ACB
Radio Equipment Directive
Michael Derby
ACB 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
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
Radio Equipment Directive
• 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
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!)
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 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
Radio Equipment Directive
• 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
Radio Equipment Directive
• 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 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
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)
Radio Equipment Directive
• 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
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
Radio Equipment Directive
• 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
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.
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
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
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
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
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?
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
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’
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
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
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 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
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
Radio Equipment Directive
• 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
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
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
Radio Equipment Directive
• Manufacturer’s sample testing
• When appropriate, manufacturers will be
required to perform their own sample testing,
keep records of problems and inform others
Radio Equipment Directive
• Manufacturer providing information
• Manufacturers are obliged to cooperate with
national authorities and provide any
information requested by the authority
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
Questions?
• Contacts:
• michaeld@acbcert.com
• www.acbcert.com