subject:"RTTE"

In message 
ca+nn315eg5krv5rgtjbmfqbhkancteqsbuwjkhobpopurog...@mail.gmail.com, 
dated Mon, 20 Jul 2015, Dave Heald emcp...@gmail.com writes:


Even though the EN 301 489-1 standard's Normative References list 
specific dates (and according to the standard, *only* those versions of 
the standard should be used), is it OK to use the most recent versions 
of the Reference standards to claim compliance?  


If a reference is dated, that edition must be used. If it is not dated, 
the latest edition must be used.

--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk
When I turn my back on the sun, it's to look for a rainbow
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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Re: [PSES] RTTE OJ listing vs conflicting Reference Standards in EN 301 489-1 v1.9.2

2015-07-20 Thread Dave Heald

Hi John,
  I agree, and this has been my stance with the lab and with our ODM who
contracted the lab  had the testing done.

Also, the problem doesn't stop with the 55022 reference - for *EVERY* dated
( thus specific) basic EMC standard that has a newer version, the newer
standard was used.  For a few, the test method has changed, and this is the
sticking point - the lab wants us to pay for any delta testing to the old
standards that they technically should have used in the first place.

If it is generally acceptable or good enough to use the newer standards,
I don't want to stand in the way of product release while we get the
testing re-done (we know what happens to employees that take stands on
technicalities that aren't important in the grand scheme of things  it's
not good)
However, I also don't want to give in without some input from other experts
on how important this is to compliance assessment.

Thanks,
-David

On Mon, Jul 20, 2015 at 12:18 PM, John Woodgate j...@jmwa.demon.co.uk
wrote:

 In message 
 ca+nn315eg5krv5rgtjbmfqbhkancteqsbuwjkhobpopurog...@mail.gmail.com,
 dated Mon, 20 Jul 2015, Dave Heald emcp...@gmail.com writes:

  Even though the EN 301 489-1 standard's Normative References list
 specific dates (and according to the standard, *only* those versions of the
 standard should be used), is it OK to use the most recent versions of the
 Reference standards to claim compliance?


 If a reference is dated, that edition must be used. If it is not dated,
 the latest edition must be used.
 --
 OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk
 When I turn my back on the sun, it's to look for a rainbow
 John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK


 -
 
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[PSES] RTTE OJ listing vs conflicting Reference Standards in EN 301 489-1 v1.9.2

2015-07-20 Thread Dave Heald

I have a technical question on the OJ vs References in standards.

Here is the conflict:  EN 301 489 -1 V1.9.2 is the current standard in
the RTTE OJ.

However, 301 489-1 V 1.9.2, it lists several specific standards in it's
Normative References chapter... and one of these standards (EN 55022: 2006
+ A1 (2007) expired in the RTTE OJ in 2013.

Even though the EN 301 489-1 standard's Normative References list specific
dates (and according to the standard, *only* those versions of the standard
should be used), is it OK to use the most recent versions of the Reference
standards to claim compliance?


Any advice on this?


Thanks  Best Regards,
-David Heald

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Re: [PSES] RTTE OJ listing vs conflicting Reference Standards in EN 301 489-1 v1.9.2

2015-07-20 Thread Nyffenegger, Dave

At the risk of going off topic,  I don't see anything identified at 
http://eur-lex.europa.eu/homepage.html  for harmonized standards for the new 
2014/30/EU EMC and 2014/35/EU LVD directives that go into force April 2016.  
Time to start getting prepared.  Am I missing something or is it just too soon 
for them to be published?  

The same line of thinking could apply as to whether or not to start using newer 
standards sooner than later.  A benefit would be not having to go through the 
cost of additional testing to a newer standard only months later.

-Dave

-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk] 
Sent: Monday, July 20, 2015 5:15 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] RTTE OJ listing vs conflicting Reference Standards in EN 
301 489-1 v1.9.2

In message 85d45e15f71741059f90847883213...@thhste15d1be4.hs20.net,
dated Mon, 20 Jul 2015, Charlie Blackham char...@sulisconsultants.com
writes:

The discussion concluded that whilst final responsibility would always 
rest with the manufacturer (and Notified Body if used), that using the 
latest state of the art standard would be perfectly acceptable or 
perhaps even the better decision.

 
The committee that wrote the referencing standard decided to use dated 
references, and that was voted on and accepted. So how can it be a 'better 
decision' to ignore that?

While the advantages of dated and undated references are pretty evenly 
balanced, the main point in favour of dating is that the user ***is in no doubt 
which edition of the reference standard to apply***. Teaching people to 
disregard that seems extremely perverse.
--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk When I turn 
my back on the sun, it's to look for a rainbow John Woodgate, J M Woodgate and 
Associates, Rayleigh, Essex UK

-

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Attachments are not permitted but the IEEE PSES Online Communities site at 
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Re: [PSES] RTTE OJ listing vs conflicting Reference Standards in EN 301 489-1 v1.9.2

In message 85d45e15f71741059f90847883213...@thhste15d1be4.hs20.net, 
dated Mon, 20 Jul 2015, Charlie Blackham char...@sulisconsultants.com 
writes:


The discussion concluded that whilst final responsibility would always 
rest with the manufacturer (and Notified Body if used), that using the 
latest state of the art standard would be perfectly acceptable or 
perhaps even the better decision.


 
The committee that wrote the referencing standard decided to use dated 
references, and that was voted on and accepted. So how can it be a 
'better decision' to ignore that?


While the advantages of dated and undated references are pretty evenly 
balanced, the main point in favour of dating is that the user ***is in 
no doubt which edition of the reference standard to apply***. Teaching 
people to disregard that seems extremely perverse.

--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk
When I turn my back on the sun, it's to look for a rainbow
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

-

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list. To post a message to the list, send your e-mail to emc-p...@ieee.org

All emc-pstc postings are archived and searchable on the web at:
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Attachments are not permitted but the IEEE PSES Online Communities site at 
http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used 
formats), large files, etc.

Website:  http://www.ieee-pses.org/
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Re: [PSES] RTTE OJ listing vs conflicting Reference Standards in EN 301 489-1 v1.9.2

2015-07-20 Thread Charlie Blackham

David

I’ll offer a slightly different angle.

Newer standards, whilst not referenced in the product standard, do represent 
“state of the art”.

There was a discussion recently in the RTTE compliance association related to 
the fact that several product type EN 301 489-X standards referenced EN 301 
489-1 version 1.8.1 or even 1.4.1.
The discussion concluded that whilst final responsibility would always rest 
with the manufacturer (and Notified Body if used), that using the latest state 
of the art standard would be perfectly acceptable or perhaps even the better 
decision.

I’m not suggesting that the lab did the correct thing, but the choice of basic 
EMC standard is only a part of demonstrating EMC compliance and a smaller part 
of the whole CE marking compliance jigsaw and if that was the only area that 
wasn’t perfect, then you would be in a pretty good place ☺

Regards
Charlie


From: Dave Heald [mailto:emcp...@gmail.com]
Sent: 20 July 2015 19:52
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] RTTE OJ listing vs conflicting Reference Standards in EN 
301 489-1 v1.9.2

Hi John,
  I agree, and this has been my stance with the lab and with our ODM who 
contracted the lab  had the testing done.

Also, the problem doesn't stop with the 55022 reference - for *EVERY* dated ( 
thus specific) basic EMC standard that has a newer version, the newer 
standard was used.  For a few, the test method has changed, and this is the 
sticking point - the lab wants us to pay for any delta testing to the old 
standards that they technically should have used in the first place.

If it is generally acceptable or good enough to use the newer standards, I 
don't want to stand in the way of product release while we get the testing 
re-done (we know what happens to employees that take stands on technicalities 
that aren't important in the grand scheme of things  it's not good)
However, I also don't want to give in without some input from other experts on 
how important this is to compliance assessment.

Thanks,
-David

On Mon, Jul 20, 2015 at 12:18 PM, John Woodgate 
j...@jmwa.demon.co.ukmailto:j...@jmwa.demon.co.uk wrote:
In message 
ca+nn315eg5krv5rgtjbmfqbhkancteqsbuwjkhobpopurog...@mail.gmail.commailto:ca%2bnn315eg5krv5rgtjbmfqbhkancteqsbuwjkhobpopurog...@mail.gmail.com,
 dated Mon, 20 Jul 2015, Dave Heald 
emcp...@gmail.commailto:emcp...@gmail.com writes:
Even though the EN 301 489-1 standard's Normative References list specific 
dates (and according to the standard, *only* those versions of the standard 
should be used), is it OK to use the most recent versions of the Reference 
standards to claim compliance?

If a reference is dated, that edition must be used. If it is not dated, the 
latest edition must be used.
--
OOO - Own Opinions Only. With best wishes. See 
www.jmwa.demon.co.ukhttp://www.jmwa.demon.co.uk
When I turn my back on the sun, it's to look for a rainbow
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK


-

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discussion list. To post a message to the list, send your e-mail to 
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All emc-pstc postings are archived and searchable on the web at:
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Attachments are not permitted but the IEEE PSES Online Communities site at 
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formats), large files, etc.

Website:  http://www.ieee-pses.org/
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For policy questions, send mail to:
Jim Bacher:  j.bac...@ieee.orgmailto:j.bac...@ieee.org
David Heald: dhe...@gmail.commailto:dhe...@gmail.com

-


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All emc-pstc postings are archived and searchable on the web at: 
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Attachments are not permitted but the IEEE PSES Online Communities site at 
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Re: [PSES] RTTE OJ listing vs conflicting Reference Standards in EN 301 489-1 v1.9.2

In message 
ca+nn3167r18+1zbr3kfqw2rq9b_fd58zm-cqh83x4td8sjz...@mail.gmail.com, 
dated Mon, 20 Jul 2015, Dave Heald emcp...@gmail.com writes:


If it is generally acceptable or good enough to use the newer 
standards, I don't want to stand in the way of product release while we 
get the testing re-done (we know what happens to employees that take 
stands on technicalities that aren't important in the grand scheme of 
things  it's not good)
However, I also don't want to give in without some input from other 
experts on how important this is to compliance assessment.


It's impossible to generalize; there are three cases:

1. The new edition is *exactly* the same as the earlier one for every 
cross-reference in the referencing standard;


2. The new edition is *exactly* the same for some cross-references, but 
not others;


3. The new edition is a complete re-write, so that the cross-references 
in the referencing standard are meaningless.


Case 1. is the only one that doesn't spell trouble. *exactly* means 
word-for-word and includes any Notes or examples.

--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk
When I turn my back on the sun, it's to look for a rainbow
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

-

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list. To post a message to the list, send your e-mail to emc-p...@ieee.org

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Re: [PSES] RTTE OJ listing vs conflicting Reference Standards in EN 301 489-1 v1.9.2

2015-07-20 Thread Nyffenegger, Dave

Thanks for reminding me.  I remember now, the published OJ harmonized standards 
lists will have the in force date listed for each standard.
Thanks
-Dave

-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk] 
Sent: Monday, July 20, 2015 9:02 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] RTTE OJ listing vs conflicting Reference Standards in EN 
301 489-1 v1.9.2

In message
bn3pr0801mb09797f0e4351fc2be25f6e0985...@bn3pr0801mb0979.namprd08.prod.o
utlook.com, dated Mon, 20 Jul 2015, Nyffenegger, Dave 
dave.nyffeneg...@bhemail.com writes:

At the risk of going off topic,  I don't see anything identified at 
http://eur-lex.europa.eu/homepage.html  for harmonized standards for 
the new 2014/30/EU EMC and 2014/35/EU LVD directives that go into force 
April 2016.  Time to start getting prepared.  Am I missing something or 
is it just too soon for them to be published?

You are not missing anything. The reason you haven't seen anything yet is 
complicated and largely irrelevant. The lists will not change significantly due 
to the changes of Directive alone.

The same line of thinking could apply as to whether or not to start 
using newer standards sooner than later.  A benefit would be not having 
to go through the cost of additional testing to a newer standard only 
months later.

You almost never *have* to re-test to a new standard only months later; there 
is a transition period which is normally 36 months. You can
*choose* to apply a new edition of a standard as soon as it is notified in the 
Official Journal, but you don't have to.
--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk When I turn 
my back on the sun, it's to look for a rainbow John Woodgate, J M Woodgate and 
Associates, Rayleigh, Essex UK

-

This message is from the IEEE Product Safety Engineering Society emc-pstc 
discussion list. To post a message to the list, send your e-mail to 
emc-p...@ieee.org

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Attachments are not permitted but the IEEE PSES Online Communities site at 
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formats), large files, etc.

Website:  http://www.ieee-pses.org/
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Jim Bacher:  j.bac...@ieee.org
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Attachments are not permitted but the IEEE PSES Online Communities site at 
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Re: [PSES] RTTE OJ listing vs conflicting Reference Standards in EN 301 489-1 v1.9.2

2014-11-20 Thread ce-test, qualified testing bv - Gert Gremmen

In message 
bn3pr0801mb09797f0e4351fc2be25f6e0985...@bn3pr0801mb0979.namprd08.prod.o
utlook.com, dated Mon, 20 Jul 2015, Nyffenegger, Dave 
dave.nyffeneg...@bhemail.com writes:


At the risk of going off topic,  I don't see anything identified at 
http://eur-lex.europa.eu/homepage.html  for harmonized standards for 
the new 2014/30/EU EMC and 2014/35/EU LVD directives that go into force 
April 2016.  Time to start getting prepared.  Am I missing something or 
is it just too soon for them to be published?


You are not missing anything. The reason you haven't seen anything yet 
is complicated and largely irrelevant. The lists will not change 
significantly due to the changes of Directive alone.


The same line of thinking could apply as to whether or not to start 
using newer standards sooner than later.  A benefit would be not having 
to go through the cost of additional testing to a newer standard only 
months later.


You almost never *have* to re-test to a new standard only months later; 
there is a transition period which is normally 36 months. You can 
*choose* to apply a new edition of a standard as soon as it is notified 
in the Official Journal, but you don't have to.

--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk
When I turn my back on the sun, it's to look for a rainbow
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

-

This message is from the IEEE Product Safety Engineering Society emc-pstc discussion 
list. To post a message to the list, send your e-mail to emc-p...@ieee.org

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Attachments are not permitted but the IEEE PSES Online Communities site at 
http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used 
formats), large files, etc.

Website:  http://www.ieee-pses.org/
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List rules: http://www.ieee-pses.org/listrules.html

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Mike Cantwell mcantw...@ieee.org

For policy questions, send mail to:
Jim Bacher:  j.bac...@ieee.org
David Heald: dhe...@gmail.com

[PSES] Looking for Notified Body for RTTE

2015-05-26 Thread S Drysdale

Hi All,

I am looking for recommendations for a Notified Body to contact for a radio
transmitting device that does not appear to have a harmonized standard.
The frequency range on the device is 9300 to 9500, and the closest standard
I can find on the OJ appears to be EN 303 213-6-1.However the device is a
frequency swept radar not a pulsed radar, as specified in that standard.
The device is well above the 25 mW specified in Annex 6 B of ERC
recommendation 70-03 and is used for long range radar applications.

I am looking for a private response(s) with recommendations of a NB to
contact who is particularly helpful towards RTTE directive Annex III, IV,
and/or V would be appreciated.

Best Regards,
Scott Drysdale
OOO - Own opinions only
http://ca.linkedin.com/in/scottdrysdale

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[PSES] New list with Harmonised Standards for RTTE Directive 1999/5/EC and Low Voltage Directive 2006/95/EC

2015-04-18 Thread Helge Knudsen

Hello all,

 

On 17. April New list with Harmonised Standards for RTTE Directive
1999/5/EC and Low Voltage Directive 2006/95/EC were brought In OJ.

 

RTTE:

http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=OJ:JOC_2015_125_R_000
1
http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=OJ:JOC_2015_125_R_00
01from=EN from=EN

 

LVD:

Engelsk

http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=OJ:JOC_2015_125_R_000
2
http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=OJ:JOC_2015_125_R_00
02from=EN from=EN

 

 

 

Best regards

 

Helge Knudsen

Denmark


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Re: [PSES] TTE Equipment and RTTE Directive

2014-11-25 Thread Carl Newton


Thanks very much to all of you for your replies.

Carl

On Mon, 24 Nov 2014 03:18:01 -0500, Allen, Chris chris.d.al...@hp.com  
wrote:



The TS 103-021 series has been replaced by ES 203-021 series.

If you obtain an ES 203-021 test report it can be used in some countries  
outside the EU instead of carrying out local testing.


Thanks,
Chris.

-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk]
Sent: 21 November 2014 21:54
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] TTE Equipment and RTTE Directive

In message 006601d005d1$a9aaef40$fd00cdc0$@randolph-telecom.com, dated  
Fri, 21 Nov 2014, Joe Randolph j...@randolph-telecom.com writes:



While compliance with these standards is not a regulatory requirement,
some manufacturers (and their customers) feel more comfortable knowing
that a product meets these requirements.  In my judgment, the
requirements in the TS-103 021 series are pretty reasonable, especially
compared to the some of the per-country national requirements that were
mandatory prior to the implementation of the TTE directive in 2000.

So, it might be appropriate to at least review the requirements in the
TS 103 021 series and satisfy yourself that your product complies with
those requirements.  However, that would be a purely voluntary activity
because there is no regulatory requirement to meet those requirements.

If your product is a listen-only device that only looks for ringing,
only a small subset of the requirements in the TS 103 021 series would
be relevant, such as the impedance presented to ring signals and the
applicable thresholds for ring detection.  I think you will find the
requirements to be easy to meet.


I think this is very good advice.
--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk When  
I turn my back on the sun, it's to look for a rainbow John Woodgate, J M  
Woodgate and Associates, Rayleigh, Essex UK


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Re: [PSES] TTE Equipment and RTTE Directive

2014-11-24 Thread Allen, Chris

The TS 103-021 series has been replaced by ES 203-021 series. 

If you obtain an ES 203-021 test report it can be used in some countries 
outside the EU instead of carrying out local testing.

Thanks,
Chris.

-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk] 
Sent: 21 November 2014 21:54
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] TTE Equipment and RTTE Directive

In message 006601d005d1$a9aaef40$fd00cdc0$@randolph-telecom.com, dated Fri, 
21 Nov 2014, Joe Randolph j...@randolph-telecom.com writes:

While compliance with these standards is not a regulatory requirement, 
some manufacturers (and their customers) feel more comfortable knowing 
that a product meets these requirements.  In my judgment, the 
requirements in the TS-103 021 series are pretty reasonable, especially 
compared to the some of the per-country national requirements that were 
mandatory prior to the implementation of the TTE directive in 2000.

So, it might be appropriate to at least review the requirements in the 
TS 103 021 series and satisfy yourself that your product complies with 
those requirements.  However, that would be a purely voluntary activity 
because there is no regulatory requirement to meet those requirements.

If your product is a listen-only device that only looks for ringing, 
only a small subset of the requirements in the TS 103 021 series would 
be relevant, such as the impedance presented to ring signals and the 
applicable thresholds for ring detection.  I think you will find the 
requirements to be easy to meet.

I think this is very good advice.
--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk When I turn 
my back on the sun, it's to look for a rainbow John Woodgate, J M Woodgate and 
Associates, Rayleigh, Essex UK

-

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Re: [PSES] TTE Equipment and RTTE Directive

2014-11-21 Thread Joe Randolph

Hi Carl:

As Larry noted, for the EU, land line telecom terminals are only required to
meet the applicable requirements for safety and EMC.  For CE marking, there
are no *regulatory* requirements for compatibility with the land line
telecom network.  This has been the case ever since the TTE directive came
into effect in 2000.

In the late 1990s, TBR 21 was ETSI's attempt to come up with a harmonized EU
standard for equipment that interfaces to the analog land line telephone
network.  The intention was to use TBR 21 as the basis for a harmonized
regulatory standard called CTR 21, which would have applied under an earlier
regulatory scheme that was replaced by the TTE directive.

Since the TTE directive eliminated any regulatory requirements on the
parameters covered by TBR -21, some manufacturers were uneasy having no
official guidance on compatibility with the analog land-line phone network.
For this reason, ETSI continued to update and evolve TBR 21 for many years
as an advisory standard that was purely voluntary.  I think the current
version is a set of documents called TS 103 021-1, TS 103 021-2, and TS 103
021-3.

While compliance with these standards is not a regulatory requirement, some
manufacturers (and their customers) feel more comfortable knowing that a
product meets these requirements.  In my judgment, the requirements in the
TS-103 021 series are pretty reasonable, especially compared to the some of
the per-country national requirements that were mandatory prior to the
implementation of the TTE directive in 2000.

So, it might be appropriate to at least review the requirements in the TS
103 021 series and satisfy yourself that your product complies with those
requirements.  However, that would be a purely voluntary activity because
there is no regulatory requirement to meet those requirements.

If your product is a listen-only device that only looks for ringing, only a
small subset of the requirements in the TS 103 021 series would be relevant,
such as the impedance presented to ring signals and the applicable
thresholds for ring detection.  I think you will find the requirements to be
easy to meet.


Joe Randolph
Telecom Design Consultant
Randolph Telecom, Inc.
781-721-2848 (USA)
j...@randolph-telecom.com
http://www.randolph-telecom.com



-Original Message-
From: Larry K. Stillings [mailto:la...@complianceworldwide.com] 
Sent: Wednesday, November 19, 2014 3:27 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] TTE Equipment and RTTE Directive

Hi Carl,

What you have surmised is correct. You are not required to meet any line
standards is order to comply with the directives. 

The DoCs you are seeing, is the voluntary testing to ETSI standards to show
that the line interface device is compatible with the phone network. I asked
several times a joint NIST - EU meetings (in the
2000's) about the implementation of TTE standards under the RTTE directive
and always got the same response. There are no formal complaints and
therefore no implementation of mandatory standards will occur. Also, the
other reason the directive is going to become the Radio Equipment Directive
(RED), as that is all it has ever really covered.

Of course being a test lab whom does those tests, we can only make a mild
suggestion you should test, as to this day we still have product showing up
that don't comply with the ETSI TBR and or ES 203 021-x standards, but that
is always a financial / business decision on what the risk is of performing
no testing.


Larry K. Stillings
Compliance Worldwide, Inc. 
Test Locally, Sell Globally and Launch Your Products Around the World! 
FCC - Wireless - Telecom - CE Marking - International Approvals - Product
Safety
357 Main Street
Sandown, NH 03873
(603) 887 3903 Fax 887-6445
www.complianceworldwide.com

Privileged/Confidential Information may be contained in this message. If you
are not the addressee indicated in this message (or responsible for delivery
of the message to such person), you may not copy or deliver this message to
anyone. In such case, you should destroy this message and kindly notify the
sender by reply email. Please advise immediately if you or your employer do
not consent to Internet email for messages of this kind. Opinions,
conclusions and other information in this message that do not relate to the
official business of my firm shall be understood as neither given nor
endorsed by it.


-Original Message-
From: Carl Newton [mailto:emcl...@gmail.com]
Sent: Wednesday, November 19, 2014 3:10 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] TTE Equipment and RTTE Directive

Dear List Members,

I haven't worked with land-line telecom hardware for many years.  I have a
device intended for use by handicapped persons that will enable a visual
alarm if the land-line phone is ringing, so the device is listen-only.

I've found what appears to be good and reliable guidance concerning TTE
equipment at this link which indicates that TTE equipment need only comply

Re: [PSES] TTE Equipment and RTTE Directive

2014-11-21 Thread John Woodgate

In message 006601d005d1$a9aaef40$fd00cdc0$@randolph-telecom.com, dated 
Fri, 21 Nov 2014, Joe Randolph j...@randolph-telecom.com writes:


While compliance with these standards is not a regulatory requirement, 
some manufacturers (and their customers) feel more comfortable knowing 
that a product meets these requirements.  In my judgment, the 
requirements in the TS-103 021 series are pretty reasonable, especially 
compared to the some of the per-country national requirements that were 
mandatory prior to the implementation of the TTE directive in 2000.


So, it might be appropriate to at least review the requirements in the 
TS 103 021 series and satisfy yourself that your product complies with 
those requirements.  However, that would be a purely voluntary activity 
because there is no regulatory requirement to meet those requirements.


If your product is a listen-only device that only looks for ringing, 
only a small subset of the requirements in the TS 103 021 series would 
be relevant, such as the impedance presented to ring signals and the 
applicable thresholds for ring detection.  I think you will find the 
requirements to be easy to meet.


I think this is very good advice.
--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk
When I turn my back on the sun, it's to look for a rainbow
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

-

This message is from the IEEE Product Safety Engineering Society emc-pstc discussion 
list. To post a message to the list, send your e-mail to emc-p...@ieee.org

All emc-pstc postings are archived and searchable on the web at:
http://www.ieee-pses.org/emc-pstc.html

Attachments are not permitted but the IEEE PSES Online Communities site at 
http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used 
formats), large files, etc.

Website:  http://www.ieee-pses.org/
Instructions:  http://www.ieee-pses.org/list.html (including how to unsubscribe)
List rules: http://www.ieee-pses.org/listrules.html

For help, send mail to the list administrators:
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Mike Cantwell mcantw...@ieee.org

For policy questions, send mail to:
Jim Bacher:  j.bac...@ieee.org
David Heald: dhe...@gmail.com

Re: [PSES] TTE Equipment and RTTE Directive

These standards do exist for  a good reason, they guarantee
interoperability
with PSTN networks all over the world. So the good news is that testing
is not mandatory,
the bad news is that by skipping them your product may fail in certain
places or even full networks.
As the standards are free, I suggest that at least you  read them and
even better 
implement the tests in your own development lab

Note that for a long time the telecom operators had internal test
protocols exceeding TBR21
(we tested their equipment for some time) , to allow their equipment
stand out from 
the competition on the market.

The standards mentioned provide for minimum requirements only.

Gert
Ce-test qualified testing bv

-Original Message-
From: Carl Newton [mailto:emcl...@gmail.com] 
Sent: Wednesday, November 19, 2014 9:33 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] TTE Equipment and RTTE Directive

Excellent response Larry.  When something sounds too good to be true it
usually is.  But not in this case.

Thanks very much,

Carl



On Wed, 19 Nov 2014 15:26:53 -0500, Larry K. Stillings
la...@complianceworldwide.com wrote:

 Hi Carl,

 What you have surmised is correct. You are not required to meet any 
 line standards is order to comply with the directives.

 The DoCs you are seeing, is the voluntary testing to ETSI standards to

 show that the line interface device is compatible with the phone 
 network. I asked several times a joint NIST - EU meetings (in the
 2000's) about the implementation of TTE standards under the RTTE 
 directive and always got the same response. There are no formal 
 complaints and therefore no implementation of mandatory standards will

 occur. Also, the other reason the directive is going to become the 
 Radio Equipment Directive (RED), as that is all it has ever really
covered.

 Of course being a test lab whom does those tests, we can only make a 
 mild suggestion you should test, as to this day we still have product 
 showing up that don't comply with the ETSI TBR and or ES 203 021-x 
 standards, but that is always a financial / business decision on what 
 the risk is of performing no testing.


 Larry K. Stillings
 Compliance Worldwide, Inc.
 Test Locally, Sell Globally and Launch Your Products Around the World!
 FCC - Wireless - Telecom - CE Marking - International Approvals - 
 Product Safety
 357 Main Street
 Sandown, NH 03873
 (603) 887 3903 Fax 887-6445
 www.complianceworldwide.com

 Privileged/Confidential Information may be contained in this message. 
 If you are not the addressee indicated in this message (or responsible

 for delivery of the message to such person), you may not copy or 
 deliver this message to anyone. In such case, you should destroy this 
 message and kindly notify the sender by reply email. Please advise 
 immediately if you or your employer do not consent to Internet email 
 for messages of this kind. Opinions, conclusions and other information

 in this message that do not relate to the official business of my firm

 shall be understood as neither given nor endorsed by it.


 -Original Message-
 From: Carl Newton [mailto:emcl...@gmail.com]
 Sent: Wednesday, November 19, 2014 3:10 PM
 To: EMC-PSTC@LISTSERV.IEEE.ORG
 Subject: [PSES] TTE Equipment and RTTE Directive

 Dear List Members,

 I haven't worked with land-line telecom hardware for many years.  I 
 have a device intended for use by handicapped persons that will enable

 a visual alarm if the land-line phone is ringing, so the device is 
 listen-only.

 I've found what appears to be good and reliable guidance concerning 
 TTE equipment at this link which indicates that TTE equipment need 
 only comply with the EMCD and LVD:

 http://ec.europa.eu/enterprise/sectors/rtte/regulatory-framework/index
 _e
 n.htm

 However, I'm seeing DoCs and product specs for current TTE equipment 
 that reference the ETSI 201 703 and TBR series of standards, and 
 those standards are not listed under the RTTED, EMCD, or LVD on the 
 Europa Harmonized Standards pages.

 Can someone shed some light on this confusing issue?  Is TTE really 
 not required to meet a line connection standard of some type as the 
 Europa link above indicates?

 Thanks very much,

 Carl

 --

 -
 
 This message is from the IEEE Product Safety Engineering Society 
 emc-pstc discussion list. To post a message to the list, send your 
 e-mail to emc-p...@ieee.org

 All emc-pstc postings are archived and searchable on the web at:
 http://www.ieee-pses.org/emc-pstc.html

 Attachments are not permitted but the IEEE PSES Online Communities 
 site at http://product-compliance.oc.ieee.org/ can be used for 
 graphics (in well-used formats), large files, etc.

 Website:  http://www.ieee-pses.org/
 Instructions:  http://www.ieee-pses.org/list.html (including how to
 unsubscribe) List rules: http://www.ieee-pses.org/listrules.html

 For help, send mail to the list

Re: [PSES] TTE Equipment and RTTE Directive

2014-11-20 Thread Carl Newton


Thank you for your insight Gert.

Carl

On Thu, 20 Nov 2014 05:32:32 -0500, ce-test, qualified testing bv - Gert  
Gremmen g.grem...@cetest.nl wrote:



These standards do exist for  a good reason, they guarantee
interoperability
with PSTN networks all over the world. So the good news is that testing
is not mandatory,
the bad news is that by skipping them your product may fail in certain
places or even full networks.
As the standards are free, I suggest that at least you  read them and
even better
implement the tests in your own development lab

Note that for a long time the telecom operators had internal test
protocols exceeding TBR21
(we tested their equipment for some time) , to allow their equipment
stand out from
the competition on the market.

The standards mentioned provide for minimum requirements only.

Gert
Ce-test qualified testing bv

-Original Message-
From: Carl Newton [mailto:emcl...@gmail.com]
Sent: Wednesday, November 19, 2014 9:33 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] TTE Equipment and RTTE Directive

Excellent response Larry.  When something sounds too good to be true it
usually is.  But not in this case.

Thanks very much,

Carl



On Wed, 19 Nov 2014 15:26:53 -0500, Larry K. Stillings
la...@complianceworldwide.com wrote:


Hi Carl,

What you have surmised is correct. You are not required to meet any
line standards is order to comply with the directives.

The DoCs you are seeing, is the voluntary testing to ETSI standards to



show that the line interface device is compatible with the phone
network. I asked several times a joint NIST - EU meetings (in the
2000's) about the implementation of TTE standards under the RTTE
directive and always got the same response. There are no formal
complaints and therefore no implementation of mandatory standards will



occur. Also, the other reason the directive is going to become the
Radio Equipment Directive (RED), as that is all it has ever really

covered.


Of course being a test lab whom does those tests, we can only make a
mild suggestion you should test, as to this day we still have product
showing up that don't comply with the ETSI TBR and or ES 203 021-x
standards, but that is always a financial / business decision on what
the risk is of performing no testing.


Larry K. Stillings
Compliance Worldwide, Inc.
Test Locally, Sell Globally and Launch Your Products Around the World!
FCC - Wireless - Telecom - CE Marking - International Approvals -
Product Safety
357 Main Street
Sandown, NH 03873
(603) 887 3903 Fax 887-6445
www.complianceworldwide.com

Privileged/Confidential Information may be contained in this message.
If you are not the addressee indicated in this message (or responsible



for delivery of the message to such person), you may not copy or
deliver this message to anyone. In such case, you should destroy this
message and kindly notify the sender by reply email. Please advise
immediately if you or your employer do not consent to Internet email
for messages of this kind. Opinions, conclusions and other information



in this message that do not relate to the official business of my firm



shall be understood as neither given nor endorsed by it.


-Original Message-
From: Carl Newton [mailto:emcl...@gmail.com]
Sent: Wednesday, November 19, 2014 3:10 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] TTE Equipment and RTTE Directive

Dear List Members,

I haven't worked with land-line telecom hardware for many years.  I
have a device intended for use by handicapped persons that will enable



a visual alarm if the land-line phone is ringing, so the device is
listen-only.

I've found what appears to be good and reliable guidance concerning
TTE equipment at this link which indicates that TTE equipment need
only comply with the EMCD and LVD:

http://ec.europa.eu/enterprise/sectors/rtte/regulatory-framework/index
_e
n.htm

However, I'm seeing DoCs and product specs for current TTE equipment
that reference the ETSI 201 703 and TBR series of standards, and
those standards are not listed under the RTTED, EMCD, or LVD on the
Europa Harmonized Standards pages.

Can someone shed some light on this confusing issue?  Is TTE really
not required to meet a line connection standard of some type as the
Europa link above indicates?

Thanks very much,

Carl

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Re: [PSES] TTE Equipment and RTTE Directive

2014-11-20 Thread John Woodgate

In message FCA549BE3ECF9D4CB8CB8576837EA48920AB07@ZEUS.cetest.local, 
dated Thu, 20 Nov 2014, ce-test, qualified testing bv - Gert Gremmen 
g.grem...@cetest.nl writes:


Note that for a long time the telecom operators had internal test 
protocols exceeding TBR21


At least one claimed to do tests that later proved impossible, because 
the operator didn't have, and could not obtain, some of the essential 
parts of the test equipment.

--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk
When I turn my back on the sun, it's to look for a rainbow
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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[PSES] TTE Equipment and RTTE Directive

2014-11-19 Thread Carl Newton


Dear List Members,

I haven't worked with land-line telecom hardware for many years.  I have a  
device intended for use by handicapped persons that will enable a visual  
alarm if the land-line phone is ringing, so the device is listen-only.   
I've found what appears to be good and reliable guidance concerning TTE  
equipment at this link which indicates that TTE equipment need only comply  
with the EMCD and LVD:


http://ec.europa.eu/enterprise/sectors/rtte/regulatory-framework/index_en.htm

However, I'm seeing DoCs and product specs for current TTE equipment that  
reference the ETSI 201 703 and TBR series of standards, and those  
standards are not listed under the RTTED, EMCD, or LVD on the Europa  
Harmonized Standards pages.


Can someone shed some light on this confusing issue?  Is TTE really not  
required to meet a line connection standard of some type as the Europa  
link above indicates?


Thanks very much,

Carl

--

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http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used 
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Re: [PSES] TTE Equipment and RTTE Directive

2014-11-19 Thread Larry K. Stillings

Hi Carl,

What you have surmised is correct. You are not required to meet any line
standards is order to comply with the directives. 

The DoCs you are seeing, is the voluntary testing to ETSI standards to
show that the line interface device is compatible with the phone
network. I asked several times a joint NIST - EU meetings (in the
2000's) about the implementation of TTE standards under the RTTE
directive and always got the same response. There are no formal
complaints and therefore no implementation of mandatory standards will
occur. Also, the other reason the directive is going to become the Radio
Equipment Directive (RED), as that is all it has ever really covered.

Of course being a test lab whom does those tests, we can only make a
mild suggestion you should test, as to this day we still have product
showing up that don't comply with the ETSI TBR and or ES 203 021-x
standards, but that is always a financial / business decision on what
the risk is of performing no testing.


Larry K. Stillings
Compliance Worldwide, Inc. 
Test Locally, Sell Globally and Launch Your Products Around the World! 
FCC - Wireless - Telecom - CE Marking - International Approvals -
Product Safety 
357 Main Street
Sandown, NH 03873
(603) 887 3903 Fax 887-6445
www.complianceworldwide.com

Privileged/Confidential Information may be contained in this message. If
you are not the addressee indicated in this message (or responsible for
delivery of the message to such person), you may not copy or deliver
this message to anyone. In such case, you should destroy this message
and kindly notify the sender by reply email. Please advise immediately
if you or your employer do not consent to Internet email for messages of
this kind. Opinions, conclusions and other information in this message
that do not relate to the official business of my firm shall be
understood as neither given nor endorsed by it.


-Original Message-
From: Carl Newton [mailto:emcl...@gmail.com] 
Sent: Wednesday, November 19, 2014 3:10 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] TTE Equipment and RTTE Directive

Dear List Members,

I haven't worked with land-line telecom hardware for many years.  I have
a device intended for use by handicapped persons that will enable a
visual  
alarm if the land-line phone is ringing, so the device is listen-only.

I've found what appears to be good and reliable guidance concerning TTE
equipment at this link which indicates that TTE equipment need only
comply with the EMCD and LVD:

http://ec.europa.eu/enterprise/sectors/rtte/regulatory-framework/index_e
n.htm

However, I'm seeing DoCs and product specs for current TTE equipment
that reference the ETSI 201 703 and TBR series of standards, and those
standards are not listed under the RTTED, EMCD, or LVD on the Europa
Harmonized Standards pages.

Can someone shed some light on this confusing issue?  Is TTE really not
required to meet a line connection standard of some type as the Europa
link above indicates?

Thanks very much,

Carl

--

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at http://product-compliance.oc.ieee.org/ can be used for graphics (in
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Attachments are not permitted but the IEEE PSES Online Communities site at 
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formats), large files, etc.

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Re: [PSES] TTE Equipment and RTTE Directive

2014-11-19 Thread Carl Newton

Excellent response Larry.  When something sounds too good to be true it  
usually is.  But not in this case.


Thanks very much,

Carl



On Wed, 19 Nov 2014 15:26:53 -0500, Larry K. Stillings  
la...@complianceworldwide.com wrote:



Hi Carl,

What you have surmised is correct. You are not required to meet any line
standards is order to comply with the directives.

The DoCs you are seeing, is the voluntary testing to ETSI standards to
show that the line interface device is compatible with the phone
network. I asked several times a joint NIST - EU meetings (in the
2000's) about the implementation of TTE standards under the RTTE
directive and always got the same response. There are no formal
complaints and therefore no implementation of mandatory standards will
occur. Also, the other reason the directive is going to become the Radio
Equipment Directive (RED), as that is all it has ever really covered.

Of course being a test lab whom does those tests, we can only make a
mild suggestion you should test, as to this day we still have product
showing up that don't comply with the ETSI TBR and or ES 203 021-x
standards, but that is always a financial / business decision on what
the risk is of performing no testing.


Larry K. Stillings
Compliance Worldwide, Inc.
Test Locally, Sell Globally and Launch Your Products Around the World!
FCC - Wireless - Telecom - CE Marking - International Approvals -
Product Safety
357 Main Street
Sandown, NH 03873
(603) 887 3903 Fax 887-6445
www.complianceworldwide.com

Privileged/Confidential Information may be contained in this message. If
you are not the addressee indicated in this message (or responsible for
delivery of the message to such person), you may not copy or deliver
this message to anyone. In such case, you should destroy this message
and kindly notify the sender by reply email. Please advise immediately
if you or your employer do not consent to Internet email for messages of
this kind. Opinions, conclusions and other information in this message
that do not relate to the official business of my firm shall be
understood as neither given nor endorsed by it.


-Original Message-
From: Carl Newton [mailto:emcl...@gmail.com]
Sent: Wednesday, November 19, 2014 3:10 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] TTE Equipment and RTTE Directive

Dear List Members,

I haven't worked with land-line telecom hardware for many years.  I have
a device intended for use by handicapped persons that will enable a
visual
alarm if the land-line phone is ringing, so the device is listen-only.

I've found what appears to be good and reliable guidance concerning TTE
equipment at this link which indicates that TTE equipment need only
comply with the EMCD and LVD:

http://ec.europa.eu/enterprise/sectors/rtte/regulatory-framework/index_e
n.htm

However, I'm seeing DoCs and product specs for current TTE equipment
that reference the ETSI 201 703 and TBR series of standards, and those
standards are not listed under the RTTED, EMCD, or LVD on the Europa
Harmonized Standards pages.

Can someone shed some light on this confusing issue?  Is TTE really not
required to meet a line connection standard of some type as the Europa
link above indicates?

Thanks very much,

Carl

--

-

This message is from the IEEE Product Safety Engineering Society
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at http://product-compliance.oc.ieee.org/ can be used for graphics (in
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Website:  http://www.ieee-pses.org/
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--
Using Opera's mail client: http://www.opera.com/mail/

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[PSES] OJEU publication of harmonised standards under the RTTE Directive

2014-09-12 Thread Hooper, Nick

FYI

http://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1410509109080uri=OJ:JOC_2014_313_R_0001


Note, this is now in landscape format.  There is an extra column (3) for the 
“First publication OJ” date etc.


Regards
Nick


Nick Hooper BSc(Eng) CEng MIET SMIEEE
Chairman RTTE CA

UL
Grove House Business Centre, Chineham Court, Lutyens,
Basingstoke, Hampshire, RG24 8AG, England

T: +44 1256 31 2097 | F: +44 1256 31 2001 | M: +44 7970 429 665
E: nick.hoo...@ul.com | W: www.ul.com

This email and any files transmitted with it are confidential and intended 
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it and notify the sender.


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the intended recipient: (1) you may not disclose, use, distribute, copy or rely 
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[PSES] European RTTE Class 1 and 2 devices.

2014-08-04 Thread Michael Derby

Hello all,

 

As we've been talking about the RTTE Class 1 and 2 devices, the lists have
been updated:

 

http://ec.europa.eu/enterprise/sectors/rtte/documents/index_en.htm#h2-5

 

 

Michael.

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

Certification Resource for the Wireless Industry

Web:http://www.acbcert.com www.acbcert.com

 

e-mail: mailto:micha...@acbcert.com micha...@acbcert.com

Direct phone:(+1) 703 468 1746   (USA area code)

Mobile phone:   (+44) 7939 880829   (UK area code)

 

Corporate office phone: USA:   (+1) 703 847 4700

Corporate office fax:USA:   (+1) 703 847 6888

 


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[PSES] RTTE

2013-11-14 Thread Mark Schmidt

Well, I have a Class A (EN55011) product under EN61326-1. Initially it was not 
going to be sold with an FCC/IC/CE Bluetooth certified module. So when sales 
decided they had to have this feature we then needed to meet EN301489-1 and in 
Annex C.3.1 it indicates that The limits and tests used to demonstrate 
compliance of the combined equipment shall be taken from the harmonized EMC 
standard relevant to the primary function (declared by the manufacturer). So 
my interpretation of this is that a Class A unintentional radiator can utilize 
a BT compliant module and still meet the requirements of the RTTE Directive. 
Great right? Then Sales decided that they have this huge potential for sales in 
the Korean market.  Apparently when the Koreans adopted EN301489-1 the KN 
version of this standard omitted the clause in Annex C.3.1.  So we had the 
device tested in-country and they indicated that the unintentional radiator had 
to meet Class B EN55022/CISPR 22 for ITE with 6 db margin. Naturally we failed. 
This is not an ITE product and was not designed to meet Class B any comments 
are appreciated.
Has anyone else experienced this?

Thanks,
Mark Schmidt




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Re: [PSES] RTTE

2013-11-14 Thread McInturff, Gary

I'm curious about the 6 dB margin. Is that in the Korean version of the 
standard? Usually standards have limits but not margin. In fact if it were a 
required to have this margin, wouldn't the limit simple be the international 
limit minus 6 dB. Typically test houses don't get to invent or enforce margins 
to the limit.

Gary

From: Mark Schmidt [mailto:mark.schm...@dornerworks.com]
Sent: Thursday, November 14, 2013 7:33 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] RTTE

Well, I have a Class A (EN55011) product under EN61326-1. Initially it was not 
going to be sold with an FCC/IC/CE Bluetooth certified module. So when sales 
decided they had to have this feature we then needed to meet EN301489-1 and in 
Annex C.3.1 it indicates that The limits and tests used to demonstrate 
compliance of the combined equipment shall be taken from the harmonized EMC 
standard relevant to the primary function (declared by the manufacturer). So 
my interpretation of this is that a Class A unintentional radiator can utilize 
a BT compliant module and still meet the requirements of the RTTE Directive. 
Great right? Then Sales decided that they have this huge potential for sales in 
the Korean market.  Apparently when the Koreans adopted EN301489-1 the KN 
version of this standard omitted the clause in Annex C.3.1.  So we had the 
device tested in-country and they indicated that the unintentional radiator had 
to meet Class B EN55022/CISPR 22 for ITE with 6 db margin. Naturally we failed. 
This is not an ITE product and was not designed to meet Class B any comments 
are appreciated.
Has anyone else experienced this?

Thanks,
Mark Schmidt



-


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Re: [PSES] RTTE

2013-11-14 Thread Mark Schmidt

No it is not in the standard. However it was translated so I will assume it is 
not in there. The test lab indicated that they would accept 3db of margin to 
the CISPR B limit. The plots actually had the international CIPSR B limit line 
displayed and the 6db margin limit line displayed. Do I have to meet Class B 
CISPR 22.

From: McInturff, Gary [mailto:gary.mcintu...@esterline.com]
Sent: Thursday, November 14, 2013 11:42 AM
To: Mark Schmidt; 'EMC-PSTC@LISTSERV.IEEE.ORG'
Subject: RE: RTTE

I'm curious about the 6 dB margin. Is that in the Korean version of the 
standard? Usually standards have limits but not margin. In fact if it were a 
required to have this margin, wouldn't the limit simple be the international 
limit minus 6 dB. Typically test houses don't get to invent or enforce margins 
to the limit.

Gary

From: Mark Schmidt [mailto:mark.schm...@dornerworks.com]
Sent: Thursday, November 14, 2013 7:33 AM
To: EMC-PSTC@LISTSERV.IEEE.ORGmailto:EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] RTTE

Well, I have a Class A (EN55011) product under EN61326-1. Initially it was not 
going to be sold with an FCC/IC/CE Bluetooth certified module. So when sales 
decided they had to have this feature we then needed to meet EN301489-1 and in 
Annex C.3.1 it indicates that The limits and tests used to demonstrate 
compliance of the combined equipment shall be taken from the harmonized EMC 
standard relevant to the primary function (declared by the manufacturer). So 
my interpretation of this is that a Class A unintentional radiator can utilize 
a BT compliant module and still meet the requirements of the RTTE Directive. 
Great right? Then Sales decided that they have this huge potential for sales in 
the Korean market.  Apparently when the Koreans adopted EN301489-1 the KN 
version of this standard omitted the clause in Annex C.3.1.  So we had the 
device tested in-country and they indicated that the unintentional radiator had 
to meet Class B EN55022/CISPR 22 for ITE with 6 db margin. Naturally we failed. 
This is not an ITE product and was not designed to meet Class B any comments 
are appreciated.
Has anyone else experienced this?

Thanks,
Mark Schmidt

-

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Re: [PSES] RTTE

2013-11-14 Thread John Woodgate

In message 119fa9545c6e264b830c4582886d119068e70...@quimby.dw.local, 
dated Thu, 14 Nov 2013, Mark Schmidt mark.schm...@dornerworks.com 
writes:


 Apparently when the Koreans adopted EN301489-1 the KN version of this 
standard omitted the clause in Annex C.3.1.  So we had the device 
tested in-country and they indicated that the unintentional radiator 
had to meet Class B EN55022/CISPR 22 for ITE with 6 db margin. 
Naturally we failed. This is not an ITE product and was not designed to 
meet Class B any comments are appreciated.


The test house or regulators are simply applying the wrong standard. 
Your remedy is to patiently explain the true situation - CISPR 11 
applies. Do you have anyone who can communicate technically with them in 
Korean?

--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk
Nondum ex silvis sumus
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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Re: [PSES] RTTE

2013-11-14 Thread Brian Ceresney

Hi Mark,
We had a similar occurrence lately, where the Korean EMC lab tested our Class A 
Industrial product to ITE standards, and we failed Class B. We had previously 
submitted to them our EMC test report for North America and Europe, so the 
mistake was unexpected.

They retested to Class A at our request(at no charge that was visible to us), 
and we then passed the correct requirement.

Best Regards,
Brian C.


From: Mark Schmidt [mailto:mark.schm...@dornerworks.com]
Sent: November-14-13 7:33 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] RTTE

Well, I have a Class A (EN55011) product under EN61326-1. Initially it was not 
going to be sold adopted EN301489-1 the KN version of this standard omitted 
the clause in Annex C.3.1.  So we had the device tested in-country and they 
indicated that the unintentional radiator had to meet Class B EN55022/CISPR 22 
for ITE with 6 db margin. Naturally we failed. This is not an ITE product and 
was not designed to meet Class B any comments are appreciated.
Has anyone else experienced this?

Thanks,
Mark Schmidt



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Re: [PSES] RTTE

2013-11-14 Thread Mark Schmidt

We have calmly explained this. They have copies of our NA and European Test 
reports, I think part of the problem is that the text in both the EN and KN 301 
489 indicates:
The environment classification used in the present document refers to the 
environment classification used in: EN 61000-6-3 and EN 61000-6-1 for the 
residential, commercial and light industrial environment; or TR 101 651 for the 
telecommunication centre environment; or ISO 7637-2 for the vehicular 
environment.

So if I refer to the generic standard EN 61000-6-3 the applicable limits are 
Class B only this standard does not recognize a Class A limit.  Another 
complication is that it is a hand-held portable device that uses a 30 Watt EPS 
used for charging the battery. This device is a measurement device typically 
used in a lab or factory environment. Again, initially classified 
EN61326-1/EN55011 Group1, Class A.

I think we may just have to sell the non BT version which they have also tested 
and oddly enough to Class A.


-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk] 
Sent: Thursday, November 14, 2013 1:11 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] RTTE

In message 119fa9545c6e264b830c4582886d119068e70...@quimby.dw.local,
dated Thu, 14 Nov 2013, Mark Schmidt mark.schm...@dornerworks.com
writes:

  Apparently when the Koreans adopted EN301489-1 the KN version of this 
standard omitted the clause in Annex C.3.1.  So we had the device 
tested in-country and they indicated that the unintentional radiator 
had to meet Class B EN55022/CISPR 22 for ITE with 6 db margin.
Naturally we failed. This is not an ITE product and was not designed to 
meet Class B any comments are appreciated.

The test house or regulators are simply applying the wrong standard. 
Your remedy is to patiently explain the true situation - CISPR 11 applies. Do 
you have anyone who can communicate technically with them in Korean?
--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk Nondum ex 
silvis sumus John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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Re: [PSES] RTTE

2013-11-14 Thread John Woodgate

In message 119fa9545c6e264b830c4582886d119068e70...@quimby.dw.local, 
dated Thu, 14 Nov 2013, Mark Schmidt mark.schm...@dornerworks.com 
writes:


We have calmly explained this. They have copies of our NA and European 
Test reports, I think part of the problem is that the text in both the 
EN and KN 301 489 indicates: The environment classification used in the 
present document refers to the environment classification used in: EN 
61000-6-3 and EN 61000-6-1 for the residential, commercial and light 
industrial environment; or TR 101 651 for the telecommunication centre 
environment; or ISO 7637-2 for the vehicular environment.


I see; yes, it does seem that the problem lies there. You would have to 
take that up with ETSI, if you are sure that other environments (Class 
A) are not mentioned anywhere else in the standard.



So if I refer to the generic standard EN 61000-6-3 the applicable 
limits are Class B only this standard does not recognize a Class A 
limit.


It can't, because it applies only to the Class B environment

Another complication is that it is a hand-held portable device that 
uses a 30 Watt EPS used for charging the battery. This device is a 
measurement device typically used in a lab or factory environment. 
Again, initially classified EN61326-1/EN55011 Group1, Class A.


Quite correctly, as you describe it.


I think we may just have to sell the non BT version which they have 
also tested and oddly enough to Class A.


Because EN 301489 and its deficient 'environment' clause doesn't apply.
--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk
Nondum ex silvis sumus
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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[PSES] RTTE Harm Std

2013-10-12 Thread Helge Knudsen

Hi all,

 

On 2013-10-12 a new list of harmonized standard was released in OJ, see

 

http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:C:2013:297:0001:003
1:EN:PDF

 

 

Best regards 

 

Helge Knudsen

Denmark


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Re: [PSES] RTTE example

2013-09-04 Thread Sundstrom, Michael

Tom,
I was always taught FFC + FCC doesn't = FCC compliant...
Or
CE + CE doesn't = CE

The whole system needs to be tested, because all combinations can't be covered 
by any one manufacturer testing.

 Michael Sundstrom
OHD TREQ Dallas
Electronic Lab Analyst EMC Lead
(214) 579 6312  office
(940) 390 3644  cell
マイク
KB5UKT

-Original Message-
From: T.Sato [mailto:vef00...@nifty.ne.jp] 
Sent: Friday, August 30, 2013 6:26 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] RTTE example

On Wed, 28 Aug 2013 15:44:35 +,
  Ian White (SXS UK) ian.wh...@uk.spiraxsarco.com wrote:

 If you have a control panel which has relays and various other control gear 
 on, all mounted on a Din rail type construction this all comes under the LVD 
 and EMC Directives.
 
 If you then include a DIN rail mounted 3G Modem (which has its own D of C) 
 would the entire panel then come under RTTE Directive ?
 
 1) Would the panel have to be re-tested ?
 2) RTTE requirements on LVD now apply with no bottom limits on LVD?

I think it is essentially a general question, What is the requirements for a 
final product that integrates an RTTE Directive assessed module?.

I think the panel would also be covered by the RTTE Directive.
There is a discussion about this topic in RTTE CA guidance note, at:
http://www.rtteca.com/TGN01%20-%20May%202013.pdf

Regards,
Tom

--
Tomonori Sato  vef00...@nifty.ne.jp
URL: http://homepage3.nifty.com/tsato/

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Re: [PSES] RTTE example

2013-09-04 Thread John Woodgate

In message b1a87e5abaca334bbf399a017113928406852...@sv-mbx01.ohdc.com, 
dated Wed, 4 Sep 2013, Sundstrom, Michael 
michael_sundst...@overheaddoor.com writes:



CE + CE doesn't = CE


There is special treatment for control panels because they are usually 
unique or identical only in small numbers.

--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk
If dictionaries were correct, we would only need one, because they would all
give the same information.
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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Re: [PSES] RTTE example

2013-08-30 Thread T.Sato

On Wed, 28 Aug 2013 15:44:35 +,
  Ian White (SXS UK) ian.wh...@uk.spiraxsarco.com wrote:

 If you have a control panel which has relays and various other control gear 
 on, all mounted on a Din rail type construction this all comes under the LVD 
 and EMC Directives.
 
 If you then include a DIN rail mounted 3G Modem (which has its own D of C) 
 would the entire panel then come under RTTE Directive ?
 
 1) Would the panel have to be re-tested ?
 2) RTTE requirements on LVD now apply with no bottom limits on LVD?

I think it is essentially a general question, What is the requirements
for a final product that integrates an RTTE Directive assessed module?.

I think the panel would also be covered by the RTTE Directive.
There is a discussion about this topic in RTTE CA guidance note, at:
http://www.rtteca.com/TGN01%20-%20May%202013.pdf

Regards,
Tom

-- 
Tomonori Sato  vef00...@nifty.ne.jp
URL: http://homepage3.nifty.com/tsato/

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[PSES] RTTE example

2013-08-28 Thread Ian White (SXS UK)

Forum members,

Could l have your views on the following please.

If you have a control panel which has relays and various other control gear on, 
all mounted on a Din rail type construction this all comes under the LVD and 
EMC Directives.

If you then include a DIN rail mounted 3G Modem (which has its own D of C) 
would the entire panel then come under RTTE Directive ?

1) Would the panel have to be re-tested ?
2) RTTE requirements on LVD now apply with no bottom limits on LVD?

Thanks

Ian White
Compliance and Reliability.

_
Spirax-Sarco Engineering Plc.  This e-mail has been scanned for viruses by 
Verizon Business Internet Managed Scanning Services - powered by MessageLabs. 
For further information visit http://www.verizonbusiness.com/uk

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Re: [PSES] RTTE example

2013-08-28 Thread John Woodgate

In message 
ea4ca5c9ced91040aa61aacf924588669d9...@ukldexm02.global.spiraxsarco.com
, dated Wed, 28 Aug 2013, Ian White (SXS UK) 
ian.wh...@uk.spiraxsarco.com writes:




If you have a control panel which has relays and various other control 
gear on, all mounted on a Din rail type construction this all comes 
under the LVD and EMC Directives.


 

If you then include a DIN rail mounted 3G Modem (which has its own D of 
C) would the entire panel then come under RTTE Directive ?


 
The LVD and EMCD Guides mention control panels, if I remember correctly, 
because they are usually specially made and not 'catalogue items'. But 
whether the RTTED or its Guide have similar provisions is another 
matter. Such things as DIN-rail modems may not have been in mind when 
the documents were written.


1) Would the panel have to be re-tested ?


Is there any reason to expect the modem not to conform just because it's 
mounted in your panel? It was presumably type-tested for conformity in a 
typical panel environment (i.e. properly mounted on a DIN rail).


2) RTTE requirements on LVD now apply with no bottom limits on LVD?


I'm not sure that it's relevant.
--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk
Why is the stapler always empty just when you want it?

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

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Re: [PSES] Is a Notified Body really needed to assess electrical safety for a 12VDC RTTE device?

2013-06-24 Thread Willem Jan Jong

Dear Group,

 

Some correction is needed here.

 

Notified body involvement is mandatory when harmonized standards can not
be used or are not available for the equipment at hand. Or if the
manufacturer wants to use its own testing routine. In all these cases
the NB needs to assess the equipment against the essential requirements
(annex IV).

 

Self declaration is only allowed if all applicable harmonized standards
are being (fully) followed.

 

Kind regards,

 

Willem Jan Jong

Manager Product Certification

Telefication

 

 

From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of ce-test,
qualified testing bv - Gert Gremmen
Sent: zaterdag, 22 juni, 2013 4:20 PM
To: Crane, Lauren; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: Is a Notified Body really needed to assess electrical
safety for a 12VDC RTTE device?

 

 

Hi Lauren,

 

As far as my understanding goes, without any

further study regarding your arguments, I remember that for NO

RTTED equipment a NoBo is mandatory.

 

Said differently, the intention of the RTTED has always been

(and I was always learned ) that the manufacturers declaration

is sufficient for all.  NoBo's are mandatory for some machines,

medical equipment class 2 and higher and a number of other

directives that cover high risk equipment.

 

The same is true for the EMCD and the LVD.

 

In general the tendency in Europe is to reduce the role of the NoBo's.

 

The fault you make in my view, is that you state that the product is not
in the scope

of the LVD (12V), so you need to apply annex III, IV or V  (instead of
II, IV or V), 

but  as the voltage requirement is removed, all equipment falls in the
(modified) LVD scope.

 

In my experience most equipment is assessed as office equipment (EN
60950)

 

Hope this helps...

 

Regards,

Ing.  Gert Gremmen, BSc

 

 

g.grem...@cetest.nl

www.cetest.nl


Kiotoweg 363

3047 BG Rotterdam

T 31(0)104152426
F 31(0)104154953

Before printing, think about the environment. 

 

 

Van: emc-p...@ieee.org [mailto:emc-p...@ieee.org] Namens Crane, Lauren
Verzonden: Friday, June 21, 2013 11:59 PM
Aan: EMC-PSTC@LISTSERV.IEEE.ORG
Onderwerp: Is a Notified Body really needed to assess electrical safety
for a 12VDC RTTE device?

 

Dear Experts, I am looking for help in understanding how to correctly
address LVD concerns within the RTTED. 

 

The RTTED has three main concerns (essential requirements), 

1.   Radio spectrum issues [art. 3.2]

2.   Low voltage safety [art. 3.1.a] - LVD

3.   Electromagnetic compatibility [art. 3.1.b] - EMCD

 

EU guidance says each of these concerns may be addressed separately.
[Csion guide Apr 2009 6.1 first para] 

 

The low voltage directive (LVD)  as a stand alone requirement, doesn't
apply until DC input voltages reach 75V, but the RTTED requires the LVD
to apply regardless of voltage [art. 3.1.a -end]. RTTED also says that
the conformity assessment procedures of the LVD may be used where the
item is within scope of the LVD (e.g., electrical equipment operating
from 80VDC) [art. 10.2].  If a product is not within scope of the LVD on
its own (e.g., operating from 12 VDC), one must use the conformity
assessment procedures defined in the RTTED (I think). 

 

In the RTTED the only assessment procedure that does not require a
notified body is 'production control' (Annex II).   The Production
Control method (Annex II) is *not* allowed for equipment with radio
transmitters [art. 10.3,4,5]. 

 

So if I have a very low voltage device (e.g. 12 volts) with a data
transmission function I must, at first glance, use RTTED conformity
assessment methods (and thereby a Notified Body), to assess the LVD
concerns. 

 

I have already had my widget assessed for radio spectrum issues and EMC
issues by Notified Bodies.  It looks like I need a notified body for the
LVD stuff too. If the voltages were higher, I could self declare LVD
compliance. This does not make sense. What am I misunderstanding?

 

Regards,

Lauren Crane

KLA-Tencor

 

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[PSES] Is a Notified Body really needed to assess electrical safety for a 12VDC RTTE device?

2013-06-21 Thread Crane, Lauren

Dear Experts, I am looking for help in understanding how to correctly address 
LVD concerns within the RTTED.

The RTTED has three main concerns (essential requirements),

1.   Radio spectrum issues [art. 3.2]

2.   Low voltage safety [art. 3.1.a] - LVD

3.   Electromagnetic compatibility [art. 3.1.b] - EMCD

EU guidance says each of these concerns may be addressed separately. [Csion 
guide Apr 2009 6.1 first para]

The low voltage directive (LVD)  as a stand alone requirement, doesn't apply 
until DC input voltages reach 75V, but the RTTED requires the LVD to apply 
regardless of voltage [art. 3.1.a -end]. RTTED also says that the conformity 
assessment procedures of the LVD may be used where the item is within scope of 
the LVD (e.g., electrical equipment operating from 80VDC) [art. 10.2].  If a 
product is not within scope of the LVD on its own (e.g., operating from 12 
VDC), one must use the conformity assessment procedures defined in the RTTED (I 
think).

In the RTTED the only assessment procedure that does not require a notified 
body is 'production control' (Annex II).   The Production Control method (Annex 
II) is *not* allowed for equipment with radio transmitters [art. 10.3,4,5].

So if I have a very low voltage device (e.g. 12 volts) with a data transmission 
function I must, at first glance, use RTTED conformity assessment methods (and 
thereby a Notified Body), to assess the LVD concerns.

I have already had my widget assessed for radio spectrum issues and EMC issues 
by Notified Bodies.  It looks like I need a notified body for the LVD stuff 
too. If the voltages were higher, I could self declare LVD compliance. This 
does not make sense. What am I misunderstanding?

Regards,
Lauren Crane
KLA-Tencor


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Re: [PSES] How to determine EU RTTE class.

2013-04-12 Thread Anthony Thomson

Hello Lauren,

Rather than a lengthy explanation, can I point you to the Commission’s RTTED 
Reference page...

http://ec.europa.eu/enterprise/sectors/rtte/documents/#h2-2

Follow the link to Equipment Classes where there is an explanation and two 
fairly recent lists defining Class 1 and Class 2 equipment. Also read section 4 
the ‘Guide’ (my constant companion)
@ http://ec.europa.eu/enterprise/sectors/rtte/files/guide2009-04-20_en.pdf 

I did have a little look-see at what goes on at 1700 kHz. Now I’m not sure here 
but I think you might be encroaching into the AM broadcast band, cordless 
phone, ship-shore radio, inductive transmission, and amateur radio bands. I’m 
not sure you can use this band in Europe for data telemetry applications which 
I what I think you are doing? Particularly for OOKing which is very aggressive 
in terms of spectrum usage. If others know otherwise... please correct me.

Anyway, according to current guidance your kit doesn’t appear to be Class 2. If 
there are Harmonised Standards for your particular equipment then you’re in the 
clear and it’s very probably Class 1.

If neither then I would suggest you seek advice from a Notified Body who may be 
able to help.

Without knowing much more about the equipment it's impossible to be more 
specific but I hope this helps.

Cheers,
T
- Original Message -
From: Crane, Lauren
Sent: 04/11/13 12:00 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] How to determine EU RTTE class.

I am looking for advice on how to determine the EU RTTE class of a product.
The product has a base station and a sensor. The battery powered sensor can be 
taken out of the base station and used elsewhere to do its sensing thing, and 
then be brought back to the base station for charging and uploading of the 
sensed data.
The nominal transmit frequency for sense data communication is 1700 KHz +/-100 
KHz. The modulation scheme uses On-Off Keying (OOK). The nominal baudrate base 
station to sensor is 1,000 Hz. The nominal baudrate sensor to base station is 
8,000 Hz.
Based on this information, can someone help me understand which RTTE class this 
product is, and why?
Regards,
Lauren Crane
KLA-Tencor

-

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Re: [PSES] How to determine EU RTTE class.

2013-04-12 Thread T.Sato

On Wed, 10 Apr 2013 23:00:27 +,
  Crane, Lauren lauren.cr...@kla-tencor.com wrote:

 I am looking for advice on how to determine the EU RTTE class of a product.
 
 The product has a base station and a sensor. The battery powered sensor can 
 be taken out of the base station and used elsewhere to do its sensing thing, 
 and then be brought back to the base station for charging and uploading of 
 the sensed data.
 
 The nominal transmit frequency for sense data communication is 1700 KHz 
 +/-100 KHz. The modulation scheme uses On-Off Keying (OOK).  The nominal 
 baudrate base station to sensor is 1,000 Hz. The nominal baudrate sensor to 
 base station is 8,000 Hz.
 
 
 Based on this information, can someone help me understand which RTTE class 
 this product is, and why?

Information related to equipment classes can be found at:

   http://ec.europa.eu/enterprise/sectors/rtte/documents/

If your product is of low power inductive communication, you can
check whether your product fall under sub-class 74 described in
the document Subclasses of Class 1 - July 2012 first, I think.

Regards,
Tom

-- 
Tomonori Sato  vef00...@nifty.ne.jp
URL: http://homepage3.nifty.com/tsato/

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Re: [PSES] How to determine EU RTTE class.

2013-04-12 Thread Crane, Lauren

Hi, Tom.

Sorry I left out that key detail. This is inductive coupled communication (and 
charging).

Charlie Blackman sent me a lead on RTTE guidance from CEPT. I am fairly certain 
this device can be considered Class 1, sub-class 74 under RTTE.

The mag field for the communications is quite small. The field for charging is 
higher, but I assume it can be ignored (inductive charging is not covered by 
RTTE).

Regards,
Lauren

From: Thomas Cokenias [mailto:t...@tncokenias.org]
Sent: Thursday, April 11, 2013 6:53 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] How to determine EU RTTE class.

Hi Lauren

Is this over the air 1700 kHz transmission or conducted over wire or AC mains?

best regards

Tom Cokenias


On Apr 10, 2013, at 4:00 PM, Crane, Lauren wrote:


I am looking for advice on how to determine the EU RTTE class of a product.

The product has a base station and a sensor. The battery powered sensor can be 
taken out of the base station and used elsewhere to do its sensing thing, and 
then be brought back to the base station for charging and uploading of the 
sensed data.

The nominal transmit frequency for sense data communication is 1700 KHz +/-100 
KHz. The modulation scheme uses On-Off Keying (OOK).  The nominal baudrate base 
station to sensor is 1,000 Hz. The nominal baudrate sensor to base station is 
8,000 Hz.


Based on this information, can someone help me understand which RTTE class this 
product is, and why?

Regards,
Lauren Crane
KLA-Tencor

-


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Re: [PSES] How to determine EU RTTE class.

2013-04-12 Thread Crane, Lauren

Thanks, Tom. 

I was looking for a bit more description of what could be considered inductive 
devices for Sub-class 74. 

Charlie Blackman pointed me to 
http://www.erodocdb.dk/docs/doc98/official/pdf/rec7003e.pdf  which have a bit 
more description than the Commission class documents. 


Regards,
Lauren 

-Original Message-
From: T.Sato [mailto:vef00...@nifty.ne.jp] 
Sent: Friday, April 12, 2013 5:43 AM
To: Crane, Lauren
Cc: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: How to determine EU RTTE class.

On Wed, 10 Apr 2013 23:00:27 +,
  Crane, Lauren lauren.cr...@kla-tencor.com wrote:

 I am looking for advice on how to determine the EU RTTE class of a product.
 
 The product has a base station and a sensor. The battery powered sensor can 
 be taken out of the base station and used elsewhere to do its sensing thing, 
 and then be brought back to the base station for charging and uploading of 
 the sensed data.
 
 The nominal transmit frequency for sense data communication is 1700 KHz 
 +/-100 KHz. The modulation scheme uses On-Off Keying (OOK).  The nominal 
 baudrate base station to sensor is 1,000 Hz. The nominal baudrate sensor to 
 base station is 8,000 Hz.
 
 
 Based on this information, can someone help me understand which RTTE class 
 this product is, and why?

Information related to equipment classes can be found at:

   http://ec.europa.eu/enterprise/sectors/rtte/documents/

If your product is of low power inductive communication, you can check whether 
your product fall under sub-class 74 described in the document Subclasses of 
Class 1 - July 2012 first, I think.

Regards,
Tom

--
Tomonori Sato  vef00...@nifty.ne.jp
URL: http://homepage3.nifty.com/tsato/

-

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formats), large files, etc.

Website:  http://www.ieee-pses.org/
Instructions:  http://listserv.ieee.org/request/user-guide.html
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Re: [PSES] How to determine EU RTTE class.

2013-04-11 Thread Thomas Cokenias

Hi Lauren

Is this over the air 1700 kHz transmission or conducted over wire or AC mains?

best regards

Tom Cokenias


On Apr 10, 2013, at 4:00 PM, Crane, Lauren wrote:

 I am looking for advice on how to determine the EU RTTE class of a product.
  
 The product has a base station and a sensor. The battery powered sensor can 
 be taken out of the base station and used elsewhere to do its sensing thing, 
 and then be brought back to the base station for charging and uploading of 
 the sensed data.
  
 The nominal transmit frequency for sense data communication is 1700 KHz 
 +/-100 KHz. The modulation scheme uses On-Off Keying (OOK).  The nominal 
 baudrate base station to sensor is 1,000 Hz. The nominal baudrate sensor to 
 base station is 8,000 Hz.
  
  
 Based on this information, can someone help me understand which RTTE class 
 this product is, and why?
  
 Regards,
 Lauren Crane
 KLA-Tencor
  
 -
 
 This message is from the IEEE Product Safety Engineering Society emc-pstc 
 discussion list. To post a message to the list, send your e-mail to 
 emc-p...@ieee.org
 
 All emc-pstc postings are archived and searchable on the web at: 
 http://www.ieee-pses.org/emc-pstc.html
 
 Attachments are not permitted but the IEEE PSES Online Communities site at 
 http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used 
 formats), large files, etc.
 
 Website: http://www.ieee-pses.org/
 Instructions: http://listserv.ieee.org/request/user-guide.html
 List rules: http://www.ieee-pses.org/listrules.html
 
 For help, send mail to the list administrators:
 Scott Douglas emcp...@radiusnorth.net
 Mike Cantwell mcantw...@ieee.org
 
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 Jim Bacher j.bac...@ieee.org
 David Heald dhe...@gmail.com
 


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[PSES] How to determine EU RTTE class.

2013-04-10 Thread Crane, Lauren

I am looking for advice on how to determine the EU RTTE class of a product.

The product has a base station and a sensor. The battery powered sensor can be 
taken out of the base station and used elsewhere to do its sensing thing, and 
then be brought back to the base station for charging and uploading of the 
sensed data.

The nominal transmit frequency for sense data communication is 1700 KHz +/-100 
KHz. The modulation scheme uses On-Off Keying (OOK).  The nominal baudrate base 
station to sensor is 1,000 Hz. The nominal baudrate sensor to base station is 
8,000 Hz.


Based on this information, can someone help me understand which RTTE class this 
product is, and why?

Regards,
Lauren Crane
KLA-Tencor


-

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discussion list. To post a message to the list, send your e-mail to 
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[PSES] SV: [PSES] SV: [PSES] RTTE - Radio product or not

2013-03-21 Thread Amund Westin

Mike

I see that approach. 
Radio tests on one combination of A+B is approximate $10.000. So doing a 
reasonable number of combinations will be very costly. And we can run into 
problems that is caused by Item B's, which are made from other manufacturers ...

But we have done a successful test on Item A + B previously. We could measured 
the IF spectra on output port (coax cable) of old Item A model, and compared it 
with similar measurements (harmonics, spurious, freq. drift, etc) on the new 
Item A model. Then should at least the input signals to Item B be in the same 
range.

#Amund


 



-Opprinnelig melding-
Fra: Heckrotte, Michael [mailto:michael.heckro...@ul.com] 
Sendt: 20. mars 2013 17:07
Til: EMC-PSTC@LISTSERV.IEEE.ORG
Emne: Re: [PSES] SV: [PSES] RTTE - Radio product or not

Amund,

Regarding your second paragraph, a cost-effective approach is to develop a Test 
Plan that specifies tests on a reasonable number of combinations, submit it to 
a Notified Body for review, then get the Notified Body Expert Opinion based on 
that plan and the test results.

Best Regards,
Mike

-Original Message-
From: Amund Westin [mailto:am...@westin-emission.no]
Sent: Wednesday, March 20, 2013 1:44 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] SV: [PSES] RTTE - Radio product or not

Thanks!
I see the 'intended function'  ... Agree that Item A should be handled as a 
radio product.
But it will be hard to make compliance to radio standards since the product 
Item, A is only a part of a total radio systems. Radio parameters according to 
ETSI / EN standards will not be able to check before a complete systems (Item A 
+ B) is running. These parameters will not be able to check before the complete 
system is running.

Let me just comment that Item A is made by a single manufacturer and Item B is 
made by manufacturer B and there are many possible Item B's on the market. 
Testing out all possible configurations of Itema A + Item B is considered 
unacceptable, since it will cover 95% of configurations which never will be 
used and it would also cost a huge amount of $$.

Thanks.

#Amund




-Opprinnelig melding-
Fra: John Woodgate [mailto:j...@jmwa.demon.co.uk]
Sendt: 19. mars 2013 20:42
Til: EMC-PSTC@LISTSERV.IEEE.ORG
Emne: Re: [PSES] RTTE - Radio product or not

In message
3f0347ac6ed9504191f91f07629fbb0c01540...@thhsle14mbx2.hslive.net,
dated Tue, 19 Mar 2013, Charlie Blackham char...@sulisconsultants.com
writes:

Product B isn’t a radio without product A attached, therefore product A 
is part of a radio system and the RTTE Directive applies.

I would tentatively agree: in CENELEC long ago, the question was (half
seriously) raised as to whether a washing machine with a  microprocessor was a 
household appliance or ITE. The answer was  that the 'intended function' is 
definitive.

I think this can be extended to products like A and B, which are not intended 
to work alone but are components of a system. The 'intended function' of the 
system is a radio, so the component parts are 'radio'.
--
OOO - Own Opinions Only. See www.jmwa.demon.co.uk SHOCK HORROR! Dinosaur-like 
DNA found in chicken and turkey meals John Woodgate, J M Woodgate and 
Associates, Rayleigh, Essex UK

-

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David

Re: [PSES] SV: [PSES] SV: [PSES] RTTE - Radio product or not

In message 000b01ce2609$28d0d960$7a728c20$@no, dated Thu, 21 Mar 2013, 
Amund Westin am...@westin-emission.no writes:


Radio tests on one combination of A+B is approximate $10.000. So doing 
a reasonable number of combinations will be very costly. And we can run 
into problems that is caused by Item B's, which are made from other 
manufacturers ...


You have quoted several old messages unnecessarily, but you seem to have 
missed the most important one. Anthony Thomson wrote:


QUOTE
However… I guess it's entirely possible that any meaningful assessment 
against the RTTED may not be possible on the separate components 
assuming both are required to implement the ‘radio’. In this case, 
the Commission's 2009 guide offers some very helpful advice: “Where a 
radio system is integrated on site — as in the case of microwave 
point-to-point and point-to-multipoint systems — the system 
integrators responsible for ensuring compliance of the system with the 
Directive when the system is brought into service.”


So my opinion would be that each component of the system falls under the 
RTTED and it is the system integrator's responsibility for compliance.

ENDQUOTE

This means that manufacturer A need only ensure that product A meets the 
relevant requirements. Responsibility for making sure that combinations 
of A with B1, B2, B3... rests with the 'system integrators' who put the 
products to work together.

--
OOO - Own Opinions Only. See www.jmwa.demon.co.uk
SHOCK HORROR! Dinosaur-like DNA found in chicken and turkey meals
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

-

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Re: [PSES] SV: [PSES] RTTE - Radio product or not

2013-03-21 Thread Heckrotte, Michael

Amund,

This approach typically includes a set of design and/or installation guidelines 
and engineering justification as needed to establish a presumption of 
conformity with the Directive for the untested combinations. The reasonable 
number of tests, the number of full tests, the number of partial tests, and 
the particular guidelines are case-by-case and subject to discussion with and 
approval by the NB.

Best Regards,
Mike

-Original Message-
From: Amund Westin [mailto:am...@westin-emission.no]
Sent: Thursday, March 21, 2013 12:53 AM
To: Heckrotte, Michael; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: SV: [PSES] SV: [PSES] RTTE - Radio product or not

Mike

I see that approach.
Radio tests on one combination of A+B is approximate $10.000. So doing a 
reasonable number of combinations will be very costly. And we can run into 
problems that is caused by Item B's, which are made from other manufacturers ...

But we have done a successful test on Item A + B previously. We could measured 
the IF spectra on output port (coax cable) of old Item A model, and compared it 
with similar measurements (harmonics, spurious, freq. drift, etc) on the new 
Item A model. Then should at least the input signals to Item B be in the same 
range.

#Amund






-Opprinnelig melding-
Fra: Heckrotte, Michael [mailto:michael.heckro...@ul.com]
Sendt: 20. mars 2013 17:07
Til: EMC-PSTC@LISTSERV.IEEE.ORG
Emne: Re: [PSES] SV: [PSES] RTTE - Radio product or not

Amund,

Regarding your second paragraph, a cost-effective approach is to develop a Test 
Plan that specifies tests on a reasonable number of combinations, submit it to 
a Notified Body for review, then get the Notified Body Expert Opinion based on 
that plan and the test results.

Best Regards,
Mike

-Original Message-
From: Amund Westin [mailto:am...@westin-emission.no]
Sent: Wednesday, March 20, 2013 1:44 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] SV: [PSES] RTTE - Radio product or not

Thanks!
I see the 'intended function'  ... Agree that Item A should be handled as a 
radio product.
But it will be hard to make compliance to radio standards since the product 
Item, A is only a part of a total radio systems. Radio parameters according to 
ETSI / EN standards will not be able to check before a complete systems (Item A 
+ B) is running. These parameters will not be able to check before the complete 
system is running.

Let me just comment that Item A is made by a single manufacturer and Item B is 
made by manufacturer B and there are many possible Item B's on the market. 
Testing out all possible configurations of Itema A + Item B is considered 
unacceptable, since it will cover 95% of configurations which never will be 
used and it would also cost a huge amount of $$.

Thanks.

#Amund




-Opprinnelig melding-
Fra: John Woodgate [mailto:j...@jmwa.demon.co.uk]
Sendt: 19. mars 2013 20:42
Til: EMC-PSTC@LISTSERV.IEEE.ORG
Emne: Re: [PSES] RTTE - Radio product or not

In message
3f0347ac6ed9504191f91f07629fbb0c01540...@thhsle14mbx2.hslive.net,
dated Tue, 19 Mar 2013, Charlie Blackham char...@sulisconsultants.com
writes:

Product B isn’t a radio without product A attached, therefore product A
is part of a radio system and the RTTE Directive applies.

I would tentatively agree: in CENELEC long ago, the question was (half
seriously) raised as to whether a washing machine with a  microprocessor was a 
household appliance or ITE. The answer was  that the 'intended function' is 
definitive.

I think this can be extended to products like A and B, which are not intended 
to work alone but are components of a system. The 'intended function' of the 
system is a radio, so the component parts are 'radio'.
--
OOO - Own Opinions Only. See www.jmwa.demon.co.uk SHOCK HORROR! Dinosaur-like 
DNA found in chicken and turkey meals John Woodgate, J M Woodgate and 
Associates, Rayleigh, Essex UK

-

This message is from the IEEE Product Safety Engineering Society emc-pstc 
discussion list. To post a message to the list, send your e-mail to 
emc-p...@ieee.org

All emc-pstc postings are archived and searchable on the web at:
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Attachments are not permitted but the IEEE PSES Online Communities site at 
http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used 
formats), large files, etc.

Website:  http://www.ieee-pses.org/
Instructions:  http://listserv.ieee.org/request/user-guide.html
List rules: http://www.ieee-pses.org/listrules.html

For help, send mail to the list administrators:
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Mike Cantwell mcantw...@ieee.org

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David Heald: dhe...@gmail.com

-

This message is from the IEEE Product Safety Engineering Society emc-pstc 
discussion list. To post a message to the list, send your e

Re: [PSES] SV: [PSES] SV: [PSES] RTTE - Radio product or not

2013-03-21 Thread Charlie Blackham

Care must be taken when quoting from guidance documents.

The sentence Where a radio system is integrated on site — as in the case of 
microwave point-to-point and point-to-multipoint systems — the system 
integrator is responsible for ensuring compliance of the system with the 
Directive when the system is brought into service. Is in a section dealing 
with the integration of a unit with an antenna, it is not in the context of 
combining two or more boxes to form a radio transmitter or transceiver.

I suspect that a complete answer to this issue could only be given when knowing 
more detail as to the exact application of this device

Regards
Charlie



-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk] 
Sent: 21 March 2013 08:41
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] SV: [PSES] SV: [PSES] RTTE - Radio product or not

In message 000b01ce2609$28d0d960$7a728c20$@no, dated Thu, 21 Mar 2013, Amund 
Westin am...@westin-emission.no writes:

Radio tests on one combination of A+B is approximate $10.000. So doing 
a reasonable number of combinations will be very costly. And we can run 
into problems that is caused by Item B's, which are made from other 
manufacturers ...

You have quoted several old messages unnecessarily, but you seem to have missed 
the most important one. Anthony Thomson wrote:

QUOTE
However… I guess it's entirely possible that any meaningful assessment against 
the RTTED may not be possible on the separate components assuming both are 
required to implement the ‘radio’. In this case, the Commission's 2009 guide 
offers some very helpful advice: “Where a radio system is integrated on site — 
as in the case of microwave point-to-point and point-to-multipoint systems — 
the system integrators responsible for ensuring compliance of the system with 
the Directive when the system is brought into service.”

So my opinion would be that each component of the system falls under the RTTED 
and it is the system integrator's responsibility for compliance.
ENDQUOTE

This means that manufacturer A need only ensure that product A meets the 
relevant requirements. Responsibility for making sure that combinations of A 
with B1, B2, B3... rests with the 'system integrators' who put the products to 
work together.
--
OOO - Own Opinions Only. See www.jmwa.demon.co.uk SHOCK HORROR! Dinosaur-like 
DNA found in chicken and turkey meals John Woodgate, J M Woodgate and 
Associates, Rayleigh, Essex UK

-

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All emc-pstc postings are archived and searchable on the web at:
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-

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All emc-pstc postings are archived and searchable on the web at:
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Re: [PSES] SV: [PSES] SV: [PSES] RTTE - Radio product or not

In message 
3f0347ac6ed9504191f91f07629fbb0c01542...@thhsle14mbx2.hslive.net, 
dated Thu, 21 Mar 2013, Charlie Blackham char...@sulisconsultants.com 
writes:


The sentence Where a radio system is integrated on site — as in the 
case of microwave point-to-point and point-to-multipoint systems — 
the system integrator is responsible for ensuring compliance of the 
system with the Directive when the system is brought into service. Is 
in a section dealing with the integration of a unit with an antenna, it 
is not in the context of combining two or more boxes to form a radio 
transmitter or transceiver.


But that's exactly what it is. How A and B are connected together is 
surely site-dependent, because there is not just one possible B. And the 
length and quality of the interconnecting cables are influential.

--
OOO - Own Opinions Only. See www.jmwa.demon.co.uk
SHOCK HORROR! Dinosaur-like DNA found in chicken and turkey meals
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

-

This message is from the IEEE Product Safety Engineering Society emc-pstc discussion 
list. To post a message to the list, send your e-mail to emc-p...@ieee.org

All emc-pstc postings are archived and searchable on the web at:
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Jim Bacher:  j.bac...@ieee.org
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Re: [PSES] SV: [PSES] SV: [PSES] RTTE - Radio product or not

2013-03-21 Thread Charlie Blackham

Section 1.3.1 of the guidance document, that contains this phrase, discusses 
whether or not antennas are covered by the RTTE Directive.



Point to point systems are integrated on site with an antenna, but that antenna 
must (typically) comply with certain requirements that may include gain and 
aspects of antenna pattern. For some equipment they must use antennas that are 
covered by other Harmonised Standards. The antenna gain will also affect other 
aspects such as article 3.1a EMF compliance which is another aspect that the 
final system integrator must consider.



This particular product in question contains two separate and active parts with 
part B containing a frequency conversion and amplification stage. Correct 
consideration of the application of the RTTE Directive to this device cannot 
be taken from a section discussing correct choice of antenna.



Regards

Charlie



-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk]
Sent: 21 March 2013 17:27
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] SV: [PSES] SV: [PSES] RTTE - Radio product or not



In message

3f0347ac6ed9504191f91f07629fbb0c01542...@thhsle14mbx2.hslive.netmailto:3f0347ac6ed9504191f91f07629fbb0c01542...@thhsle14mbx2.hslive.net,

dated Thu, 21 Mar 2013, Charlie Blackham 
char...@sulisconsultants.commailto:char...@sulisconsultants.com

writes:



The sentence Where a radio system is integrated on site — as in the

case of microwave point-to-point and point-to-multipoint systems — the

system integrator is responsible for ensuring compliance of the system

with the Directive when the system is brought into service. Is in a

section dealing with the integration of a unit with an antenna, it is

not in the context of combining two or more boxes to form a radio

transmitter or transceiver.



But that's exactly what it is. How A and B are connected together is surely 
site-dependent, because there is not just one possible B. And the length and 
quality of the interconnecting cables are influential.

--

OOO - Own Opinions Only. See www.jmwa.demon.co.ukhttp://www.jmwa.demon.co.uk 
SHOCK HORROR! Dinosaur-like DNA found in chicken and turkey meals John 
Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK



-



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discussion list. To post a message to the list, send your e-mail to 
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formats), large files, etc.



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List rules: http://www.ieee-pses.org/listrules.html



For help, send mail to the list administrators:

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All emc-pstc postings are archived and searchable on the web at:
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Re: [PSES] SV: [PSES] SV: [PSES] RTTE - Radio product or not

In message 
3f0347ac6ed9504191f91f07629fbb0c01542...@thhsle14mbx2.hslive.net, 
dated Thu, 21 Mar 2013, Charlie Blackham char...@sulisconsultants.com 
writes:




Section 1.3.1 of the guidance document, that contains this phrase, 
discusses whether or not antennas are covered by the RTTE Directive.


I haven't any idea of what useful point you are making, if any. I think 
you are indulging in pointless debate. If I'm wrong, please explain why 
you think that whoever puts product A together with Product B (or B1, 
B2, B3 etc.) to make a working system is not responsible for the 
system's conformity with the RTTED.

--
OOO - Own Opinions Only. See www.jmwa.demon.co.uk
SHOCK HORROR! Dinosaur-like DNA found in chicken and turkey meals
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

-

This message is from the IEEE Product Safety Engineering Society emc-pstc discussion 
list. To post a message to the list, send your e-mail to emc-p...@ieee.org

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Re: [PSES] SV: [PSES] SV: [PSES] RTTE - Radio product or not

2013-03-21 Thread Charlie Blackham

John



You previously wrote:

{begin quote}



You have quoted several old messages unnecessarily, but you seem to have missed 
the most important one. Anthony Thomson wrote:



QUOTE

However... I guess it's entirely possible that any meaningful assessment 
against the RTTED may not be possible on the separate components assuming both 
are required to implement the 'radio'. In this case, the Commission's 2009 
guide offers some very helpful advice: Where a radio system is integrated on 
site - as in the case of microwave point-to-point and point-to-multipoint 
systems - the system integrators responsible for ensuring compliance of the 
system with the Directive when the system is brought into service.



So my opinion would be that each component of the system falls under the RTTED 
and it is the system integrator's responsibility for compliance.

ENDQUOTE



This means that manufacturer A need only ensure that product A meets the 
relevant requirements. Responsibility for making sure that combinations of A 
with B1, B2, B3... rests with the 'system integrators' who put the products to 
work together.



{end quote]



My point is that you were, perhaps inadvertently, citing a section talking 
about antennas as guidance for how to deal with Product A and Product B 
scenario.



Regards

Charlie





-Original Message-,
From: John Woodgate [mailto:j...@jmwa.demon.co.uk]
Sent: 21 March 2013 18:42
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] SV: [PSES] SV: [PSES] RTTE - Radio product or not



In message

3f0347ac6ed9504191f91f07629fbb0c01542...@thhsle14mbx2.hslive.netmailto:3f0347ac6ed9504191f91f07629fbb0c01542...@thhsle14mbx2.hslive.net,

dated Thu, 21 Mar 2013, Charlie Blackham 
char...@sulisconsultants.commailto:char...@sulisconsultants.com

writes:





Section 1.3.1 of the guidance document, that contains this phrase,

discusses whether or not antennas are covered by the RTTE Directive.



I haven't any idea of what useful point you are making, if any. I think you are 
indulging in pointless debate. If I'm wrong, please explain why you think that 
whoever puts product A together with Product B (or B1, B2, B3 etc.) to make a 
working system is not responsible for the system's conformity with the RTTED.

--

OOO - Own Opinions Only. See www.jmwa.demon.co.ukhttp://www.jmwa.demon.co.uk 
SHOCK HORROR! Dinosaur-like DNA found in chicken and turkey meals John 
Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK



-



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discussion list. To post a message to the list, send your e-mail to 
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All emc-pstc postings are archived and searchable on the web at:

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Attachments are not permitted but the IEEE PSES Online Communities site at 
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Re: [PSES] SV: [PSES] SV: [PSES] RTTE - Radio product or not

2013-03-20 Thread ce-test, qualified testing bv - Gert Gremmen

In message 
3f0347ac6ed9504191f91f07629fbb0c01542...@thhsle14mbx2.hslive.net, 
dated Thu, 21 Mar 2013, Charlie Blackham char...@sulisconsultants.com 
writes:




My point is that you were, perhaps inadvertently, citing a section 
talking about antennas as guidance for how to deal with Product A and 
Product B scenario.


OK, now I understand. In my opinion, the *general* statement:

Where a radio system is integrated on site - as in the case of microwave 
point-to-point and point-to-multipoint systems - the system integrators 
responsible for ensuring compliance of the system with the Directive 
when the system is brought into service.


applies precisely to the A + B1, B2, B3... case, irrespective of 
appearing in a section on antennas. Since the A and the alternative B's 
are from different manufacturers, it's most likely that they would be 
brought together and connected on site, but the same applies if they are 
brought together elsewhere by the system integrator.

--
OOO - Own Opinions Only. See www.jmwa.demon.co.uk
SHOCK HORROR! Dinosaur-like DNA found in chicken and turkey meals
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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[PSES] SV: [PSES] RTTE - Radio product or not

2013-03-20 Thread Amund Westin

Product A contains some fundamental radio parameters that you have mention 
(modulation, demodulation) and probably some others as well such as Frequency 
accuracy/stability. Does it offer any useful functionality without being 
connected to B?

 

==  Yes, even though it’s not possible to verify all radio parameters because 
Item B is missing, it should be possible to check some relevant requirements in 
the ETSI/EN 301 XXX standards on the TX/RX ports of Item A.

==  No, Item A doesn’t have any functionality when Item B is missing.

 

 

 

Regards

Amund

 

Fra: Charlie Blackham [mailto:char...@sulisconsultants.com] 
Sendt: 19. mars 2013 20:12
Til: amund; EMC-PSTC@LISTSERV.IEEE.ORG
Emne: RE: [PSES] RTTE - Radio product or not

 

Amund

 

I’d look at it the other way around:

 

Product B isn’t a radio without product A attached, therefore product A is part 
of a radio system and the RTTE Directive applies.

 

Product A contains some fundamental radio parameters that you have mention 
(modulation, demodulation) and probably some others as well such as Frequency 
accuracy/stability. Does it offer any useful functionality without being 
connected to B?

 

(some other regulatory regimes often only require “certification” of the bit 
that actually “transmits”, but the RTTE directive is a bit different)

 

Regards

Charlie

 

 

From: Amund Westin [mailto:am...@westin-emission.no] 
Sent: 19 March 2013 10:41
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] RTTE - Radio product or not

 

Item A: Processing unit. Connection to PC and LAN (not directly to telecom 
network). Radio modulator  demodulator. Output radio signal 800MHz / 0dbm on 
cable to Item B.

Item B: Upconverter to 10GHz and High Power Amplifier and antenna

 

Item A and B together is a complete radio system and RTTE apply.

 

Item A stand-alone: I would say that it’s not a radio product since it does not 
transmit / receive to space. The radio signals (TX and RX) in on the cable to 
Item B and could be categorized as a signal line. LAN connection is not 
directly coupled to public telecom network. RTTE will not apply, that’s my 
opinion. The system integrator (Item A + B) will put his system into use and 
should be responsible for fulfilling RTTE.

 

Folks, do you agree?

 

 

Cheers,

Amund  

 

PS: 

From RTTE guidelines: Telecommunications terminal equipment is defined as a 
product enabling communication or a relevant component thereof which is 
intended to be connected directly or indirectly by any means

 

The wording “indirect” makes maybe Item A to a telecom terminal equipment ….

 

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[PSES] SV: [PSES] RTTE - Radio product or not

2013-03-20 Thread Amund Westin

Thanks!
I see the 'intended function'  ... Agree that Item A should be handled as a 
radio product.
But it will be hard to make compliance to radio standards since the product 
Item, A is only a part of a total radio systems. Radio parameters according to 
ETSI / EN standards will not be able to check before a complete systems (Item A 
+ B) is running. These parameters will not be able to check before the complete 
system is running.

Let me just comment that Item A is made by a single manufacturer and Item B is 
made by manufacturer B and there are many possible Item B's on the market. 
Testing out all possible configurations of Itema A + Item B is considered 
unacceptable, since it will cover 95% of configurations which never will be 
used and it would also cost a huge amount of $$.

Thanks.

#Amund 




-Opprinnelig melding-
Fra: John Woodgate [mailto:j...@jmwa.demon.co.uk] 
Sendt: 19. mars 2013 20:42
Til: EMC-PSTC@LISTSERV.IEEE.ORG
Emne: Re: [PSES] RTTE - Radio product or not

In message
3f0347ac6ed9504191f91f07629fbb0c01540...@thhsle14mbx2.hslive.net,
dated Tue, 19 Mar 2013, Charlie Blackham char...@sulisconsultants.com
writes:

Product B isn’t a radio without product A attached, therefore product A 
is part of a radio system and the RTTE Directive applies.

I would tentatively agree: in CENELEC long ago, the question was (half
seriously) raised as to whether a washing machine with a  microprocessor was a 
household appliance or ITE. The answer was  that the 'intended function' is 
definitive.

I think this can be extended to products like A and B, which are not intended 
to work alone but are components of a system. The 'intended function' of the 
system is a radio, so the component parts are 'radio'.
--
OOO - Own Opinions Only. See www.jmwa.demon.co.uk SHOCK HORROR! Dinosaur-like 
DNA found in chicken and turkey meals John Woodgate, J M Woodgate and 
Associates, Rayleigh, Essex UK

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Re: [PSES] RTTE - Radio product or not

2013-03-20 Thread Anthony Thomson

Amund,
The definition of radio equipment in the context of the directive is quite 
clear: “radio equipment means a product, or relevant component thereof, 
capable of communication by means of the emission and/or reception of radio 
waves utilising the spectrum allocated to terrestrial/space radiocommunication;”
I think therefore it is clear that system components A  B fall under the 
RTTED.
However… I guess it’s entirely possible that any meaningful assessment against 
the RTTED may not be possible on the separate components assuming both are 
required to implement the ‘radio’. In this case, the Commission’s 2009 guide 
offers some very helpful advice: “Where a radio system is integrated on site — 
as in the case of microwave point-to-point and point-to-multipoint systems — 
the system integrators responsible for ensuring compliance of the system with 
the Directive when the system is brought into service.”
So my opinion would be that each component of the system falls under the RTTED 
and it is the system integrator’s responsibility for compliance.
Just my ‘two-penneth’.
T
- Original Message -
From: Amund Westin
Sent: 03/19/13 10:41 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] RTTE - Radio product or not

Item A: Processing unit. Connection to PC and LAN (not directly to telecom 
network). Radio modulator  demodulator. Output radio signal 800MHz / 0dbm on 
cable to Item B.
Item B: Upconverter to 10GHz and High Power Amplifier and antenna
Item A and B together is a complete radio system and RTTE apply.
Item A stand-alone: I would say that it’s not a radio product since it does not 
transmit / receive to space. The radio signals (TX and RX) in on the cable to 
Item B and could be categorized as a signal line. LAN connection is not 
directly coupled to public telecom network. RTTE will not apply, that’s my 
opinion. The system integrator (Item A + B) will put his system into use and 
should be responsible for fulfilling RTTE.
Folks, do you agree?
Cheers,
Amund 
PS: 
From RTTE guidelines: Telecommunications terminal equipment is defined as a 
product enabling communication or a relevant component thereof which is 
intended to be connected directly or  *indirectly by any means
The wording “indirect” makes maybe Item A to a telecom terminal equipment ….

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Re: [PSES] RTTE - Radio product or not

I remember this ground radar, that I had for testing a

number of years ago, operating by sending an ground impulse with an antenna 
that 

was shielded upwards, followed by receiving

that echo from the ground.

 

From different authorities, I got different responses onto the applicability

of the RTTD or EMC directive.

 

Using the  definition 

:  “ radio equipment means a product, or relevant component thereof, capable 
of communication by means of the emission and/or reception of radio waves 
utilising the spectrum allocated to terrestrial/space radiocommunication;”

created even more problems, as the question rose if the soil is part of the 
space

allocate for radio communication.

 

The device was so well constructed , that it passed Class A emissions, but some 
authorities

(notably the Swiss) insisted on applying the RTTE directive, and wanted the 
device to be

classified in terms of frequency use, modulation method and used bandwidth (and 
more)

and finally decided to refuse it’s use on Swiss soil.

 

Regards,

Ing.  Gert Gremmen, BSc

 

 

 

g.grem...@cetest.nl mailto:g.grem...@cetest.nl 

www.cetest.nl


Kiotoweg 363

3047 BG Rotterdam

T 31(0)104152426
F 31(0)104154953

Before printing, think about the environment. 

 

 

Van: emc-p...@ieee.org [mailto:emc-p...@ieee.org] Namens Anthony Thomson
Verzonden: Wednesday, March 20, 2013 10:29 AM
Aan: EMC-PSTC@LISTSERV.IEEE.ORG
Onderwerp: Re: [PSES] RTTE - Radio product or not

 

Amund,

 

The definition of radio equipment in the context of the directive is quite 
clear:  “ radio equipment means a product, or relevant component thereof, 
capable of communication by means of the emission and/or reception of radio 
waves utilising the spectrum allocated to terrestrial/space radiocommunication;”

 

I think therefore it is clear that system components A  B fall under the 
RTTED.

 

However… I guess it’s entirely possible that any meaningful assessment against 
the RTTED may not be possible on the separate components assuming both are 
required to implement the ‘radio’.  In this case, the Commission’s 2009 guide 
offers some very helpful advice: “Where a radio system is integrated on site — 
as in the case of microwave point-to-point and point-to-multipoint systems — 
the system integrators responsible for ensuring compliance of the system with 
the Directive when the system is brought into service.”

 

So my opinion would be that each component of the system falls under the RTTED 
and it is the system integrator’s responsibility for compliance.

 

Just my ‘two-penneth’.

 

T

 

- Original Message -

From: Amund Westin

Sent: 03/19/13 10:41 AM

To: EMC-PSTC@LISTSERV.IEEE.ORG

Subject: [PSES] RTTE - Radio product or not

 

Item A: Processing unit. Connection to PC and LAN (not directly to 
telecom network). Radio modulator  demodulator. Output radio signal 800MHz / 
0dbm on cable to Item B.

 

Item B: Upconverter to 10GHz and High Power Amplifier and antenna

 

Item A and B together is a complete radio system and RTTE apply.

 

Item A stand-alone: I would say that it’s not a radio product since it 
does not transmit / receive to space. The radio signals (TX and RX) in on the 
cable to Item B and could be categorized as a signal line. LAN connection is 
not directly coupled to public telecom network. RTTE will not apply, that’s my 
opinion. The system integrator (Item A + B) will put his system into use and 
should be responsible for fulfilling RTTE.

 

Folks, do you agree?

 

Cheers,

 

Amund  

 

 

 

 

 

PS: 

 

 

From RTTE guidelines: Telecommunications terminal equipment is defined 
as a product enabling communication or a relevant component thereof which is 
intended to be connected directly or indirectly by any means

 

 

 

 

 

The wording “indirect” makes maybe Item A to a telecom terminal 
equipment ….

 

 

 

 

 

-


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Re: [PSES] RTTE - Radio product or not

2013-03-20 Thread John Woodgate

In message FCA549BE3ECF9D4CB8CB8576837EA489140DAA@ZEUS.cetest.local, 
dated Wed, 20 Mar 2013, ce-test, qualified testing bv - Gert Gremmen 
g.grem...@cetest.nl writes:



and finally decided to refuse it’s use on Swiss soil.


Well, they haven't got much; Switzerland is mostly rock.

Seriously, it is surprising that dinosaurs survive there.

Ground radar is *essentially* terrestrial.
--
OOO - Own Opinions Only. See www.jmwa.demon.co.uk
SHOCK HORROR! Dinosaur-like DNA found in chicken and turkey meals
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

-

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Re: [PSES] RTTE - Radio product or not

2013-03-20 Thread Charlie Blackham

Gert

You don’t say how long ago this was, but Ground Penetrating Radar is (now) 
covered by RTTE, as detailed in ERC recommendation 70-03, and ETSI EN 302 
066-2.

Regards
Charlie


From: ce-test, qualified testing bv - Gert Gremmen [mailto:g.grem...@cetest.nl]
Sent: 20 March 2013 12:25
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] RTTE - Radio product or not

I remember this ground radar, that I had for testing a
number of years ago, operating by sending an ground impulse with an antenna that
was shielded upwards, followed by receiving
that echo from the ground.

From different authorities, I got different responses onto the applicability
of the RTTD or EMC directive.

Using the  definition
:  “ radio equipment means a product, or relevant component thereof, capable 
of communication by means of the emission and/or reception of radio waves 
utilising the spectrum allocated to terrestrial/space radiocommunication;”
created even more problems, as the question rose if the soil is part of the 
space
allocate for radio communication.

The device was so well constructed , that it passed Class A emissions, but some 
authorities
(notably the Swiss) insisted on applying the RTTE directive, and wanted the 
device to be
classified in terms of frequency use, modulation method and used bandwidth (and 
more)
and finally decided to refuse it’s use on Swiss soil.

Regards,

Ing.  Gert Gremmen, BSc



g.grem...@cetest.nlmailto:g.grem...@cetest.nl
www.cetest.nl

Kiotoweg 363
3047 BG Rotterdam
T 31(0)104152426
F 31(0)104154953
Before printing, think about the environment.


Van: emc-p...@ieee.orgmailto:emc-p...@ieee.org [mailto:emc-p...@ieee.org] 
Namens Anthony Thomson
Verzonden: Wednesday, March 20, 2013 10:29 AM
Aan: EMC-PSTC@LISTSERV.IEEE.ORGmailto:EMC-PSTC@LISTSERV.IEEE.ORG
Onderwerp: Re: [PSES] RTTE - Radio product or not

Amund,

The definition of radio equipment in the context of the directive is quite 
clear:  “ radio equipment means a product, or relevant component thereof, 
capable of communication by means of the emission and/or reception of radio 
waves utilising the spectrum allocated to terrestrial/space radiocommunication;”

I think therefore it is clear that system components A  B fall under the 
RTTED.

However… I guess it’s entirely possible that any meaningful assessment against 
the RTTED may not be possible on the separate components assuming both are 
required to implement the ‘radio’.  In this case, the Commission’s 2009 guide 
offers some very helpful advice: “Where a radio system is integrated on site — 
as in the case of microwave point-to-point and point-to-multipoint systems — 
the system integrators responsible for ensuring compliance of the system with 
the Directive when the system is brought into service.”

So my opinion would be that each component of the system falls under the RTTED 
and it is the system integrator’s responsibility for compliance.

Just my ‘two-penneth’.

T



- Original Message -

From: Amund Westin

Sent: 03/19/13 10:41 AM

To: EMC-PSTC@LISTSERV.IEEE.ORGmailto:EMC-PSTC@LISTSERV.IEEE.ORG

Subject: [PSES] RTTE - Radio product or not

Item A: Processing unit. Connection to PC and LAN (not directly to telecom 
network). Radio modulator  demodulator. Output radio signal 800MHz / 0dbm on 
cable to Item B.


Item B: Upconverter to 10GHz and High Power Amplifier and antenna


Item A and B together is a complete radio system and RTTE apply.


Item A stand-alone: I would say that it’s not a radio product since it does not 
transmit / receive to space. The radio signals (TX and RX) in on the cable to 
Item B and could be categorized as a signal line. LAN connection is not 
directly coupled to public telecom network. RTTE will not apply, that’s my 
opinion. The system integrator (Item A + B) will put his system into use and 
should be responsible for fulfilling RTTE.


Folks, do you agree?


Cheers,


Amund









PS:




From RTTE guidelines: Telecommunications terminal equipment is defined as a 
product enabling communication or a relevant component thereof which is 
intended to be connected directly or indirectly by any means









The wording “indirect” makes maybe Item A to a telecom terminal equipment ….










-


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discussion list. To post a message to the list, send your e-mail to 
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Re: [PSES] SV: [PSES] RTTE - Radio product or not

2013-03-20 Thread Heckrotte, Michael

Amund,

Regarding your second paragraph, a cost-effective approach is to develop a Test 
Plan that specifies tests on a reasonable number of combinations, submit it to 
a Notified Body for review, then get the Notified Body Expert Opinion based on 
that plan and the test results.

Best Regards,
Mike

-Original Message-
From: Amund Westin [mailto:am...@westin-emission.no]
Sent: Wednesday, March 20, 2013 1:44 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] SV: [PSES] RTTE - Radio product or not

Thanks!
I see the 'intended function'  ... Agree that Item A should be handled as a 
radio product.
But it will be hard to make compliance to radio standards since the product 
Item, A is only a part of a total radio systems. Radio parameters according to 
ETSI / EN standards will not be able to check before a complete systems (Item A 
+ B) is running. These parameters will not be able to check before the complete 
system is running.

Let me just comment that Item A is made by a single manufacturer and Item B is 
made by manufacturer B and there are many possible Item B's on the market. 
Testing out all possible configurations of Itema A + Item B is considered 
unacceptable, since it will cover 95% of configurations which never will be 
used and it would also cost a huge amount of $$.

Thanks.

#Amund




-Opprinnelig melding-
Fra: John Woodgate [mailto:j...@jmwa.demon.co.uk]
Sendt: 19. mars 2013 20:42
Til: EMC-PSTC@LISTSERV.IEEE.ORG
Emne: Re: [PSES] RTTE - Radio product or not

In message
3f0347ac6ed9504191f91f07629fbb0c01540...@thhsle14mbx2.hslive.net,
dated Tue, 19 Mar 2013, Charlie Blackham char...@sulisconsultants.com
writes:

Product B isn’t a radio without product A attached, therefore product A
is part of a radio system and the RTTE Directive applies.

I would tentatively agree: in CENELEC long ago, the question was (half
seriously) raised as to whether a washing machine with a  microprocessor was a 
household appliance or ITE. The answer was  that the 'intended function' is 
definitive.

I think this can be extended to products like A and B, which are not intended 
to work alone but are components of a system. The 'intended function' of the 
system is a radio, so the component parts are 'radio'.
--
OOO - Own Opinions Only. See www.jmwa.demon.co.uk SHOCK HORROR! Dinosaur-like 
DNA found in chicken and turkey meals John Woodgate, J M Woodgate and 
Associates, Rayleigh, Essex UK

-

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[PSES] RTTE - Radio product or not

2013-03-19 Thread Amund Westin

Item A: Processing unit. Connection to PC and LAN (not directly to telecom 
network). Radio modulator  demodulator. Output radio signal 800MHz / 0dbm on 
cable to Item B.

Item B: Upconverter to 10GHz and High Power Amplifier and antenna

 

Item A and B together is a complete radio system and RTTE apply.

 

Item A stand-alone: I would say that it’s not a radio product since it does not 
transmit / receive to space. The radio signals (TX and RX) in on the cable to 
Item B and could be categorized as a signal line. LAN connection is not 
directly coupled to public telecom network. RTTE will not apply, that’s my 
opinion. The system integrator (Item A + B) will put his system into use and 
should be responsible for fulfilling RTTE.

 

Folks, do you agree?

 

 

Cheers,

Amund  

 

PS: 

From RTTE guidelines: Telecommunications terminal equipment is defined as a 
product enabling communication or a relevant component thereof which is 
intended to be connected directly or indirectly by any means

 

The wording “indirect” makes maybe Item A to a telecom terminal equipment ….

 


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Re: [PSES] RTTE - Radio product or not

2013-03-19 Thread Charlie Blackham

Amund

I’d look at it the other way around:

Product B isn’t a radio without product A attached, therefore product A is part 
of a radio system and the RTTE Directive applies.

Product A contains some fundamental radio parameters that you have mention 
(modulation, demodulation) and probably some others as well such as Frequency 
accuracy/stability. Does it offer any useful functionality without being 
connected to B?

(some other regulatory regimes often only require “certification” of the bit 
that actually “transmits”, but the RTTE directive is a bit different)

Regards
Charlie


From: Amund Westin [mailto:am...@westin-emission.no]
Sent: 19 March 2013 10:41
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] RTTE - Radio product or not

Item A: Processing unit. Connection to PC and LAN (not directly to telecom 
network). Radio modulator  demodulator. Output radio signal 800MHz / 0dbm on 
cable to Item B.
Item B: Upconverter to 10GHz and High Power Amplifier and antenna

Item A and B together is a complete radio system and RTTE apply.

Item A stand-alone: I would say that it’s not a radio product since it does not 
transmit / receive to space. The radio signals (TX and RX) in on the cable to 
Item B and could be categorized as a signal line. LAN connection is not 
directly coupled to public telecom network. RTTE will not apply, that’s my 
opinion. The system integrator (Item A + B) will put his system into use and 
should be responsible for fulfilling RTTE.

Folks, do you agree?


Cheers,
Amund

PS:
From RTTE guidelines: Telecommunications terminal equipment is defined as a 
product enabling communication or a relevant component thereof which is 
intended to be connected directly or indirectly by any means

The wording “indirect” makes maybe Item A to a telecom terminal equipment ….

-


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Re: [PSES] RTTE - Radio product or not

2013-03-19 Thread John Woodgate

In message 
3f0347ac6ed9504191f91f07629fbb0c01540...@thhsle14mbx2.hslive.net, 
dated Tue, 19 Mar 2013, Charlie Blackham char...@sulisconsultants.com 
writes:


Product B isn’t a radio without product A attached, therefore product 
A is part of a radio system and the RTTE Directive applies.


I would tentatively agree: in CENELEC long ago, the question was (half 
seriously) raised as to whether a washing machine with a  microprocessor 
was a household appliance or ITE. The answer was  that the 'intended 
function' is definitive.


I think this can be extended to products like A and B, which are not 
intended to work alone but are components of a system. The 'intended 
function' of the system is a radio, so the component parts are 'radio'.

--
OOO - Own Opinions Only. See www.jmwa.demon.co.uk
SHOCK HORROR! Dinosaur-like DNA found in chicken and turkey meals
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

-

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Re: [PSES] Recast of RTTE directive

2013-02-27 Thread Pat Lawler

So, would having a DoC with a unique device ID imply the specific
device was tested to the standards listed - 100% production testing?
That would be cost prohibitive, not to mention degrading product
reliability in the case of line surge immunity testing.

Is there something in the recast that clarifies that a DoC with a
unique device ID doesn't mean the device was actually tested (aside
from normal production safety testing)?

Pat

On Mon, Feb 25, 2013 at 7:11 PM, Scott Douglas sdoug...@radiusnorth.net wrote:
 I can tell you that trying to make a unique DofC for each individual unit
 serial number is absolutely unworkable. Not to mention a documentation and
 logistics nightmare.

 So who do we complain to about having a unique DofC for each specific
 product? How do we get our voices heard?

 Scott


 On 2/25/2013 8:30 AM, John Woodgate wrote:

 In message
 617eb8c8634c9149aa66c853d7b8ac53040e3...@by2prd0310mb389.namprd03.prod.o
 utlook.com, dated Mon, 25 Feb 2013, Crane, Lauren
 lauren.cr...@kla-tencor.com writes:

 John, since you ask...(but perhaps you only meant the re-scoping)...


 I did mean the re-scoping.


 The RTTE recast is also be stepping forward with the unique equipment
 number requirement in the DoC which seems to require 1 DoC per unit (rather
 than 1 DoC per model line).


 AARGH!!!


 As I've mentioned in a previous post, this is also appearing in the LVD
 recast, though 1 parliamentarian (Zuzana Roithová) is trying to change the
 impact of this DoC requirements point 1 to be a unique identifier for the
 DoC document itself.


 I hope that industry in ALL countries will strongly object to this
 impractical AND ineffective provision.

 A non-compliant product can just as easily be supplied with a DoC carrying
 a serial number as a compliant product can (even though that is not at all
 easy in practice).


 -
 
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Re: [PSES] Recast of RTTE directive

2013-02-27 Thread Ron Pickard

I've followed this thread and am concerned that such an action would constitute 
and introduce a significant barrier to trade, which is contrary to the intent 
of the scheme of the new approach directives, is it not?

Best regards,

Ron Pickard
Sent from my  Android phone

 Original message 
From: Pat Lawler plawl...@gmail.com 
Date:  
To: EMC-PSTC@LISTSERV.IEEE.ORG 
Subject: Re: [PSES] Recast of RTTE directive 
 
So, would having a DoC with a unique device ID imply the specific
device was tested to the standards listed - 100% production testing?
That would be cost prohibitive, not to mention degrading product
reliability in the case of line surge immunity testing.

Is there something in the recast that clarifies that a DoC with a
unique device ID doesn't mean the device was actually tested (aside
from normal production safety testing)?

Pat

On Mon, Feb 25, 2013 at 7:11 PM, Scott Douglas sdoug...@radiusnorth.net wrote:
 I can tell you that trying to make a unique DofC for each individual unit
 serial number is absolutely unworkable. Not to mention a documentation and
 logistics nightmare.

 So who do we complain to about having a unique DofC for each specific
 product? How do we get our voices heard?

 Scott


 On 2/25/2013 8:30 AM, John Woodgate wrote:

 In message
 617eb8c8634c9149aa66c853d7b8ac53040e3...@by2prd0310mb389.namprd03.prod.o
 utlook.com, dated Mon, 25 Feb 2013, Crane, Lauren
 lauren.cr...@kla-tencor.com writes:

 John, since you ask...(but perhaps you only meant the re-scoping)...


 I did mean the re-scoping.


 The RTTE recast is also be stepping forward with the unique equipment
 number requirement in the DoC which seems to require 1 DoC per unit (rather
 than 1 DoC per model line).


 AARGH!!!


 As I've mentioned in a previous post, this is also appearing in the LVD
 recast, though 1 parliamentarian (Zuzana Roithová) is trying to change the
 impact of this DoC requirements point 1 to be a unique identifier for the
 DoC document itself.


 I hope that industry in ALL countries will strongly object to this
 impractical AND ineffective provision.

 A non-compliant product can just as easily be supplied with a DoC carrying
 a serial number as a compliant product can (even though that is not at all
 easy in practice).


 -
 
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 discussion list. To post a message to the list, send your e-mail to
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[PSES] DoC Point 1 update regarding LVD RTTE recasts

2013-02-27 Thread Crane, Lauren

I received a nice response from Ms. Roithova (the parliamentarian who proposed
a change to point 1 language in the LVD recast). She says the LVD recast
language has been changed in negotiations and the current version does not
mention unique identification. So the problem may be solved for the LVD
recast, but not for the necessarily for the RTTE recast.

Ref
http://www.europarl.europa.eu/oeil/popups/ficheprocedure.do?lang=enreference=2012/0283(COD)
if you would like to learn the name of the Parliamentary Rapporteur and
Shadow Rapporteurs or the Commission officer for the RTTE recast. You could
send them an email voicing your concern about this point (if you have one).

Regards,
Lauren

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Re: [PSES] Recast of RTTE directive

In message 512c27c6.4020...@radiusnorth.net, dated Mon, 25 Feb 2013, 
Scott Douglas sdoug...@radiusnorth.net writes:


So who do we complain to about having a unique DofC for each specific 
product? How do we get our voices heard?


Contact your National Standards body, (i.e. ANSI, CSI, DIN, BSI...) and 
persevere until you find someone who understands what you are talking 
about and knows what to do about it.

--
OOO - Own Opinions Only. See www.jmwa.demon.co.uk
SHOCK HORROR! Dinosaur-like DNA found in chicken and turkey meals
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

-

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Re: [PSES] Recast of RTTE directive

2013-02-26 Thread Anthony Thomson

I’m with Scott on this and I appreciate John’s advice about canvassing one's 
relevant National Standards body.
However, I would like to understand who is driving and supporting the 
rquirement for uniquely serialised DoC’s and their motives and rationale behind 
the requirement. Because at the moment, from my perspective, whoever is doing 
so is demonstrating a worrying and total lack of understanding regarding the 
products, consumer market, distribution and manufacturing of the vast majority 
(95% at a guess) of products falling under the scope of the RTTE and its 
recast.
Non RTTE compliant product is already prolific enough without adding even more 
barriers to compliance, ESPECIALLY with regards to Administrative Complaince. 
Technical Compliance and the enforement thereof must be the main focus. After 
all, the marking on the packaging or documentation does not affect the 
operation and co-existance of my electronics one iota, spurious emissions or a 
modest lack of immunity to environmental influences does however.
So who is driving and supporting the requirement for uniquely serialised DoC's 
and what is their technical and economical justification for doing so. Or shall 
we just do the sensible thing and drop this daft requirement. 
T
- Original Message -
From: John Woodgate
Sent: 02/26/13 08:41 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Recast of RTTE directive

In message 512c27c6.4020...@radiusnorth.net, dated Mon, 25 Feb 2013, Scott 
Douglas sdoug...@radiusnorth.net writes: So who do we complain to about 
having a unique DofC for each specific product? How do we get our voices 
heard? Contact your National Standards body, (i.e. ANSI, CSI, DIN, BSI...) and 
persevere until you find someone who understands what you are talking about and 
knows what to do about it. -- OOO - Own Opinions Only. See www.jmwa.demon.co.uk 
SHOCK HORROR! Dinosaur-like DNA found in chicken and turkey meals John 
Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK snip

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Re: [PSES] Recast of RTTE directive

2013-02-26 Thread John Cotman

Surely if this is a real issue, (and I'm not convinced that it is), it would
have to be in the text of the directive(s), and is nothing to do with
standards?

 

John C

 

  _  

From: Anthony Thomson [mailto:ton...@europe.com] 
Sent: 26 February 2013 10:18
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Recast of RTTE directive

 

I'm with Scott on this and I appreciate John's advice about canvassing one's
relevant National Standards body.

 

However, I would like to understand who is driving and supporting the
rquirement for uniquely serialised DoC's and their motives and rationale
behind the requirement. Because at the moment, from my perspective, whoever
is doing so is demonstrating a worrying and total lack of understanding
regarding the products, consumer market, distribution and manufacturing of
the vast majority (95% at a guess) of products falling under the scope of
the RTTE and its recast.

 

Non RTTE compliant product is already prolific enough without adding even
more barriers to compliance, ESPECIALLY with regards to Administrative
Complaince. Technical Compliance and the enforement thereof must be the main
focus. After all, the marking on the packaging or documentation does not
affect the operation and co-existance of my electronics one iota, spurious
emissions or a modest lack of immunity to environmental influences does
however.

 

So who is driving and supporting the requirement for uniquely serialised
DoC's and what is their technical and economical justification for doing so.
Or shall we just do the sensible thing and drop this daft requirement. 

 

T

 

- Original Message -

From: John Woodgate

Sent: 02/26/13 08:41 AM

To: EMC-PSTC@LISTSERV.IEEE.ORG

Subject: Re: [PSES] Recast of RTTE directive

 

In message 512c27c6.4020...@radiusnorth.net, dated Mon, 25 Feb 2013, 
Scott Douglas sdoug...@radiusnorth.net writes: 
 
So who do we complain to about having a unique DofC for each specific 
product? How do we get our voices heard? 
 
Contact your National Standards body, (i.e. ANSI, CSI, DIN, BSI...) and 
persevere until you find someone who understands what you are talking 
about and knows what to do about it. 
-- 
OOO - Own Opinions Only. See www.jmwa.demon.co.uk 
SHOCK HORROR! Dinosaur-like DNA found in chicken and turkey meals 
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK 
 
snip

 

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Re: [PSES] Recast of RTTE directive

In message 20130226101739.148...@gmx.com, dated Tue, 26 Feb 2013, 
Anthony Thomson ton...@europe.com writes:


So who is driving and supporting the requirement for uniquely 
serialised DoC's and what is their technical and economical 
justification for doing so.


Probably some enthusiastic 'experts' (maybe lawyers) in the Commission, 
and maybe there is an unrealistic 'consumer interest' lobby group, with 
no experience of industry.

--
OOO - Own Opinions Only. See www.jmwa.demon.co.uk
SHOCK HORROR! Dinosaur-like DNA found in chicken and turkey meals
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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Re: [PSES] Recast of RTTE directive

In message 2EC8CC67196B4ED1BB7595C6964E7620@LENVOR61iJOHN, dated Tue, 
26 Feb 2013, John Cotman john.cot...@conformance.co.uk writes:


Surely if this is a real issue, (and I?m not convinced that it is), it 
would have to be in the text of the directive(s), and is nothing to do 
with standards?


See the Subject line: it IS in the draft Directive.

The reason why I directed people to standards bodies is that they are 
generally likely to be the best route to the people concerned with the 
Directive, whether they are standards-body senior staff or government 
officials.


Of course, you can approach the relevant government department directly, 
IF you know which one, and which 'division' of it, and so on down the 
hierarchy.

--
OOO - Own Opinions Only. See www.jmwa.demon.co.uk
SHOCK HORROR! Dinosaur-like DNA found in chicken and turkey meals
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

-

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Re: [PSES] Recast of RTTE directive

2013-02-26 Thread Anthony Thomson

I believe John's advice related to the National Standards bodies' input and 
influence into the European Commission's Directives processes. Please correct 
me if I misunderstood this.

As for being an issue... If you're manufacturing broadcast transmitters or 4G 
cellular base stations in volumes of 10's having manufacturing costs of 
£/€1000's, then it's not a problem. It you're manufacturing wireless computer 
mice, Bluetooth dongles, mobile phones, wireless home routers, doorbells, 
'Plip-Plips' and garage door openers, vehicle tyre pressure sensors, OEM 
wireless modules, etc., etc., etc., etc. in their millions at manufacturing 
costs of pennies or cents in some cases, from multiple factories across 
multiple countries, for worldwide distribution, including Europe, then it's a 
massive problem.

Like I said, a worrying lack of understanding from those supposedly 'in the 
know'. Or maybe I've misuderstood the requirement... wouldn't be the first time 
I got something wrong.

T

- Original Message -
From: John Cotman
Sent: 02/26/13 10:27 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Recast of RTTE directive

Surely if this is a real issue, (and I’m not convinced that it is), it would 
have to be in the text of the directive(s), and is nothing to do with standards?
John C

-
From: Anthony Thomson [mailto:ton...@europe.com]
Sent: 26 February 2013 10:18
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Recast of RTTE directive
I’m with Scott on this and I appreciate John’s advice about canvassing one's 
relevant National Standards body.
However, I would like to understand who is driving and supporting the 
rquirement for uniquely serialised DoC’s and their motives and rationale behind 
the requirement. Because at the moment, from my perspective, whoever is doing 
so is demonstrating a worrying and total lack of understanding regarding the 
products, consumer market, distribution and manufacturing of the vast majority 
(95% at a guess) of products falling under the scope of the RTTE and its 
recast.
Non RTTE compliant product is already prolific enough without adding even more 
barriers to compliance, ESPECIALLY with regards to Administrative Complaince. 
Technical Compliance and the enforement thereof must be the main focus. After 
all, the marking on the packaging or documentation does not affect the 
operation and co-existance of my electronics one iota, spurious emissions or a 
modest lack of immunity to environmental influences does however.
So who is driving and supporting the requirement for uniquely serialised DoC's 
and what is their technical and economical justification for doing so. Or shall 
we just do the sensible thing and drop this daft requirement. 
T
- Original Message -
From: John Woodgate
ent: 02/26/13 08:41 AM
o: EMC-PSTC@LISTSERV.IEEE.ORG
ubject: Re: [PSES] Recast of RTTE directive
In message 512c27c6.4020...@radiusnorth.net, dated Mon, 25 Feb 2013, 

Scott Douglas sdoug...@radiusnorth.net writes: 
So who do we complain to about having a unique DofC for each specific 
product? How do we get our voices heard? 
Contact your National Standards body, (i.e. ANSI, CSI, DIN, BSI...) and 
persevere until you find someone who understands what you are talking 
about and knows what to do about it. 
-- 
OOO - Own Opinions Only. See www.jmwa.demon.co.uk 
SHOCK HORROR! Dinosaur-like DNA found in chicken and turkey meals

-

This message is from the IEEE Product Safety Engineering Society emc-pstc 
discussion list. To post a message to the list, send your e-mail to 
emc-p...@ieee.org

All emc-pstc postings are archived and searchable on the web at:
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Re: [PSES] Recast of RTTE directive

2013-02-26 Thread John Cotman

It would defy all common sense if it got in.  Among other matters, there has
to be a regulatory impact assessment of any new legislation.

John C

-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk] 
Sent: 26 February 2013 10:59
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Recast of RTTE directive

In message 2EC8CC67196B4ED1BB7595C6964E7620@LENVOR61iJOHN, dated Tue, 
26 Feb 2013, John Cotman john.cot...@conformance.co.uk writes:

Surely if this is a real issue, (and I?m not convinced that it is), it 
would have to be in the text of the directive(s), and is nothing to do 
with standards?

See the Subject line: it IS in the draft Directive.

The reason why I directed people to standards bodies is that they are 
generally likely to be the best route to the people concerned with the 
Directive, whether they are standards-body senior staff or government 
officials.

Of course, you can approach the relevant government department directly, 
IF you know which one, and which 'division' of it, and so on down the 
hierarchy.
-- 
OOO - Own Opinions Only. See www.jmwa.demon.co.uk
SHOCK HORROR! Dinosaur-like DNA found in chicken and turkey meals
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

-

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Re: [PSES] Recast of RTTE directive

In message 7B529F5F748344499F9D6BA0A8C663C8@LENVOR61iJOHN, dated Tue, 
26 Feb 2013, John Cotman john.cot...@conformance.co.uk writes:


It would defy all common sense if it got in.  Among other matters, 
there has to be a regulatory impact assessment of any new legislation.


But if people don't protest, it is assumed that they agree. Any other 
assumption makes things unworkable.

--
OOO - Own Opinions Only. See www.jmwa.demon.co.uk
Dark energy found in famous Irish drink!
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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Re: [PSES] Recast of RTTE directive

2013-02-26 Thread Kunde, Brian

For fun, let's look at what we would have to do if we did everything the 
current and future proposed EU Directives states regarding DofCs. Let's assume 
unique everything.

At the end of every production line you would have an officer of the company 
(director level or higher). For each product produced, he would have to take a 
picture of it, load the picture file into a computer, enter the model and 
serial number of the product, and print out a DofC with a unique document 
number. Then you would have to create a print for that DofC and an ECN to add 
this document number into the BOM for this product. Then he would have to sign 
the DofC, run over to a copy machine, make a copy, put the copy in a huge file 
cabinet (for 10 years) then put the original in the box with the product.

If you have a production line producing 10K products a shift, you will need a 
lot of directors.

I hope you are smiling and crying at the same time.

The Other Brian


-Original Message-
From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Scott Douglas
Sent: Monday, February 25, 2013 10:11 PM
To: John Woodgate
Cc: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Recast of RTTE directive

I can tell you that trying to make a unique DofC for each individual unit 
serial number is absolutely unworkable. Not to mention a documentation and 
logistics nightmare.

So who do we complain to about having a unique DofC for each specific product? 
How do we get our voices heard?

Scott

On 2/25/2013 8:30 AM, John Woodgate wrote:
 In message
 617eb8c8634c9149aa66c853d7b8ac53040e3...@by2prd0310mb389.namprd03.pro
 d.o utlook.com, dated Mon, 25 Feb 2013, Crane, Lauren
 lauren.cr...@kla-tencor.com writes:

 John, since you ask...(but perhaps you only meant the re-scoping)...

 I did mean the re-scoping.

 The RTTE recast is also be stepping forward with the unique
 equipment number requirement in the DoC which seems to require 1 DoC
 per unit (rather than 1 DoC per model line).

 AARGH!!!

 As I've mentioned in a previous post, this is also appearing in the
 LVD recast, though 1 parliamentarian (Zuzana Roithová) is trying to
 change the impact of this DoC requirements point 1 to be a unique
 identifier for the DoC document itself.

 I hope that industry in ALL countries will strongly object to this
 impractical AND ineffective provision.

 A non-compliant product can just as easily be supplied with a DoC
 carrying a serial number as a compliant product can (even though that
 is not at all easy in practice).

-

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LECO Corporation Notice: This communication may contain confidential 
information intended for the named recipient(s) only. If you received this by 
mistake, please destroy it and notify us of the error. Thank you.

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Re: [PSES] Recast of RTTE directive

2013-02-26 Thread Crane, Lauren

You can reach out by email to the parliamentary committee managing the RTTE 
project, particularly the leader (the rapporteur) and the shadow 
rapporteurs. I'll see if I can dig up their names and share. I know it seems 
like a long shot, but I also know from personal experience it can be effective. 

Does IEEE have any presence in Europe that might be able to contact related 
legislators in Brussels on behalf of us all? - Or contact Orgalime an 
association of manufacturing associations (I think) that tends to lobby a lot 
on such issues.  

Contact the US Department of Commerce in DC who can liaise with the US Mission 
to Brussels to communicate with EU legislators (I have a contact I will reach 
out to and see if I can share back here)

Perhaps you have subsidiaries in the EU or a government affairs group in your 
company that can engage Brussels. 

The unique aspect of the problem here is that the unique DoC issue seems 
embedded in the New Legislative Frame (NLF) legislation, the ideas of which are 
being promulgated across all CE marking directives one by one. If you squash it 
in RTTE it will still pop up in LVD unless the NLF gets changed. 

Regards,
Lauren 


-Original Message-
From: Scott Douglas [mailto:sdoug...@radiusnorth.net] 
Sent: Monday, February 25, 2013 9:11 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Recast of RTTE directive

I can tell you that trying to make a unique DofC for each individual unit 
serial number is absolutely unworkable. Not to mention a documentation and 
logistics nightmare.

So who do we complain to about having a unique DofC for each specific product? 
How do we get our voices heard?

Scott

On 2/25/2013 8:30 AM, John Woodgate wrote:
 In message
 617eb8c8634c9149aa66c853d7b8ac53040e3...@by2prd0310mb389.namprd03.pro
 d.o utlook.com, dated Mon, 25 Feb 2013, Crane, Lauren
 lauren.cr...@kla-tencor.com writes:

 John, since you ask...(but perhaps you only meant the re-scoping)...

 I did mean the re-scoping.

 The RTTE recast is also be stepping forward with the unique 
 equipment number requirement in the DoC which seems to require 1 DoC 
 per unit (rather than 1 DoC per model line).

 AARGH!!!

 As I've mentioned in a previous post, this is also appearing in the 
 LVD recast, though 1 parliamentarian (Zuzana Roithová) is trying to 
 change the impact of this DoC requirements point 1 to be a unique 
 identifier for the DoC document itself.

 I hope that industry in ALL countries will strongly object to this 
 impractical AND ineffective provision.

 A non-compliant product can just as easily be supplied with a DoC 
 carrying a serial number as a compliant product can (even though that 
 is not at all easy in practice).

-

This message is from the IEEE Product Safety Engineering Society emc-pstc 
discussion list. To post a message to the list, send your e-mail to 
emc-p...@ieee.org

All emc-pstc postings are archived and searchable on the web at:
http://www.ieee-pses.org/emc-pstc.html

Attachments are not permitted but the IEEE PSES Online Communities site at 
http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used 
formats), large files, etc.

Website:  http://www.ieee-pses.org/
Instructions:  http://listserv.ieee.org/request/user-guide.html
List rules: http://www.ieee-pses.org/listrules.html

For help, send mail to the list administrators:
Scott Douglas emcp...@radiusnorth.net
Mike Cantwell mcantw...@ieee.org

For policy questions, send mail to:
Jim Bacher:  j.bac...@ieee.org
David Heald: dhe...@gmail.com

-

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Website:  http://www.ieee-pses.org/
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For help, send mail to the list administrators:
Scott Douglas emcp...@radiusnorth.net
Mike Cantwell mcantw...@ieee.org

For policy questions, send mail to:
Jim Bacher:  j.bac...@ieee.org
David Heald: dhe...@gmail.com

Re: [PSES] Recast of RTTE directive