I remember this ground radar, that I had for testing a

number of years ago, operating by sending an ground impulse with an antenna 
that 

was shielded upwards, followed by receiving

that echo from the ground.

 

From different authorities, I got different responses onto the applicability

of the R&TTD or EMC directive.

 

Using the  definition 

:  “ "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;”

created even more problems, as the question rose if the soil is part of the 
space

allocate for radio communication.

 

The device was so well constructed , that it passed Class A emissions, but some 
authorities

(notably the Swiss) insisted on applying the RTTE directive, and wanted the 
device to be

classified in terms of frequency use, modulation method and used bandwidth (and 
more)

and finally decided to refuse it’s use on Swiss soil.

 

Regards,

Ing.  Gert Gremmen, BSc

 

 

 

[email protected] <mailto:[email protected]> 

www.cetest.nl


Kiotoweg 363

3047 BG Rotterdam

T 31(0)104152426
F 31(0)104154953

Before printing, think about the environment. 

 

 

Van: [email protected] [mailto:[email protected]] Namens Anthony Thomson
Verzonden: Wednesday, March 20, 2013 10:29 AM
Aan: [email protected]
Onderwerp: Re: [PSES] RTTE - Radio product or not

 

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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