ACB Radio Equipment Directive Michael Derby ACB Europe9 April 2014.

ACBRadio Equipment Directive

Michael DerbyACB Europe 9 April 2014

Introduction• American Certification Body

• TCB, FCB, RCB, Notified Body• Notified Body to the R&TTE Directive

• Michael Derby• Regulatory Engineer, TCB, FCB, Notified Body

• Liaison: The TCB Council and the R&TTE CA

Change of Directives• R&TTE Directive

• Applicable to Radio and Telecommunication Terminal Equipment

• 1999/5/EC• Time for an update

• Radio Equipment Directive• RE Directive

• Will replace the R&TTE Directive• More than just alignment with the NLF

Agenda

• Agenda of presentation• History of the RE Directive progress• Proposed and expected text

• Emphasis on changes from R&TTE Directive

• Timeline

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

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

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 R&TTE D or RE D• Until approximate Q3/Q4 of 2016


• 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


• No more telecommunication terminal• As the name change suggests, R&TTE 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


• 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!)


• 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 R&TTE 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


• Text of RE Directive scope• Expected scope of the new Directive may be:

• Radio Equipment……an 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


• Frequency Range of RE Directive• The frequency range of the R&TTE 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


• 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 R&TTE 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)


• Safety for animals• If you read carefully, safety within the R&TTE

Directive did include animals• But it wasn’t clear to those who didn’t 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


• 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


• Evaluation Kits• Specifically for professionals to use in R&D

facilities are excluded from the scope• Encourage innovation and development• Support R&D in Europe• Other Directives do exempt these devices• Remove confusion and uncertainties about this

type of device with regard to Directives


• 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.


• 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


• 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


• 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


• 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


• 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?


• 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


• 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’


• 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


• 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


• 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 R&TTE 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


• 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


• Registration• It’s not in, but it’s 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


• 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


• 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


• Manufacturer’s sample testing• When appropriate, manufacturers will be

required to perform their own sample testing, keep records of problems and inform others


• Manufacturer providing information• Manufacturers are obliged to cooperate with

national authorities and provide any information requested by the authority


• Good luck!• Hopefully the final text will be out before the

next TCB Council Workshop• Anticipate detailed presentations at the

workshop in October 2014

Questions?

• Contacts:

• [email protected]

• www.acbcert.com

mailto:[email protected]

http://www.atcb.com/

ACB Radio Equipment Directive Michael Derby ACB Europe9 April 2014.

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