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 …. - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <[email protected]> All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <[email protected]> Mike Cantwell <[email protected]> For policy questions, send mail to: Jim Bacher <[email protected]> David Heald <[email protected]> - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <[email protected]> All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <[email protected]> Mike Cantwell <[email protected]> For policy questions, send mail to: Jim Bacher <[email protected]> David Heald <[email protected]> - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <[email protected]> All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <[email protected]> Mike Cantwell <[email protected]> For policy questions, send mail to: Jim Bacher: <[email protected]> David Heald: <[email protected]>

