As I read the guidance, the compliance requirement is moreso for the RFID tag than the tagged equipment. So I agree with the statement that no reason to stop ship as long as both the RFID tag (and tagged equipment) are going to a country that the RFID tag was approved for in Europe.
Thanks for sharing this. Bayode From: Monrad Monsen <[email protected]> To: [email protected] List-Post: [email protected] List-Post: [email protected] List-Post: [email protected] Date: 01/05/2010 01:49 PM Subject: RE: [PSES] RFID and the R&TTE Directive 1999/5/EC ________________________________ Thank you, Charlie, for pointing me to this excellent guidance found on the Europa web site. http://ec.europa.eu/enterprise/sectors/ tte/documents/interpretation/#h2-36.-pa sive-rfid-tags-at-the-stage-of-placing-on-the-market-and-the-rtte-directive <http://ec.europa.eu/enterprise/sectors rtte/documents/interpretation/#h2-36.-p ssive-rfid-tags-at-the-stage-of-placing-on-the-market-and-the-rtte-directive> In answer to my earlier questions .... > 1. Are passive RFID tags regulated under the European R&TTE Directive > 1999/5/EC? Yes. The RFID tags even need a CE mark if they are large enough to have one. The tag manufacturer needs to have a technical file, DOC and user information. > 2. If the answer to question #1 is "yes", then would a server that has > an RFID tag mounted on its exterior then become regulated under the > European R&TTE Directive 1999/5/EC? No. Only the RFID tag itself is regulated under European R&TTE Directive 1999/5/EC, not the product on which the tag is mounted. As I read the guidance, a system manufacturer that applies the RFID tag to its products would not have to pass on the "user information" to the ultimate user that purchases the combined system with external RFID tag. The guidance states that the buyer of the tagged equipment need not be informed. Of course, the seller needs to ensure that the tags used are sold to customers within the country or countries for which the tag's operating frequency is appropriate. I tend to believe it is best to pass on this information to the ultimate buyer of the tagged equipment anyway. However, I could not justify a stop ship if some products did not have this information as long as the tags were going to the correct nations. As it turns out, Europe has harmonized to allow RFID tags and readers to operate within the 865.5-867.6 MHz frequency band, so the tags are appropriate for all nations in the European Union. Does everyone agree with my analysis? -- Monrad L. Monsen Worldwide Compliance Officer Sun Microsystems [email protected] <mailto:[email protected]> 303.272.9612 Office -------- Original Message -------- Subject: RE: [PSES] RFID and the R&TTE Directive 1999/5/EC List-Post: [email protected] List-Post: [email protected] List-Post: [email protected] Date: Tue, 05 Jan 2010 16:40:02 +0000 From: Charlie Blackham <[email protected]> <mailto:[email protected]> To: [email protected] <mailto:[email protected]> , [email protected] <mailto:[email protected]> Monrad Guidance available at: http://ec.europa.eu/enterprise/sectors/ tte/documents/interpretation/#h2-36.-pa sive-rfid-tags-at-the-stage-of-placing-on-the-market-and-the-rtte-directive <http://ec.europa.eu/enterprise/sectors rtte/documents/interpretation/#h2-36.-p ssive-rfid-tags-at-the-stage-of-placing-on-the-market-and-the-rtte-directive> regards Charlie From: Monrad Monsen [mailto:[email protected] <mailto:[email protected]> ] Sent: 05 January 2010 16:32 To: [email protected] <mailto:[email protected]> Subject: [PSES] RFID and the R&TTE Directive 1999/5/EC 1. Are passive RFID tags regulated under the European R&TTE Directive 1999/5/EC? I note that RFID tags can only transmit a weak signal after being energized and queried by a much more powerful RFID reader. I am confident that RFID readers must comply with the European R&TTE Directive 1999/5/EC, but I am hopeful that I don't need to do anything for RFID tags. I know that FCC does not require any test reports or approvals for RFID tags. 2. If the answer to question #1 is "yes", then would a server that has an RFID tag mounted on its exterior then become regulated under the European R&TTE Directive 1999/5/EC? RFID = Radio Frequency Identification R&TTE = Radio and Telecommunications Terminal Equipment Thanks. -- Monrad L. Monsen Worldwide Compliance Officer Sun Microsystems [email protected] <mailto:[email protected]> 303.272.9612 Office - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. 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