In a message dated 5/8/2002, John Juhasz writes:

> it appears that it is not required to test the interface itself to
> 'telecom specs' such as those in the CTR21. 
> 


Hi John:

Your interpretation is correct.  For wireline POTS products/interfaces, the 
only requirements that apply under the RTTE directive are safety and EMC.  
There are no regulatory requirements whatsoever for the type of 
specifications called out in CTR 21.  CTR 21 ceased to be a regulatory 
requirement when the RTTE directive came into force on April 8, 2000.

That being said, many manufacturers are uncomfortable with having no 
regulatory requirements for telecom.  One option is to continue voluntary 
testing to CTR 21.  Another option is to obtain the individual "reference" 
standards that the RTTE directive requires each operator of a public network 
to publish.  Most of the major operators have posted these on their web 
sites.  

A third option is to review CTR 21 and the relevant "reference" 
specifications, then use engineering judgment to design and test your 
interface.  This is the preferred approach if you are seeking minimum cost 
and/or maximum compatibility with the various national networks.

The bottom line is that the telecom aspects of your product performance are 
now a matter between you and your customer, rather than between you and the 
regulators.


Joe Randolph
Telecom Design Consultant
Randolph Telecom, Inc.
781-721-2848
http://www.randolph-telecom.com

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