Amund

I’d look at it the other way around:

Product B isn’t a radio without product A attached, therefore product A is part 
of a radio system and the R&TTE Directive applies.

Product A contains some fundamental radio parameters that you have mention 
(modulation, demodulation) and probably some others as well such as Frequency 
accuracy/stability. Does it offer any useful functionality without being 
connected to B?

(some other regulatory regimes often only require “certification” of the bit 
that actually “transmits”, but the R&TTE directive is a bit different)

Regards
Charlie


From: Amund Westin [mailto:[email protected]]
Sent: 19 March 2013 10:41
To: [email protected]
Subject: [PSES] RTTE - Radio product or not

Item A: Processing unit. Connection to PC and LAN (not directly to telecom 
network). Radio modulator & demodulator. Output radio signal 800MHz / 0dbm on 
cable to Item B.
Item B: Upconverter to 10GHz and High Power Amplifier and antenna

Item A and B together is a complete radio system and RTTE apply.

Item A stand-alone: I would say that it’s not a radio product since it does not 
transmit / receive to space. The radio signals (TX and RX) in on the cable to 
Item B and could be categorized as a signal line. LAN connection is not 
directly coupled to public telecom network. RTTE will not apply, that’s my 
opinion. The system integrator (Item A + B) will put his system into use and 
should be responsible for fulfilling RTTE.

Folks, do you agree?


Cheers,
Amund

PS:
From RTTE guidelines: Telecommunications terminal equipment is defined as a 
product enabling communication or a relevant component thereof which is 
intended to be connected directly or indirectly by any means

The wording “indirect” makes maybe Item A to a telecom terminal equipment ….

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