ACB Radio Equipment Directive

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ACBRadio Equipment Directive

• Michael Derby
• ACB Europe 9 April 2014

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Introduction

• American Certification Body
• TCB, FCB, RCB, Notified Body
• Notified Body to the RTTE Directive
• Michael Derby
• Regulatory Engineer, TCB, FCB, Notified Body
• Liaison The TCB Council and the RTTE CA

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Change of Directives

• RTTE Directive
• Applicable to Radio and Telecommunication
  Terminal Equipment
• 1999/5/EC
• Time for an update
• Radio Equipment Directive
• RE Directive
• Will replace the RTTE Directive
• More than just alignment with the NLF

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Agenda

• Agenda of presentation
• History of the RE Directive progress
• Proposed and expected text
• Emphasis on changes from RTTE Directive
• Timeline

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Radio Equipment Directive

• History of RE Directive progress
• Work began in 2007 (7 years!)
• Commission proposals sent to European Parliament
  in 2011/12
• Comments were submitted
• Input from groups, including IMCO recently
• International Market and Consumer Protection
  Committee of the European Parliament

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Radio Equipment Directive

• Compromise Text in January 2014
• By the EU Council and EU Parliament
• Vote by European Parliament
• 13 March 2014
• Document accepted by European Parliament
• Approval from EU Council of Ministers
• Hopefully all will be ok
• They agreed to the compromise text

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Radio Equipment Directive

• Translation into all languages and text check
• Final text published
• Q3 at the earliest, I think
• Directive effective 20 days after publishing
• Manufacturer could DoC to RE D then
• Formally at least one MS into National Law
• Transition period of 2 years
• Can use RTTE D or RE D
• Until approximate Q3/Q4 of 2016

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Radio Equipment Directive

• Main points of interest that are expected to be
  in the RE Directive
• Many of these taken from the IMCO text
• Some were already known
• Of course we cannot guarantee anything until the
  final RE Directive is published
• .....but, we are quite confident that the
  following items have been accepted

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Radio Equipment Directive

• No more telecommunication terminal
• As the name change suggests, RTTE has become RE
• Telecommunication Terminal equipment removed from
  the Directive
• Therefore EMCD and LVD will apply to telecom
• Examples are wired telephones, fax machines, etc.
• RE Directive only applies to wireless/radio

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Radio Equipment Directive

• Scope of radio transmission
• Scope will include radio communication and also
  radio determination
• Definition of determination used to clarify
  that equipment such as radar, RFID, movement
  detection, velocity measurement, etc. are in
  scope
• Equipment which is not for communication or
  determination is out of RE Directive scope
• For example, ISM, EN 55011, CISPR 11, etc.
• (Part 18!)

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Radio Equipment Directive

• Scope of radio reception
• Receive only radio equipment is still in scope
• There had been talk of removing it
• Broadcast receivers are in scope
• They were specifically excluded from RTTE D
• There may be a longer transition period for
  broadcast receivers
• These will therefore no longer be in the scope of
  EMCD and LVD
• LVD exclusion important for low voltage devices

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Radio Equipment Directive

• Text of RE Directive scope
• Expected scope of the new Directive may be
• Radio Equipmentan electrical or electronic
  product, which intentionally emits and/or
  receives radio waves for the purpose of radio
  communication and/or radio determination, or an
  electrical or electronic product which must be
  completed with an accessory, such as antenna, so
  as to intentionally emit and/or receive radio
  waves for the purpose of radio communication
  and/or radio determination

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Radio Equipment Directive

• Frequency Range of RE Directive
• The frequency range of the RTTE Directive is 9
  kHz to 3000 GHz
• The frequency range of the RE Directive will be
  up to 3000 GHz, with no lower limit
• There are communications below 9 kHz
• These are now in scope
• ETSI and ECO have some work to do

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Radio Equipment Directive

• Radio Equipment assessed must be able to operate
  in at least one EU Country
• Without this, it cannot have a CE Mark
• In the past, people obtained Notified Body
  opinions and CE Marked their devices to the RTTE
  Directive, for non-European markets
• This will not be permitted under the RE Directive
  unless the device can actually operate in at
  least one EU Country (or CE Marking country)

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Radio Equipment Directive

• Safety for animals
• If you read carefully, safety within the RTTE
  Directive did include animals
• But it wasnt clear to those who didnt
  understand it
• To clarify, the RE Directive will specify
• The protection of the health and safety of
  persons, of domesticated animals and the
  protection of property, including the objectives
  with respect to safety requirements set out in
  Directive 2006/95/EC, but with no voltage limit

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Radio Equipment Directive

• Clearer exclusions for equipment
• Some radio equipment are covered by more specific
  Directives for their type of operation
• Exclusion from the RE Directive for such devices
  will be expressed more clearly

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Radio Equipment Directive

• Evaluation Kits
• Specifically for professionals to use in RD
  facilities are excluded from the scope
• Encourage innovation and development
• Support RD in Europe
• Other Directives do exempt these devices
• Remove confusion and uncertainties about this
  type of device with regard to Directives

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Radio Equipment Directive

• Encourage better contact information
• Member States (MS) will encourage Economic
  Operators (EO) to include website addresses in
  addition to postal addresses
• Better communication between MS, MSA, EO and
  consumers
• MSA is Market Surveillance Authority
• Economic Operator could be a manufacturer,
  supplier, importer, etc.

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Radio Equipment Directive

• Encourage better contact information
• Equipment must show identifying numbers and
  contact details for responsible party(ies)
• Contact name and details for a person must be
  supplied with each device
• On the device, or documentation for small devices
• Importers must show similar information
• Stick contact details to equipment or packaging
• Supply chain to accept legal responsibility

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Radio Equipment Directive

• Codify requirements for universal chargers
• Presently, common/universal chargers are optional
  under industry MOUs
• Requirement in the directive for common or
  universal chargers
• For example, mobile phones, tablets, cameras,
  music players, etc.
• Desire is to reduce impact to the environment and
  inconvenience to consumers

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Radio Equipment Directive

• Electronic labelling
• European Commission and many MSAs have not been
  in favour of electronic labelling
• Proposed text should allow electronic labelling
  for certain, appropriate types of equipment
• For example, equipment with an integral screen
• Other information may also be permitted
  electronically, such as model and contact points
• Devices without initial charge could have a
  removable label for shipping

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Radio Equipment Directive

• No more Country Notifications for Class 2
• Class 2 devices for use in non-harmonised
  frequency bands presently require Notification to
  each member state
• The proposal is to drop this requirement

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Radio Equipment Directive

• No more Alert Symbol for Class 2
• Class 2 devices must show the Alert Symbol to
  alert the user of a restriction of use
• This symbol will no longer be used
• Face it who other than us knew what it meant?

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Radio Equipment Directive

• No more CE Mark in the user manual
• Presently, the CE Mark must appear in the user
  manual
• The proposal is to drop this requirement

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Radio Equipment Directive

• Notified Body Certificate
• The name of the Notified Body opinion will change
  to Type Examination Certificate
• Not to be confused with Type Approval
  Certificate, used in certification Directives
• It is a DoC Directive and the Notified Body role
  is still a reviewing role not certification
• No more Negative Opinion only a Certificate, or
  no Certificate
• Need a way to track no certificate

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Radio Equipment Directive

• Notified Body Report
• To accompany the Notified Body Type Examination
  Certificate, the Notified Body will be required
  to supply a report to explain and justify the
  issuing of the certificate

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Radio Equipment Directive

• Notified Body number on the product
• Presently the NB number appears on the label of
  the product for any NB involvement
• Identification of Essential Test Suites (Annex
  III)
• Review and Opinion (Annex IV) (most common)
• Full quality assurance (Annex V)
• Under the RE Directive, the NB number will only
  be on the label when the full quality assurance
  route (Annex V) is used

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Radio Equipment Directive

• Mandatory use of Notified Body (non-HS)
• Presently any deviation from harmonised standards
  requires review and opinion from a Notified Body
• This was never the intention with the RTTE D
• RE Directive will clarify that only deviation
  from radio (Article 3.2) standards will mandate
  the review of a Notified Body
• Although any/full review is always an option

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Radio Equipment Directive

• Translations not required
• DoC must be available in each language
• There was a proposal to translate the whole TCF
  into each language
• This proposal has not been accepted

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Radio Equipment Directive

• Registration
• Its not in, but its not completely out
• The RE Directive will include the possibility for
  the EU Commission to prescribe registration for
  specified products based on inadequate compliance
• Therefore, types of device which get onto the
  naughty list could prompt a registration system
  to be started and the hooks will be in place

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Radio Equipment Directive

• Single DoC
• As expected from the NLF, all applicable
  Directives to be referenced on one DoC
• If necessary, it can be multiple pages
• In the case of multiple signatories, for example

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Radio Equipment Directive

• Photograph on the DoC
• There was a proposal that all DoCs must contain a
  photo of the device
• Compromise is that if a photos is supplied, it
  must be in colour and of good quality

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Radio Equipment Directive

• Manufacturers sample testing
• When appropriate, manufacturers will be required
  to perform their own sample testing, keep records
  of problems and inform others

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Radio Equipment Directive

• Manufacturer providing information
• Manufacturers are obliged to cooperate with
  national authorities and provide any information
  requested by the authority

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Radio Equipment Directive

• Good luck!
• Hopefully the final text will be out before the
  next TCB Council Workshop
• Anticipate detailed presentations at the workshop
  in October 2014

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Questions?

• Contacts
• michaeld_at_acbcert.com
• www.acbcert.com