RE: RTTE Directive Notification Period
Hello All, I see by the replies that I didn't state my problem clearly. I don't mean to imply that the devices are variants of each other they are not. They are separate devices each of which has been tested to the full extent required. The proposition is purely this. Since I notified the PTTs before about products with the same application and RF characteristics previously and I had no objections from the PTTs and that furthermore the only way PTTs can ban a device is to object on the basis of network harm then they cannot ban my new products and I need not wait the four weeks. Comments anyone? Rest Regards Kevin Harris -Original Message- From: CE-test - Ing. Gert Gremmen - ce-marking and more... [mailto:cet...@cetest.nl] Sent: Thursday, January 11, 2001 5:08 PM To: Wismer, Sam; Kevin Harris; EMC-PSTC (E-mail) Subject: RE: RTTE Directive Notification Period As always, people are pragmatic, and technical reasons, how valid they may be, cannot prevail over legal ones. Any compliance matter will (-in case of dispute-) finally be judged by a legal specialist, not a technical-, and if in the end you manage to convince a lawyer that A equals B, he will ask you why calling it A anyway. Furthermore , many technical properties of radio devices nowadays depend heavily of software, such as the modulation scheme. If your previous uP served well to extremes of the test range, does the newer one ?? Your reasoning Richard, and Kevin would do well for submitting your device to a test house, as a motivation for no in-hour pre-compliance testing, but not for safeguarding your boss or customers against legal charges. Sorry... Regards, Gert Gremmen, (Ing) Ce-test, qualified testing == Web presence http://www.cetest.nl http://www.cetest.nl/ CE-shop http://www.cetest.nl/ce_shop.htm http://www.cetest.nl/ce_shop.htm /-/ Compliance testing is our core business /-/ == -Original Message- From: owner-emc-p...@ieee.org [mailto:owner-emc-p...@ieee.org]On Behalf Of Wismer, Sam Sent: Thursday, January 11, 2001 7:42 PM To: Kevin Harris; EMC-PSTC (E-mail) Subject: RE: RTTE Directive Notification Period Hi Kevin, Unless you give it the same model number etc., there will always be what appears to someone who tries to check on it, an un-notified(is that a word?) product on the market. I suppose you could have notified a family of products if you had visibility of them prior to the initial notification. It's a bit like adding a new antenna to a spread spectrum device here in the US. If the antenna is of the same type and equal or lesser gain than one that has already been approved by the FCC, then you don't have to test it. However, you do have to identify it. This means you have to file a class 2 permissive change to add the antenna to the file and wait the 12 week cycle time or so until it gets granted. For your question though, if the label cannot identify it as something that has been notified, then you should re-notify. Just be glad you only have to wait 4 weeks and not 12. My 2 cents... ~ Sam Wismer Lead Regulatory Engineer/ Radio Approvals Engineer LXE, Inc. (770) 447-4224 Ext. 3654 Visit Our Website at: http://www.lxe.com http://www.lxe.com -Original Message- From: Kevin Harris [ mailto:harr...@dscltd.com mailto:harr...@dscltd.com ] Sent: Thursday, January 11, 2001 10:35 AM To: EMC-PSTC (E-mail) Subject: RTTE Directive Notification Period Hello Sages, I am trying to assess what could possibly happen under the following scenario for the notification period. Lets say I had some SRD devices that have gone through the notification period without comment. At some later point I decide to introduce further devices in the line. The radios are not identical schematically but all the RF characteristics are identical, including percentage on time. The new devices are all type tested, EMC and safety tested in exactly the same manner as the devices previously notified and will be used in the same application. My proposal at that point would be to not wait for 4 weeks to expire on notification but to market the devices immediately. My reasoning for this is that a country can only object to a device being marketed on harm to the network and then follow the procedure in Article 9.5 for banning the device. Since they did not happen previously, they cannot object now. I know that attitude might put some regulatory noses out of joint but does anyone see a problem with the argument. Best Regards, Kevin Harris Manager, Approval Services Digital Security Controls 3301 Langstaff Road Concord, Ontario CANADA L4K 4L2 Tel: +1 905 760 3000 Ext. 2378 Fax +1 905 760 3020 Email: harr...@dscltd.com mailto:harr...@dscltd.com mailto:harr...@dscltd.com --- This message is from the IEEE EMC Society Product Safety
RE: RTTE Directive Notification Period
RE: RTTE Directive Notification PeriodAs always, people are pragmatic, and technical reasons, how valid they may be, cannot prevail over legal ones. Any compliance matter will (-in case of dispute-) finally be judged by a legal specialist, not a technical-, and if in the end you manage to convince a lawyer that A equals B, he will ask you why calling it A anyway. Furthermore , many technical properties of radio devices nowadays depend heavily of software, such as the modulation scheme. If your previous uP served well to extremes of the test range, does the newer one ?? Your reasoning Richard, and Kevin would do well for submitting your device to a test house, as a motivation for no in-hour pre-compliance testing, but not for safeguarding your boss or customers against legal charges. Sorry... Regards, Gert Gremmen, (Ing) Ce-test, qualified testing == Web presence http://www.cetest.nl CE-shop http://www.cetest.nl/ce_shop.htm /-/ Compliance testing is our core business /-/ == -Original Message- From: owner-emc-p...@ieee.org [mailto:owner-emc-p...@ieee.org]On Behalf Of Wismer, Sam Sent: Thursday, January 11, 2001 7:42 PM To: Kevin Harris; EMC-PSTC (E-mail) Subject: RE: RTTE Directive Notification Period Hi Kevin, Unless you give it the same model number etc., there will always be what appears to someone who tries to check on it, an un-notified(is that a word?) product on the market. I suppose you could have notified a family of products if you had visibility of them prior to the initial notification. It's a bit like adding a new antenna to a spread spectrum device here in the US. If the antenna is of the same type and equal or lesser gain than one that has already been approved by the FCC, then you don't have to test it. However, you do have to identify it. This means you have to file a class 2 permissive change to add the antenna to the file and wait the 12 week cycle time or so until it gets granted. For your question though, if the label cannot identify it as something that has been notified, then you should re-notify. Just be glad you only have to wait 4 weeks and not 12. My 2 cents... ~ Sam Wismer Lead Regulatory Engineer/ Radio Approvals Engineer LXE, Inc. (770) 447-4224 Ext. 3654 Visit Our Website at: http://www.lxe.com -Original Message- From: Kevin Harris [mailto:harr...@dscltd.com] Sent: Thursday, January 11, 2001 10:35 AM To: EMC-PSTC (E-mail) Subject: RTTE Directive Notification Period Hello Sages, I am trying to assess what could possibly happen under the following scenario for the notification period. Lets say I had some SRD devices that have gone through the notification period without comment. At some later point I decide to introduce further devices in the line. The radios are not identical schematically but all the RF characteristics are identical, including percentage on time. The new devices are all type tested, EMC and safety tested in exactly the same manner as the devices previously notified and will be used in the same application. My proposal at that point would be to not wait for 4 weeks to expire on notification but to market the devices immediately. My reasoning for this is that a country can only object to a device being marketed on harm to the network and then follow the procedure in Article 9.5 for banning the device. Since they did not happen previously, they cannot object now. I know that attitude might put some regulatory noses out of joint but does anyone see a problem with the argument. Best Regards, Kevin Harris Manager, Approval Services Digital Security Controls 3301 Langstaff Road Concord, Ontario CANADA L4K 4L2 Tel: +1 905 760 3000 Ext. 2378 Fax +1 905 760 3020 Email: harr...@dscltd.com mailto:harr...@dscltd.com --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher: jim_bac...@mail.monarch.com Michael Garretson:pstc_ad...@garretson.org For policy questions, send mail to: Richard Nute: ri...@ieee.org attachment: Gert Gremmen.vcf
RE: RTTE Directive Notification Period
Hi Kevin, Unless you give it the same model number etc., there will always be what appears to someone who tries to check on it, an un-notified(is that a word?) product on the market. I suppose you could have notified a family of products if you had visibility of them prior to the initial notification. It's a bit like adding a new antenna to a spread spectrum device here in the US. If the antenna is of the same type and equal or lesser gain than one that has already been approved by the FCC, then you don't have to test it. However, you do have to identify it. This means you have to file a class 2 permissive change to add the antenna to the file and wait the 12 week cycle time or so until it gets granted. For your question though, if the label cannot identify it as something that has been notified, then you should re-notify. Just be glad you only have to wait 4 weeks and not 12. My 2 cents... ~ Sam Wismer Lead Regulatory Engineer/ Radio Approvals Engineer LXE, Inc. (770) 447-4224 Ext. 3654 Visit Our Website at: http://www.lxe.com -Original Message- From: Kevin Harris [mailto:harr...@dscltd.com] Sent: Thursday, January 11, 2001 10:35 AM To: EMC-PSTC (E-mail) Subject: RTTE Directive Notification Period Hello Sages, I am trying to assess what could possibly happen under the following scenario for the notification period. Lets say I had some SRD devices that have gone through the notification period without comment. At some later point I decide to introduce further devices in the line. The radios are not identical schematically but all the RF characteristics are identical, including percentage on time. The new devices are all type tested, EMC and safety tested in exactly the same manner as the devices previously notified and will be used in the same application. My proposal at that point would be to not wait for 4 weeks to expire on notification but to market the devices immediately. My reasoning for this is that a country can only object to a device being marketed on harm to the network and then follow the procedure in Article 9.5 for banning the device. Since they did not happen previously, they cannot object now. I know that attitude might put some regulatory noses out of joint but does anyone see a problem with the argument. Best Regards, Kevin Harris Manager, Approval Services Digital Security Controls 3301 Langstaff Road Concord, Ontario CANADA L4K 4L2 Tel: +1 905 760 3000 Ext. 2378 Fax +1 905 760 3020 Email: harr...@dscltd.com mailto:harr...@dscltd.com --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher: jim_bac...@mail.monarch.com Michael Garretson:pstc_ad...@garretson.org For policy questions, send mail to: Richard Nute: ri...@ieee.org
RE: RTTE Directive Notification Period
I agree. We use the same regulatory ID number on a product which include variants not affecting the rf properties. We see no reason to apply to the Notified Body for an opinion of compliance nor to notify the PTTs when a new variant is marketed where the rf properties have not changed. That new variant will have the same ID number that was previously notified to the PTTs, Richard Woods -- From: Kevin Harris [SMTP:harr...@dscltd.com] Sent: Thursday, January 11, 2001 10:35 AM To: EMC-PSTC (E-mail) Subject: RTTE Directive Notification Period Hello Sages, I am trying to assess what could possibly happen under the following scenario for the notification period. Lets say I had some SRD devices that have gone through the notification period without comment. At some later point I decide to introduce further devices in the line. The radios are not identical schematically but all the RF characteristics are identical, including percentage on time. The new devices are all type tested, EMC and safety tested in exactly the same manner as the devices previously notified and will be used in the same application. My proposal at that point would be to not wait for 4 weeks to expire on notification but to market the devices immediately. My reasoning for this is that a country can only object to a device being marketed on harm to the network and then follow the procedure in Article 9.5 for banning the device. Since they did not happen previously, they cannot object now. I know that attitude might put some regulatory noses out of joint but does anyone see a problem with the argument. Best Regards, Kevin Harris Manager, Approval Services Digital Security Controls 3301 Langstaff Road Concord, Ontario CANADA L4K 4L2 Tel: +1 905 760 3000 Ext. 2378 Fax +1 905 760 3020 Email: harr...@dscltd.com mailto:harr...@dscltd.com --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher: jim_bac...@mail.monarch.com Michael Garretson:pstc_ad...@garretson.org For policy questions, send mail to: Richard Nute: ri...@ieee.org --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher: jim_bac...@mail.monarch.com Michael Garretson:pstc_ad...@garretson.org For policy questions, send mail to: Richard Nute: ri...@ieee.org
RTTE Directive Notification Period
Hello Sages, I am trying to assess what could possibly happen under the following scenario for the notification period. Lets say I had some SRD devices that have gone through the notification period without comment. At some later point I decide to introduce further devices in the line. The radios are not identical schematically but all the RF characteristics are identical, including percentage on time. The new devices are all type tested, EMC and safety tested in exactly the same manner as the devices previously notified and will be used in the same application. My proposal at that point would be to not wait for 4 weeks to expire on notification but to market the devices immediately. My reasoning for this is that a country can only object to a device being marketed on harm to the network and then follow the procedure in Article 9.5 for banning the device. Since they did not happen previously, they cannot object now. I know that attitude might put some regulatory noses out of joint but does anyone see a problem with the argument. Best Regards, Kevin Harris Manager, Approval Services Digital Security Controls 3301 Langstaff Road Concord, Ontario CANADA L4K 4L2 Tel: +1 905 760 3000 Ext. 2378 Fax +1 905 760 3020 Email: harr...@dscltd.com mailto:harr...@dscltd.com --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher: jim_bac...@mail.monarch.com Michael Garretson:pstc_ad...@garretson.org For policy questions, send mail to: Richard Nute: ri...@ieee.org
