Amund,
The definition of radio equipment in the context of the directive is quite 
clear: “"radio equipment" means a product, or relevant component thereof, 
capable of communication by means of the emission and/or reception of radio 
waves utilising the spectrum allocated to terrestrial/space radiocommunication;”
I think therefore it is clear that system components A & B fall under the 
R&TTED.
However… I guess it’s entirely possible that any meaningful assessment against 
the R&TTED may not be possible on the separate components assuming both are 
required to implement the ‘radio’. In this case, the Commission’s 2009 guide 
offers some very helpful advice: “Where a radio system is integrated on site — 
as in the case of microwave point-to-point and point-to-multipoint systems — 
the system integrators responsible for ensuring compliance of the system with 
the Directive when the system is brought into service.”
So my opinion would be that each component of the system falls under the R&TTED 
and it is the system integrator’s responsibility for compliance.
Just my ‘two-penneth’.
T
----- Original Message -----
From: Amund Westin
Sent: 03/19/13 10:41 AM
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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