd.com> 

-Original Message-
From:   Wismer, Sam [mailto:wisme...@lxe.com]
Sent:   Thursday, October 05, 2000 4:39 PM
To: wo...@sensormatic.com; emc-p...@majordomo.ieee.org
Subject:RE: RTTE & PTT Notification


No, seemed fairly simple once I figured out where to send
the notifications
to.  Let me know if you need some of that information, I
have developed a
good database.  

Oh I did get a call from someone in France about my
notification.  He
sounded like he was at a payphone in a train station.  On
top of that, his
English was bad and my French was worse so you can imagine
the call wasn't
productive.  I'm still not sure why he called although he
did say everything
was okay.  That's all I needed to know, so that's where the
conversation
ended.

All in all, my 1st experience with the new directive has
gone well.  I am
now in the process of converting our existing approvals over
to the new
scheme.  
 


~
Sam Wismer
RF Approvals Engineer
LXE, Inc.
(770) 447-4224 Ext. 3654

Visit Our Website at:
http://www.lxe.com



-Original Message-
From: wo...@sensormatic.com [mailto:wo...@sensormatic.com]
Sent: Thursday, October 05, 2000 2:19 PM
To: emc-p...@majordomo.ieee.org
Subject: RE: RTTE & PTT Notification



Thanks for blazing the trail, Sam. Did you run into any
quirks in other EEA
countries?

Richard Woods

--
From:  Wismer, Sam [SMTP:wisme...@lxe.com]
Sent:  Thursday, October 05, 2000 2:04 PM
To:  wo...@sensormatic.com;
emc-p...@majordomo.ieee.org
    Subject:  RE: RTTE & PTT Notification

Hi Richard,
Yes that was me.  For our 2.4GHZ equipment, I made
notification to
the RegTP
declaring complaince to the essential requirements
of the RTTE
Directive as
required by Article 6.4 of the directive.  The
response I received
back was
that it was necessary to declare complaince to their
national
standard, BAPT
222 ZV 126 in this case, as well as the ETS
standards(ETS 300 328).
I
thought this to be in violation of the directive and
thus European
law and
asked my notified body for advice.  They too thought
this to be a
violation
of the directive and agreed to look into the matter.
I never heard
back
from them on this issue.  

I went ahead and re-issued my notification form
declaring compliance
to both
standards since after review, I found them to be
technically
equivalent. 


~
Sam Wismer
RF Approvals Engineer
LXE, Inc.
(770) 447-4224 Ext. 3654

Visit Our Website at:
http://www.lxe.com <http://www.lxe.com> 



-Original Message-
From: wo...@sensormatic.com [
mailto:wo...@sensormatic.com
<mailto:wo...@sensormatic.com> ]
Sent: Thursday, October 05, 2000 9:29 AM
To: emc-p...@majordomo.ieee.org
Subject: RTTE & PTT Notification



We are about to begin our RTTE notification process
to the various
PTTs in
the EEA member countries.  I read on this forum that
Germany
requires
declaration to their national standard and not an
ETSI standard. Are
there
any countries that have "special&quo

RE: RTTE & PTT Notification

[WOODS]

Thanks Jon. We are using a recognized radio test lab to make our first
notifications. We may do it ourselves after that. I am sure that there are
many of us that would love to have a copy of that list you have. Would you
post it please?

Richard Woods

--
From:  Jon Bond [SMTP:jb...@zoomtel.com]
Sent:  Thursday, October 05, 2000 4:42 PM
To:  'rehel...@mmm.com'; wo...@sensormatic.com
Cc:  emc-p...@majordomo.ieee.org
Subject:  RE: RTTE & PTT Notification

We recently submitted notifications to the EU and EFTA member
states. With 
the generous help of a regular contributor to this forum, we were
provided 
with numerous member state notification forms, mailing addresses and
email 
addresses to send out the notifications.

We also "heard" that Germany was requiring declarations to a
national 
standard. In hopes of avoiding any problems, we used a notified body
to 
perform notification submittals to Germany and 3 other countries
we've had 
problems with in the past with regards to regulatory approvals. We
notified 
about 15 EU / EFTA members on our own. We only declared to the
relevant 
ETSI and EN standards, we did not declare to anyone's national
standard. 
The 4 week timeframe  has come and gone and we have only received
"ok's", 
and no responses. We have not received any "rejections" for not
declaring 
to a national standard. The 4-week time period has come and gone.
(BTW, 
Germany was a "no response".)

Regards,

Jon Bond
Senior Compliance Engineer
Zoom Telephonics

-Original Message-
From:   rehel...@mmm.com [SMTP:rehel...@mmm.com]
Sent:   Thursday, October 05, 2000 12:57 PM
To: wo...@sensormatic.com
    Cc: emc-p...@majordomo.ieee.org
Subject:Re: RTTE & PTT Notification




It is my understanding that the UK wants information on the
modulation used 
and
the ITU classifcation. Other than that I have not heard of anything
else 
from
any other country (including Germany).has anyone
else 
heard
of country "specials" and the RTTE?

===




wo...@sensormatic.com on 10/05/2000 08:29:15 AM

Please respond to wo...@sensormatic.com


To:   emc-p...@majordomo.ieee.org
cc:(bcc: Robert E. Heller/US-Corporate/3M/US)
Subject:  RTTE & PTT Notification




We are about to begin our RTTE notification process to the various
PTTs in
the EEA member countries.  I read on this forum that Germany
requires
declaration to their national standard and not an ETSI standard. Are
there
any countries that have "special" requirements for the notification?

Richard Woods

---
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 majord...@ieee.org
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 unsubscribe emc-pstc

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 Jim Bacher:  jim_bac...@mail.monarch.com
 Michael Garretson:pstc_ad...@garretson.org

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 Richard Nute:   ri...@ieee.org









---
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 Michael Garretson:pstc_ad...@garretson.org

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 Richard Nute:   ri...@ieee.org

---
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 Michael Garretson:pstc_ad...@garretson.org

For policy questions, send mail to:
 Richard Nute:   ri...@ieee.org

RE: RTTE & PTT Notification

[Wismer, Sam]

No, seemed fairly simple once I figured out where to send the notifications
to.  Let me know if you need some of that information, I have developed a
good database.  

Oh I did get a call from someone in France about my notification.  He
sounded like he was at a payphone in a train station.  On top of that, his
English was bad and my French was worse so you can imagine the call wasn't
productive.  I'm still not sure why he called although he did say everything
was okay.  That's all I needed to know, so that's where the conversation
ended.

All in all, my 1st experience with the new directive has gone well.  I am
now in the process of converting our existing approvals over to the new
scheme.  
 


~
Sam Wismer
RF Approvals Engineer
LXE, Inc.
(770) 447-4224 Ext. 3654

Visit Our Website at:
http://www.lxe.com



-Original Message-
From: wo...@sensormatic.com [mailto:wo...@sensormatic.com]
Sent: Thursday, October 05, 2000 2:19 PM
To: emc-p...@majordomo.ieee.org
Subject: RE: RTTE & PTT Notification



Thanks for blazing the trail, Sam. Did you run into any quirks in other EEA
countries?

Richard Woods

--
From:  Wismer, Sam [SMTP:wisme...@lxe.com]
Sent:  Thursday, October 05, 2000 2:04 PM
To:  wo...@sensormatic.com; emc-p...@majordomo.ieee.org
    Subject:  RE: RTTE & PTT Notification

Hi Richard,
Yes that was me.  For our 2.4GHZ equipment, I made notification to
the RegTP
declaring complaince to the essential requirements of the RTTE
Directive as
required by Article 6.4 of the directive.  The response I received
back was
that it was necessary to declare complaince to their national
standard, BAPT
222 ZV 126 in this case, as well as the ETS standards(ETS 300 328).
I
thought this to be in violation of the directive and thus European
law and
asked my notified body for advice.  They too thought this to be a
violation
of the directive and agreed to look into the matter.  I never heard
back
from them on this issue.  

I went ahead and re-issued my notification form declaring compliance
to both
standards since after review, I found them to be technically
equivalent. 


~
Sam Wismer
RF Approvals Engineer
LXE, Inc.
(770) 447-4224 Ext. 3654

Visit Our Website at:
http://www.lxe.com <http://www.lxe.com> 



-Original Message-
From: wo...@sensormatic.com [ mailto:wo...@sensormatic.com
<mailto:wo...@sensormatic.com> ]
Sent: Thursday, October 05, 2000 9:29 AM
To: emc-p...@majordomo.ieee.org
Subject: RTTE & PTT Notification



We are about to begin our RTTE notification process to the various
PTTs in
the EEA member countries.  I read on this forum that Germany
requires
declaration to their national standard and not an ETSI standard. Are
there
any countries that have "special" requirements for the notification?

Richard Woods

---
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 unsubscribe emc-pstc

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 Jim Bacher:  jim_bac...@mail.monarch.com
 Michael Garretson:pstc_ad...@garretson.org

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 Richard Nute:   ri...@ieee.org



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 Michael Garretson:pstc_ad...@garretson.org

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 Richard Nute:   ri...@ieee.org


---
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 Michael Garretson:pstc_ad...@garretson.org

For policy questions, send mail to:
 Richard Nute:   ri...@ieee.org

RE: RTTE & PTT Notification

[Jon Bond]

We recently submitted notifications to the EU and EFTA member states. With 
the generous help of a regular contributor to this forum, we were provided 
with numerous member state notification forms, mailing addresses and email 
addresses to send out the notifications.

We also "heard" that Germany was requiring declarations to a national 
standard. In hopes of avoiding any problems, we used a notified body to 
perform notification submittals to Germany and 3 other countries we've had 
problems with in the past with regards to regulatory approvals. We notified 
about 15 EU / EFTA members on our own. We only declared to the relevant 
ETSI and EN standards, we did not declare to anyone's national standard. 
The 4 week timeframe  has come and gone and we have only received "ok's", 
and no responses. We have not received any "rejections" for not declaring 
to a national standard. The 4-week time period has come and gone. (BTW, 
Germany was a "no response".)

Regards,

Jon Bond
Senior Compliance Engineer
Zoom Telephonics

-Original Message-
From:   rehel...@mmm.com [SMTP:rehel...@mmm.com]
Sent:   Thursday, October 05, 2000 12:57 PM
To: wo...@sensormatic.com
Cc:     emc-p...@majordomo.ieee.org
Subject:Re: RTTE & PTT Notification




It is my understanding that the UK wants information on the modulation used 
and
the ITU classifcation. Other than that I have not heard of anything else 
from
any other country (including Germany).has anyone else 
heard
of country "specials" and the RTTE?

===




wo...@sensormatic.com on 10/05/2000 08:29:15 AM

Please respond to wo...@sensormatic.com


To:   emc-p...@majordomo.ieee.org
cc:(bcc: Robert E. Heller/US-Corporate/3M/US)
Subject:  RTTE & PTT Notification




We are about to begin our RTTE notification process to the various PTTs in
the EEA member countries.  I read on this forum that Germany requires
declaration to their national standard and not an ETSI standard. Are there
any countries that have "special" requirements for the notification?

Richard Woods

---
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 majord...@ieee.org
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 unsubscribe emc-pstc

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 Jim Bacher:  jim_bac...@mail.monarch.com
 Michael Garretson:pstc_ad...@garretson.org

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 Richard Nute:   ri...@ieee.org









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 Richard Nute:   ri...@ieee.org


---
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 Michael Garretson:pstc_ad...@garretson.org

For policy questions, send mail to:
 Richard Nute:   ri...@ieee.org

RE: RTTE & PTT Notification

[WOODS]

Thanks for blazing the trail, Sam. Did you run into any quirks in other EEA
countries?

Richard Woods

--
From:  Wismer, Sam [SMTP:wisme...@lxe.com]
Sent:  Thursday, October 05, 2000 2:04 PM
To:  wo...@sensormatic.com; emc-p...@majordomo.ieee.org
Subject:  RE: RTTE & PTT Notification

Hi Richard,
Yes that was me.  For our 2.4GHZ equipment, I made notification to
the RegTP
declaring complaince to the essential requirements of the RTTE
Directive as
required by Article 6.4 of the directive.  The response I received
back was
that it was necessary to declare complaince to their national
standard, BAPT
222 ZV 126 in this case, as well as the ETS standards(ETS 300 328).
I
thought this to be in violation of the directive and thus European
law and
asked my notified body for advice.  They too thought this to be a
violation
of the directive and agreed to look into the matter.  I never heard
back
from them on this issue.  

I went ahead and re-issued my notification form declaring compliance
to both
standards since after review, I found them to be technically
equivalent. 


~
Sam Wismer
RF Approvals Engineer
LXE, Inc.
(770) 447-4224 Ext. 3654

Visit Our Website at:
http://www.lxe.com <http://www.lxe.com> 



-Original Message-
From: wo...@sensormatic.com [ mailto:wo...@sensormatic.com
<mailto:wo...@sensormatic.com> ]
Sent: Thursday, October 05, 2000 9:29 AM
To: emc-p...@majordomo.ieee.org
Subject: RTTE & PTT Notification



We are about to begin our RTTE notification process to the various
PTTs in
the EEA member countries.  I read on this forum that Germany
requires
declaration to their national standard and not an ETSI standard. Are
there
any countries that have "special" requirements for the notification?

Richard Woods

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RE: RTTE & PTT Notification

[Wismer, Sam]

Hi Richard,
Yes that was me.  For our 2.4GHZ equipment, I made notification to the RegTP
declaring complaince to the essential requirements of the RTTE Directive as
required by Article 6.4 of the directive.  The response I received back was
that it was necessary to declare complaince to their national standard, BAPT
222 ZV 126 in this case, as well as the ETS standards(ETS 300 328).  I
thought this to be in violation of the directive and thus European law and
asked my notified body for advice.  They too thought this to be a violation
of the directive and agreed to look into the matter.  I never heard back
from them on this issue.  

I went ahead and re-issued my notification form declaring compliance to both
standards since after review, I found them to be technically equivalent. 


~
Sam Wismer
RF Approvals Engineer
LXE, Inc.
(770) 447-4224 Ext. 3654

Visit Our Website at:
http://www.lxe.com  



-Original Message-
From: wo...@sensormatic.com [ mailto:wo...@sensormatic.com
 ]
Sent: Thursday, October 05, 2000 9:29 AM
To: emc-p...@majordomo.ieee.org
Subject: RTTE & PTT Notification



We are about to begin our RTTE notification process to the various PTTs in
the EEA member countries.  I read on this forum that Germany requires
declaration to their national standard and not an ETSI standard. Are there
any countries that have "special" requirements for the notification?

Richard Woods

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Re: RTTE & PTT Notification

[reheller]

It is my understanding that the UK wants information on the modulation used and
the ITU classifcation. Other than that I have not heard of anything else from
any other country (including Germany).has anyone else heard
of country "specials" and the RTTE?

===




wo...@sensormatic.com on 10/05/2000 08:29:15 AM

Please respond to wo...@sensormatic.com


To:   emc-p...@majordomo.ieee.org
cc:(bcc: Robert E. Heller/US-Corporate/3M/US)
Subject:  RTTE & PTT Notification




We are about to begin our RTTE notification process to the various PTTs in
the EEA member countries.  I read on this forum that Germany requires
declaration to their national standard and not an ETSI standard. Are there
any countries that have "special" requirements for the notification?

Richard Woods

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RE: RTTE Notification Acknowledgments

[Pettit, Ghery]

Details?

-Original Message-
From: Gorodetsky, Vitaly [mailto:vgorodet...@canoga.com]
Sent: Wednesday, September 27, 2000 8:48 AM
To: 'wo...@sensormatic.com'; emc-p...@ieee.org
Subject: RE: RTTE Notification Acknowledgments



I am wondering whether members of this group are aware of dramatic
consequences due to unauthorized use of a frequency by a US TV company
during the Olympics Opening Ceremony?
 
Vitaly  Gorodetsky


-Original Message-
From:   wo...@sensormatic.com [SMTP:wo...@sensormatic.com]
Sent:   Wednesday, September 27, 2000 6:56 AM
To: emc-p...@ieee.org
Subject:    RE: RTTE Notification Acknowledgments


I have read conflicting information in this regard. One camp says
that you
are free to market if there is no response. The other camp says that
you are
free to market but you are still responsible for ensuring that the
equipment
complies with the state's requirements.

At least you are not receiving rejections after 5 months!

Richard Woods

--
From:  Wismer, Sam [SMTP:wisme...@lxe.com]
Sent:  Wednesday, September 27, 2000 8:21 AM
To:  EMC Forum (E-mail)
Subject:  RTTE Notification Acknowledgments


Hi Group,
From http://www.radio.gov.uk/:  
"Article 6.4 of the Radio Equipment and Telecommunications
Terminal
Equipment (R&TTE) Directive 1999/5/EC requires that radio
equipment
using
frequency bands whose use is not harmonised throughout the
Community
shall
be notified to the relevant national spectrum management
authorities
at
least four weeks before it is placed on their market."
Although not specifically stated above or in the Directive,
it is my
understanding that upon acknowledgment of the notification
or after
4 weeks
has elapsed since the notification with no response,
whichever comes
first,
the manufacturer is free to place the product on the market.

If my understanding is correct, why then am I getting these
acknowledgments
5 months after making the notification?



~
Sam Wismer
RF Approvals Engineer
LXE, Inc.
(770) 447-4224 Ext. 3654

Visit Our Website at:
http://www.lxe.com



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RE: RTTE Notification Acknowledgments

[Gorodetsky, Vitaly]

I am wondering whether members of this group are aware of dramatic
consequences due to unauthorized use of a frequency by a US TV company
during the Olympics Opening Ceremony?
 
Vitaly  Gorodetsky


-Original Message-
From:   wo...@sensormatic.com [SMTP:wo...@sensormatic.com]
Sent:   Wednesday, September 27, 2000 6:56 AM
To: emc-p...@ieee.org
Subject:RE: RTTE Notification Acknowledgments


I have read conflicting information in this regard. One camp says
that you
are free to market if there is no response. The other camp says that
you are
free to market but you are still responsible for ensuring that the
equipment
complies with the state's requirements.

At least you are not receiving rejections after 5 months!

Richard Woods

--
From:  Wismer, Sam [SMTP:wisme...@lxe.com]
Sent:  Wednesday, September 27, 2000 8:21 AM
To:  EMC Forum (E-mail)
Subject:  RTTE Notification Acknowledgments


Hi Group,
From http://www.radio.gov.uk/:  
"Article 6.4 of the Radio Equipment and Telecommunications
Terminal
Equipment (R&TTE) Directive 1999/5/EC requires that radio
equipment
using
frequency bands whose use is not harmonised throughout the
Community
shall
be notified to the relevant national spectrum management
authorities
at
least four weeks before it is placed on their market."
Although not specifically stated above or in the Directive,
it is my
understanding that upon acknowledgment of the notification
or after
4 weeks
has elapsed since the notification with no response,
whichever comes
first,
the manufacturer is free to place the product on the market.

If my understanding is correct, why then am I getting these
acknowledgments
5 months after making the notification?



~
Sam Wismer
RF Approvals Engineer
LXE, Inc.
(770) 447-4224 Ext. 3654

Visit Our Website at:
http://www.lxe.com



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RE: RTTE Notification Acknowledgments

[WOODS]

I have read conflicting information in this regard. One camp says that you
are free to market if there is no response. The other camp says that you are
free to market but you are still responsible for ensuring that the equipment
complies with the state's requirements.

At least you are not receiving rejections after 5 months!

Richard Woods

--
From:  Wismer, Sam [SMTP:wisme...@lxe.com]
Sent:  Wednesday, September 27, 2000 8:21 AM
To:  EMC Forum (E-mail)
Subject:  RTTE Notification Acknowledgments


Hi Group,
From http://www.radio.gov.uk/:  
"Article 6.4 of the Radio Equipment and Telecommunications Terminal
Equipment (R&TTE) Directive 1999/5/EC requires that radio equipment
using
frequency bands whose use is not harmonised throughout the Community
shall
be notified to the relevant national spectrum management authorities
at
least four weeks before it is placed on their market."
Although not specifically stated above or in the Directive, it is my
understanding that upon acknowledgment of the notification or after
4 weeks
has elapsed since the notification with no response, whichever comes
first,
the manufacturer is free to place the product on the market.  
If my understanding is correct, why then am I getting these
acknowledgments
5 months after making the notification?



~
Sam Wismer
RF Approvals Engineer
LXE, Inc.
(770) 447-4224 Ext. 3654

Visit Our Website at:
http://www.lxe.com



---
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RE: RTTE Radio Verification

[martin]

Sam,

The assumption in the approval of a product for sale in the EU is that,   
if a manufacturer affixes a CE mark to a product and issues the DoC then,   
he is effectively saying to the authorities that he takes responsibility   
for the compliance of the product, including the conformity assessment   
procedures used.  It is acceptable for a manufacturer to issue a DoC with   
another company's name on it - when that company is selling the product,   
for example where the product is badged with the seller's name, as long   
as the actual manufacturer's name appears on the DoC.

If a new manufacturer wants to take over complete responsibility for the   
certification of a product, then it is presumed that he has control over   
manufacturing and the actual manufacturer, if not a part of the company   
(such as being an approved subcontractor), may not change the design of   
the product without the approval of the new manufacturer.  In other words   
the new manufacturer becomes the design authority and controls the design   
of the product.  This is easy for self certification because the   
compliance documentation is simply passed across to the new manufacturer.   
 The new manufacturer then issues a new DoC.

However, if a third party has been used in the assessment procedure then   
this produces complications for the new manufacturer.  This is   
particularly the case where the QA system used by the original   
manufacturer has been assessed by a notified body.  The product approval   
and the approval of the QA system is completely dependent on the   
assessment by the notified body.  This is not transferable.  So if a   
notified body has been involved in any assessment via an assessment of   
the QA system, e.g. Annex V procedures of the R&TTED, then the new   
manufacturer will have to go through the same process again.

If the new manufacturer leaves compliance responsibility with the   
original manufacturer and is simply treated as an approved subcontractor   
then the notified body may be willing to accept the original   
certification and the original manufacturer issues the DoC with the new   
manufacturer named as a supplier of the product.

Confused?  It is all really quite logical and the only thing the EU   
really want to know is where to place the blame when something goes   
wrong.

Regards

Martin Green
Technology International (Europe) Ltd.
Tel.: (44) 1793 783137
Fax: (44) 1793 782310

 -Original Message-
From:   Wismer, Sam [SMTP:wisme...@lxe.com]
Sent:   12 September 2000 14:40
To: EMC Forum (E-mail); martin
Subject:RTTE Radio Verification

   


Group,
Interesting discussion on FCC Verification of OEM ITE equipment.

I have another twist that includes radio and the EU.

Company A has a 2.4GHz radio device that they have self declared to the   
RTTE
Directive in accordance with Annex V of the directive.

Company B, with no internationally recognized quality system in place and
has not been assessed by a Notified Body,  wishes to OEM the radio device
and to assume the existing approvals.  In effect appear to the world as   
the
manufacturer.  In the USA that can be done via a Grantee change with the
FCC.  With that, company B assumes the FCC approval that company A has
obtained and now enjoys it's own FCC identity.  This allows company B to
file permissive change applications with no involvement by Company A.   
 This
also used to be the case in the EU before the RTTE Directive.  However,   
is
it still possible between company A, that used Annex V to declare
compliance, and company B who wishes to assume that approval even if   
company
B does not have the quality system in place that is required by Annex V,
which the approval is declared to?



~
Sam Wismer
RF Approvals Engineer
LXE, Inc.
(770) 447-4224 Ext. 3654

Visit Our Website at:
http://www.lxe.com



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RE: RTTE Radio Verification

[Bandele Adepoju]

Hello Sam,

I am not familiar with this 'Grantee Change' procedure that
you described below.  My experience with the FCC in the
situation of an OEM of a radio product by second company 
is that the company OEMing the product (Company B) files
'a new application' with the FCC (albeit an abbreviated 
application) referencing the test data and report previously 
submitted by the Company holding the equipment grant 
(Company A) and indicating that both products are the same 
and would continue to be so.  Company B submits new photos 
of the product, a new label with label location diagram 
showing new FCC ID, any change in product model and new 
company name and the application must be accompanied by an 
attestation statement. For the new FCC ID, Company B would 
need to file for a grantee code if it does not already have 
one.

The 'Grantee Change' procedure that you described below seems
to be the one that is applicable in the case of a 'transfer 
of control' or 'a sale' of the old company (Company A) to a 
new company (Company B).

I would believe that a similar OEM situation (Company B OEMing
Company A's product) in Europe would require that Company B 
goes the TCF route, using the test report and product data of 
Company A.  

Annex V is for Companies with a qualified Quality Assurance 
System in place.


>-Original Message-
>From: Wismer, Sam [mailto:wisme...@lxe.com]
>Sent: Tuesday, September 12, 2000 11:40 AM
>To: EMC Forum (E-mail)
>Subject: RTTE Radio Verification
>
>
>
>Group,
>Interesting discussion on FCC Verification of OEM ITE equipment.
>
>I have another twist that includes radio and the EU.
>
>Company A has a 2.4GHz radio device that they have self 
>declared to the RTTE
>Directive in accordance with Annex V of the directive.
>
>Company B, with no internationally recognized quality system 
>in place and
>has not been assessed by a Notified Body,  wishes to OEM the 
>radio device
>and to assume the existing approvals.  In effect appear to the 
>world as the
>manufacturer.  In the USA that can be done via a Grantee 
>change with the
>FCC.  With that, company B assumes the FCC approval that company A has
>obtained and now enjoys it's own FCC identity.  This allows 
>company B to
>file permissive change applications with no involvement by 
>Company A.  This
>also used to be the case in the EU before the RTTE Directive.  
>However, is
>it still possible between company A, that used Annex V to declare
>compliance, and company B who wishes to assume that approval 
>even if company
>B does not have the quality system in place that is required 
>by Annex V,
>which the approval is declared to?  
>
>
>
>~
>Sam Wismer
>RF Approvals Engineer
>LXE, Inc.
>(770) 447-4224 Ext. 3654
>
>Visit Our Website at:
>http://www.lxe.com
>
>
>
>---
>This message is from the IEEE EMC Society Product Safety
>Technical Committee emc-pstc discussion list.
>
>To cancel your subscription, send mail to:
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>with the single line:
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>
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> Michael Garretson:pstc_ad...@garretson.org
>
>For policy questions, send mail to:
> Richard Nute:   ri...@ieee.org
>
>

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RE: RTTE and Germany

[WOODS]

I am not familiar with those standards. You can obtain English translations
of BAPT standards from BSI. 
The RegTP has issued a notice that the BAPT standards are being converted to
RegTP standards. Some have no changes and some are changed. See attached.

 <> 
Good luck.

Richard Woods

--
From:  Wismer, Sam [SMTP:wisme...@lxe.com]
Sent:  Thursday, June 01, 2000 2:05 PM
To:  wo...@sensormatic.com; emc-p...@ieee.org
Subject:  RE: RTTE and Germany

Richard,
Thanks for the input.

As we do with all our radios, we have taken strides prior to
approval to
ensure that our radio met all national deviations so that we could
sell a
single device throughout Europe.  We did however have to come up
with a
separate version to take care of Spain and France.

This is why this is somewhat of a surprise to me(Not really).  

So I guess my question is, what requirement does the BAPT 222 ZV 126
standard have that is not satisfied by ETS 300 328?  Or, is it
technically
equivalent, and they're just being stubborn, in which case all I
need to do
is add this standard to my DoC? 

I don't have a copy of the standard, so I am at a loss.



Sam Wismer
RF Approvals Engineer
LXE, Inc.
(770) 447-4224 Ext. 3654

Visit Our Website at:
http://www.lxe.com



-Original Message-
From: wo...@sensormatic.com [mailto:wo...@sensormatic.com]
Sent: Thursday, June 01, 2000 10:03 AM
To: emc-p...@ieee.org
        Subject: RE: RTTE and Germany



Sam, you may place RTTE compliant equipment on the market in any
member
state without any changes. However, the equipment may not be placed
in
service in a member state until and unless it complies with any
additional
spectrum, interference and health and safety (EMF) requirements that
a state
may impose according to Article 7(2). You have just discovered that
Germany
has imposed non-harmonized spectrum requirements. My equipment has
similar
problems in Germany, and my equipment cannot be used in Portugal
since the
frequency is allocated to other equipment. You can find a summary of
the
spectrum requirements of the CEPT members in CEPT Recommendation
70-03. The
document can be found at http://www.ero.dk/ <http://www.ero.dk/>
under
"documentation".

Richard Woods

--
From:  Wismer, Sam [SMTP:wisme...@lxe.com]
Sent:  Thursday, June 01, 2000 8:46 AM
To:  EMC Forum (E-mail)
Subject:  RTTE and Germany


Group,
As required by Article 6.4 of the R&TTE directive I made
notification to
Germany of our intent to place our product on their market.
I
received a
reply advising me that I must re-submit the notification
declaring
compliance to their national standard BAPT 222 ZV 126, in
additon to
the
essential requirements of the R&TTE Directive.  It is my
understanding that
requiring me to declare compliance to their national
standard, is in
violation of the of the Directive.  I have 2 questions:

1)  Is this in violation of the Directive?
2)  Is BAPT 222 ZV 126 technically equivalent to ETS 300 328
for
which I
used to declare compliance to the Directive? 



Sam Wismer
RF Approvals Engineer
LXE, Inc.
(770) 447-4224 Ext. 3654

Visit Our Website at:
http://www.lxe.com



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RE: RTTE and Germany

[Wismer, Sam]

Richard,
Thanks for the input.

As we do with all our radios, we have taken strides prior to approval to
ensure that our radio met all national deviations so that we could sell a
single device throughout Europe.  We did however have to come up with a
separate version to take care of Spain and France.

This is why this is somewhat of a surprise to me(Not really).  

So I guess my question is, what requirement does the BAPT 222 ZV 126
standard have that is not satisfied by ETS 300 328?  Or, is it technically
equivalent, and they're just being stubborn, in which case all I need to do
is add this standard to my DoC? 

I don't have a copy of the standard, so I am at a loss.



Sam Wismer
RF Approvals Engineer
LXE, Inc.
(770) 447-4224 Ext. 3654

Visit Our Website at:
http://www.lxe.com



-Original Message-
From: wo...@sensormatic.com [mailto:wo...@sensormatic.com]
Sent: Thursday, June 01, 2000 10:03 AM
To: emc-p...@ieee.org
Subject: RE: RTTE and Germany



Sam, you may place RTTE compliant equipment on the market in any member
state without any changes. However, the equipment may not be placed in
service in a member state until and unless it complies with any additional
spectrum, interference and health and safety (EMF) requirements that a state
may impose according to Article 7(2). You have just discovered that Germany
has imposed non-harmonized spectrum requirements. My equipment has similar
problems in Germany, and my equipment cannot be used in Portugal since the
frequency is allocated to other equipment. You can find a summary of the
spectrum requirements of the CEPT members in CEPT Recommendation 70-03. The
document can be found at http://www.ero.dk/ <http://www.ero.dk/>  under
"documentation".

Richard Woods

--
From:  Wismer, Sam [SMTP:wisme...@lxe.com]
Sent:  Thursday, June 01, 2000 8:46 AM
To:  EMC Forum (E-mail)
Subject:  RTTE and Germany


Group,
As required by Article 6.4 of the R&TTE directive I made
notification to
Germany of our intent to place our product on their market.  I
received a
reply advising me that I must re-submit the notification declaring
compliance to their national standard BAPT 222 ZV 126, in additon to
the
essential requirements of the R&TTE Directive.  It is my
understanding that
requiring me to declare compliance to their national standard, is in
violation of the of the Directive.  I have 2 questions:

1)  Is this in violation of the Directive?
2)  Is BAPT 222 ZV 126 technically equivalent to ETS 300 328 for
which I
used to declare compliance to the Directive? 



Sam Wismer
RF Approvals Engineer
LXE, Inc.
(770) 447-4224 Ext. 3654

Visit Our Website at:
http://www.lxe.com



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RE: RTTE and Germany

[WOODS]

Sam, you may place RTTE compliant equipment on the market in any member
state without any changes. However, the equipment may not be placed in
service in a member state until and unless it complies with any additional
spectrum, interference and health and safety (EMF) requirements that a state
may impose according to Article 7(2). You have just discovered that Germany
has imposed non-harmonized spectrum requirements. My equipment has similar
problems in Germany, and my equipment cannot be used in Portugal since the
frequency is allocated to other equipment. You can find a summary of the
spectrum requirements of the CEPT members in CEPT Recommendation 70-03. The
document can be found at http://www.ero.dk/   under
"documentation".

Richard Woods

--
From:  Wismer, Sam [SMTP:wisme...@lxe.com]
Sent:  Thursday, June 01, 2000 8:46 AM
To:  EMC Forum (E-mail)
Subject:  RTTE and Germany


Group,
As required by Article 6.4 of the R&TTE directive I made
notification to
Germany of our intent to place our product on their market.  I
received a
reply advising me that I must re-submit the notification declaring
compliance to their national standard BAPT 222 ZV 126, in additon to
the
essential requirements of the R&TTE Directive.  It is my
understanding that
requiring me to declare compliance to their national standard, is in
violation of the of the Directive.  I have 2 questions:

1)  Is this in violation of the Directive?
2)  Is BAPT 222 ZV 126 technically equivalent to ETS 300 328 for
which I
used to declare compliance to the Directive? 



Sam Wismer
RF Approvals Engineer
LXE, Inc.
(770) 447-4224 Ext. 3654

Visit Our Website at:
http://www.lxe.com



---
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 unsubscribe emc-pstc

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 Jim Bacher:  jim_bac...@mail.monarch.com
 Michael Garretson:pstc_ad...@garretson.org

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 Richard Nute:   ri...@ieee.org


---
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RE: RTTE

[Wismer, Sam]

Richard,
All are labeling is in English.  We did not use any country codes or symbols
to represent countries, however we did of course apply the alert symbol.   

Oh, on the notification front, I am getting conflicting information on the
necessity to notify for ISM equipment.  My notified body says I don't have
to, but if you ask the folks in the regulatory agencies of their respective
countries, most say that you do.  I'm inclined to believe them since they
can toss me out of there country(Not likely, but a good rule to live by).
Anyway, I choose to notify.  


Sam Wismer
RF Approvals Engineer
LXE, Inc.
(770) 447-4224 Ext. 3654

Visit Our Website at:
http://www.lxe.com



-Original Message-
From: wo...@sensormatic.com [mailto:wo...@sensormatic.com]
Sent: Monday, May 15, 2000 3:10 PM
To: emc-p...@majordomo.ieee.org
Subject: RE: RTTE



Sam, did you use English or symbols and country codes?

Richard Woods

--
From:  Wismer, Sam [SMTP:wisme...@lxe.com]
Sent:  Monday, May 15, 2000 3:03 PM
To:  wo...@sensormatic.com; emc-p...@majordomo.ieee.org
Subject:  RE: RTTE

Richard,
My product and packaging labeling does not list the countries
independently.
I simply stated on the labels that this equipment is intended to be
used in
the EU/EFTA except for Spain and France, since our equipment is ISM
that
uses the whole 2400-2483.5MHz band.  However, I clarified that in
more depth
in the users guide, where it is more practical to list the
countries.

For our Spain/France product(2450-2483.5MHz), we reversed the label
to say
that this equipment is intended to be used in Spain and France only.

This method did not come under criticism when our TCF was submitted
to a
notified body for a Statement of Opinion.
  

Sam Wismer
RF Approvals Engineer
LXE, Inc.
(770) 447-4224 Ext. 3654

Visit Our Website at:
http://www.lxe.com



-Original Message-
From: wo...@sensormatic.com [mailto:wo...@sensormatic.com]
Sent: Monday, May 15, 2000 12:07 PM
To: emc-p...@majordomo.ieee.org
Subject: RTTE



Packaging and user instructions of radio equipment must indicate the
Member
states where the equipment is intended to be used. It appears to be
sufficient to list the two letter ISO symbols for the 15 states. I
am
concerned that some non-EU states may also be adopting the RTTE and
rewording the requirement such they must also be listed. For
example, the
EFTA states adopt the EU Directives. Is anyone aware of any need to
list
other states in addition to the 15 EU states?

Richard Woods

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---
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 Richard Nute:   ri...@ieee.org

RE: RTTE

[WOODS]

Sam, did you use English or symbols and country codes?

Richard Woods

--
From:  Wismer, Sam [SMTP:wisme...@lxe.com]
Sent:  Monday, May 15, 2000 3:03 PM
To:  wo...@sensormatic.com; emc-p...@majordomo.ieee.org
Subject:  RE: RTTE

Richard,
My product and packaging labeling does not list the countries
independently.
I simply stated on the labels that this equipment is intended to be
used in
the EU/EFTA except for Spain and France, since our equipment is ISM
that
uses the whole 2400-2483.5MHz band.  However, I clarified that in
more depth
in the users guide, where it is more practical to list the
countries.

For our Spain/France product(2450-2483.5MHz), we reversed the label
to say
that this equipment is intended to be used in Spain and France only.

This method did not come under criticism when our TCF was submitted
to a
notified body for a Statement of Opinion.
  

Sam Wismer
RF Approvals Engineer
LXE, Inc.
(770) 447-4224 Ext. 3654

Visit Our Website at:
http://www.lxe.com



-Original Message-
From: wo...@sensormatic.com [mailto:wo...@sensormatic.com]
Sent: Monday, May 15, 2000 12:07 PM
To: emc-p...@majordomo.ieee.org
Subject: RTTE



Packaging and user instructions of radio equipment must indicate the
Member
states where the equipment is intended to be used. It appears to be
sufficient to list the two letter ISO symbols for the 15 states. I
am
concerned that some non-EU states may also be adopting the RTTE and
rewording the requirement such they must also be listed. For
example, the
EFTA states adopt the EU Directives. Is anyone aware of any need to
list
other states in addition to the 15 EU states?

Richard Woods

---
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 Michael Garretson:pstc_ad...@garretson.org

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 Richard Nute:   ri...@ieee.org

---
This message is from the IEEE EMC Society Product Safety
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 unsubscribe emc-pstc

For help, send mail to the list administrators:
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 Michael Garretson:pstc_ad...@garretson.org

For policy questions, send mail to:
 Richard Nute:   ri...@ieee.org

RE: RTTE

[Wismer, Sam]

Richard,
My product and packaging labeling does not list the countries independently.
I simply stated on the labels that this equipment is intended to be used in
the EU/EFTA except for Spain and France, since our equipment is ISM that
uses the whole 2400-2483.5MHz band.  However, I clarified that in more depth
in the users guide, where it is more practical to list the countries.

For our Spain/France product(2450-2483.5MHz), we reversed the label to say
that this equipment is intended to be used in Spain and France only.

This method did not come under criticism when our TCF was submitted to a
notified body for a Statement of Opinion.
  

Sam Wismer
RF Approvals Engineer
LXE, Inc.
(770) 447-4224 Ext. 3654

Visit Our Website at:
http://www.lxe.com



-Original Message-
From: wo...@sensormatic.com [mailto:wo...@sensormatic.com]
Sent: Monday, May 15, 2000 12:07 PM
To: emc-p...@majordomo.ieee.org
Subject: RTTE



Packaging and user instructions of radio equipment must indicate the Member
states where the equipment is intended to be used. It appears to be
sufficient to list the two letter ISO symbols for the 15 states. I am
concerned that some non-EU states may also be adopting the RTTE and
rewording the requirement such they must also be listed. For example, the
EFTA states adopt the EU Directives. Is anyone aware of any need to list
other states in addition to the 15 EU states?

Richard Woods

---
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 Michael Garretson:pstc_ad...@garretson.org

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 Richard Nute:   ri...@ieee.org


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