All; It is my opinion that if Annex III is applied, that a notified body is not required. Take for example 2.4GHz ISM equipment, although the frequency band is not harmonized, the standards are(as of 14/2/2001), and according to the Annex III, a notified body is not required. There is nothing in the directive that states a NB is needed if the frequency band is not harmonized. Notifications, however, are required and the alert symbol must be used, but there is no requirement to use a NB.
I confirmed this with one of the member states regulating agencies during some recent notifications I made for an 2.4GHz ISM device. I applied the newly harmonized standards in accordance with annex III and made my notifications throughout the EU. At first I was challenged why I did not declare a NB. Apparently(not sure how or why), they were not aware that all of the standards that apply to ISM have been harmonized. After explaining and offering the evidence, they agreed that my notification was valid and that I had correctly applied the directive. No disrespect to the test labs out there because I have gotten a lot of good information from some, but I encourage folks to get there information from multiple sources and include the actual regulating agencies. I find that this is the best way to weigh the opinions of others and the sales spin of the test labs. After all, it is the regulating agencies who can throw you out of their country. ~~~~~~~~~~~~~~~~~~~~~ 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: CE-test - Ing. Gert Gremmen - ce-marking and more... [mailto:[email protected]] Sent: Wednesday, February 28, 2001 1:57 AM To: Courtland Thomas; emcpost Subject: RE: RTTE Directive There is some confusion over this subject: 1/ the ce marking directive still requires a rep "on-board" so resident on European soil. All New Approach directives under ce comply to this. 2/ The notified body (NB) is still required for R&TTE not harmonized standards to prescribe a test suite. R&TTE harmonized standards do have a suitable test suite of their own. 3/ the notified body is still required for the frequency allocation per country, unless a European harmonized frequency is used (currently just GSM and DECT). It's a good idea to comply to ERC freq. all. documents such as ERC 70-03 for short range devices. This one is a proposal for frequency harmonization for SRD in Europe. Be prepared for exceptions however. So the key is: Use a NB if Not Harmonized, otherwise do it yourself (or with our help). All network related standards such as TBR21, are voluntarily. Any way, selling devices is not forbidden at all as long as EMC and LVD requirements are met. You just should use the alert sign (and CE) including a list of ALL EC counties that utilization is not allowed. Conclusion: R&TTE is just as other electronics. The manufacturer should consult an NB for not harmonized frequencies and not harmonized (radio) standards. In the end all not harmonized frequencies usages need a notification to the authorities. 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: [email protected] [mailto:[email protected]]On Behalf >>Of Courtland Thomas >>Sent: Tuesday, February 27, 2001 11:07 PM >>To: emcpost >>Subject: RTTE Directive >> >> >> >>Hello group, >> >>I have been reading through different articles on the RTTE Directive and >>getting somewhat confused. I have concluded that there is no >>requirement for >>an authorized representative within the Community any longer. >>This may have >>been the case all along, but it was good to have that person to submit the >>technical files to a notified body. I believe the notified body >>requirement >>goes away with the RTTE directive also. Now all that is required >>is for the >>manufacturer to maintain the technical file and produce the Declaration of >>Conformity. Am I on the right page? >> >>Thanks, >> >>Courtland Thomas >>Patton Electronics >> >> >>------------------------------------------- >>This message is from the IEEE EMC Society Product Safety >>Technical Committee emc-pstc discussion list. >> >>Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ >> >>To cancel your subscription, send mail to: >> [email protected] >>with the single line: >> unsubscribe emc-pstc >> >>For help, send mail to the list administrators: >> Michael Garretson: [email protected] >> Dave Heald [email protected] >> >>For policy questions, send mail to: >> Richard Nute: [email protected] >> Jim Bacher: [email protected] >> >>All emc-pstc postings are archived and searchable on the web at: >> http://www.rcic.com/ click on "Virtual Conference Hall," >> >> ------------------------------------------- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: [email protected] with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Michael Garretson: [email protected] Dave Heald [email protected] For policy questions, send mail to: Richard Nute: [email protected] Jim Bacher: [email protected] All emc-pstc postings are archived and searchable on the web at: http://www.rcic.com/ click on "Virtual Conference Hall,"
