I agree with Charlie that it is not saying you must test to V1.8.1. It is saying that you must have spectrum sharing mechanisms (we know that, it's in V1.7.1) but we don't necessarily know what that means. It gives examples, followed by an idea of where to find tests if you want them.
Imagine the text from the OJ: This version of the standard gives presumption of conformity with the requirements of Article 3(2) of Directive 1999/5/EC under the following condition: The equipment shall implement an adequate spectrum sharing mechanism, e.g. LBT (Listen Before Talk), DAA (Detect And Avoid), etc., in order to comply with the requirement specified in clause 4.3.5 of this version. Such a mechanism shall facilitate sharing between the various technologies and applications which currently exist and in case of congestion, users will be ensured equal access (and as a consequence a graceful degradation of service to all users). The efficiency of the various sharing mechanisms can be assessed using the appropriate clauses of EN 300328 version 1.8.1. Now imagine a conversation between an industry person (let's call him "IP") and the OJ itself. For the OJ, I shall use only the text above.. OJ: This version of the standard gives presumption of conformity with the requirements of Article 3(2) of Directive 1999/5/EC under the following condition: The equipment shall implement an adequate spectrum sharing mechanism, IP: What is a "spectrum sharing mechanism"? OJ: e.g. LBT (Listen Before Talk), DAA (Detect And Avoid), etc., in order to comply with the requirement specified in clause 4.3.5 of this version. IP: Oh, I see that, but what is it for? If you explain it, maybe I can use some other way to meet that requirement. OJ: Such a mechanism shall facilitate sharing between the various technologies and applications which currently exist and in case of congestion, users will be ensured equal access (and as a consequence a graceful degradation of service to all users). IP: I see. That would be really easy if I had a WLAN or Bluetooth device but I don't, I have this cool new technology I invented. Are there any tests I can follow? OJ: The efficiency of the various sharing mechanisms can be assessed using the appropriate clauses of EN 300328 version 1.8.1. IP: Thank you, you've been very helpful. Honestly, I don't actually hear these voices in my head. Michael. Michael Derby Regulatory Engineer ACB Europe From: Charlie Blackham [mailto:[email protected]] Sent: 29 November 2012 08:31 To: [email protected] Subject: Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements Mark Harmonised Standards don't always contain all the requirements - Spectrum Requirements also apply and these are regulated by the various national radio interface regulations and not in the standards. The base for the use of the 2400-2483.5 MHz frequency band may be found in Annex 3 of ERC/REC 70-03. http://www.erodocdb.dk/Docs/doc98/official/pdf/REC7003e.pdf . This is the latest, October 2012 version, but the previous February 2011 version contained the following note: "The equipment shall implement an adequate spectrum sharing mechanism in order to facilitate sharing between the various technologies and applications covered by this annex 3." In other words an "adequate spectrum sharing requirement" has been needed for some time. The wording in the OJ has changed (evolved) from, if you like, "pointing to where ways for assessing this requirement could be found", to "telling you where they can be found". It does not say that the Spectrum Sharing requirements of V1.8.1 must be followed, it says can be found. In my opinion, the note in the OJ referring to V1.8.1 is not mandatory. Demonstration with requirement could be made through consideration of sharing requirements already built in though conformity with relevant 802.11 requirements of WiFI or BT standards. But whatever you choose, you should be prepared to justify it to a Spectrum Authority if required. The manufacturer must fully apply the relevant Harmonised Standard if they want to apply the CE mark without the use of a Notified Body and the Spectrum Requirements must also be followed before the device is put into service. The requirement hasn't actually changed when applying V1.7.1 it's just that the guidance has been improved as it has been found to be not as clear as it might have been. Though whether it's completely clear now . . . . J Regards Charlie From: Mark Gandler [mailto:[email protected]] Sent: 28 November 2012 19:51 To: Charlie Blackham; [email protected]; [email protected] Subject: RE: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements Charlie, current mandatory version is 1.7.1. Future (2015) is 1.8.1. Both harmonized. There is an application note in question which describes additional requirements. Only as of last month this Note became mandatory. Note in OJ from 2009 was simply stating what actual tests been developed in draft 1.8.1. Should the "note" be treated as any other new version of the standard, allowing grace period? Better question: how does one challenge or ask for "official" clarification on the matter? Mark _____ From: [email protected] To: [email protected]; [email protected] Subject: RE: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements Date: Wed, 28 Nov 2012 08:48:55 +0000 I'll write that correctly this time J UNLIKE many other Directives, the R&TTE Directive REQUIRES the use of a Notified Body where Radio Spectrum Standards are NOT applied in full. Harmonised Standards are, in effect, mandatory unless you use a NB - and even then, you can't choose not to apply them because you don't like them From: Charlie Blackham Sent: 28 November 2012 08:47 To: 'John Woodgate'; [email protected] Subject: RE: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements UNLIKE many other Directives, the R&TTE Directive REQUIRES the use of a Notified Body where Radio Spectrum Standards are applied in full. Regards Charlie -----Original Message----- From: John Woodgate [mailto:[email protected]] Sent: 28 November 2012 08:23 To: [email protected] Subject: Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements In message < <mailto:[email protected]> [email protected]>, dated Tue, 27 Nov 2012, Mark Gandler < <mailto:[email protected]> [email protected]> writes: > I'm not sure how anyone can justify this makes any sense and seems >like going against the spirit of RTTE and any other EU Directives, >allowing grace period for any requirement to take place. Simple >mentioning of something been developed does not substitute a legal >recruitment. Agreed; this seems like an erosion of the protection of manufacturers against instant changes. Like other Directives, the RTTE Directive contains no mandatory requirement to apply harmonized standards and carry out tests (except in the case of Full Quality Control). -- OOO - Own Opinions Only. See <http://www.jmwa.demon.co.uk> www.jmwa.demon.co.uk The longer it takes to make a point, the more obtuse it proves to be. John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. 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