All,
I have been following the recent threads on MRA's, CAB seminars etc. and am
confused.
Can someone explain to me what all the fuss about the MRA is about. Look at
the details of what it will provide:
1. EMC Directive.
US laboratories can become "competent bodies" - OK but having worked until
recently as a competent body for five years, the technical construction file
is not a very common procedure if the facts are presented honestly to
manufacturers.
US laboratories can become accredited to test to European EMC standards - OK
but there never has been a requirement to be accredited.
US laboratories can become "notified bodies" under the Article 10.5 type
examination route for radiocommunication transmission apparatus - OK but
this route effectively disappears with the impending R&TTE Directive
(99/5/EC).
2. FCC
European laboratories can offer testing under the FCC DofC procedure - OK
but the main reason for not allowing them in the DofC game in the first
place was to encourage Europe to co-operate with the MRA negotiations.
3. TTE Directive.
US laboratories can become "designated laboratories" offering testing to
European TBR's. OK but again, this need for "designated laboratories"
disappears with the R&TTE Directive and this directive will allow testing to
be performed anywhere the manufacturer wants (as the EMC directive largely
does).
US laboratories can become "notified bodies" offering Annex 1 type
examination certificates, Annex 2 product check agreements, Annex 3 factory
quality assurance and Annex 4 full quality assurance approval. The role of
notified body is dramatically reduced under the R&TTE directive - so much so
that I don't believe it would be worth becoming a US CAB in this area. The
only role of any real significance left will be offering full quality
assurance approvals.
At the end of all this, the only benefits of the MRA are:
a) American "competent bodies" for those few manufacturers who feel that
the technical construction file is a valuable tool
b) Testing under the DofC procedure in Europe
c) FCC Part 68 approval from a European organisation
All the other perceived benefits will happen anyway with the R&TTE
directive.
Am I missing something here?
Regards,
James
James Cunningham
GSM Type Approval Consultant
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