Hi Carl: As Larry noted, for the EU, land line telecom terminals are only required to meet the applicable requirements for safety and EMC. For CE marking, there are no *regulatory* requirements for compatibility with the land line telecom network. This has been the case ever since the TTE directive came into effect in 2000.
In the late 1990s, TBR 21 was ETSI's attempt to come up with a harmonized EU standard for equipment that interfaces to the analog land line telephone network. The intention was to use TBR 21 as the basis for a harmonized regulatory standard called CTR 21, which would have applied under an earlier regulatory scheme that was replaced by the TTE directive. Since the TTE directive eliminated any regulatory requirements on the parameters covered by TBR -21, some manufacturers were uneasy having no official guidance on compatibility with the analog land-line phone network. For this reason, ETSI continued to update and evolve TBR 21 for many years as an "advisory" standard that was purely voluntary. I think the current version is a set of documents called TS 103 021-1, TS 103 021-2, and TS 103 021-3. While compliance with these standards is not a regulatory requirement, some manufacturers (and their customers) feel more comfortable knowing that a product meets these requirements. In my judgment, the requirements in the TS-103 021 series are pretty reasonable, especially compared to the some of the per-country national requirements that were mandatory prior to the implementation of the TTE directive in 2000. So, it might be appropriate to at least review the requirements in the TS 103 021 series and satisfy yourself that your product complies with those requirements. However, that would be a purely voluntary activity because there is no regulatory requirement to meet those requirements. If your product is a listen-only device that only looks for ringing, only a small subset of the requirements in the TS 103 021 series would be relevant, such as the impedance presented to ring signals and the applicable thresholds for ring detection. I think you will find the requirements to be easy to meet. Joe Randolph Telecom Design Consultant Randolph Telecom, Inc. 781-721-2848 (USA) [email protected] http://www.randolph-telecom.com -----Original Message----- From: Larry K. Stillings [mailto:[email protected]] Sent: Wednesday, November 19, 2014 3:27 PM To: [email protected] Subject: Re: [PSES] TTE Equipment and R&TTE Directive Hi Carl, What you have surmised is correct. You are not required to meet any line standards is order to comply with the directives. The DoCs you are seeing, is the voluntary testing to ETSI standards to show that the line interface device is compatible with the phone network. I asked several times a joint NIST - EU meetings (in the 2000's) about the implementation of TTE standards under the R&TTE directive and always got the same response. There are no formal complaints and therefore no implementation of mandatory standards will occur. Also, the other reason the directive is going to become the Radio Equipment Directive (RED), as that is all it has ever really covered. Of course being a test lab whom does those tests, we can only make a mild suggestion you should test, as to this day we still have product showing up that don't comply with the ETSI TBR and or ES 203 021-x standards, but that is always a financial / business decision on what the risk is of performing no testing. Larry K. Stillings Compliance Worldwide, Inc. Test Locally, Sell Globally and Launch Your Products Around the World! FCC - Wireless - Telecom - CE Marking - International Approvals - Product Safety 357 Main Street Sandown, NH 03873 (603) 887 3903 Fax 887-6445 www.complianceworldwide.com Privileged/Confidential Information may be contained in this message. If you are not the addressee indicated in this message (or responsible for delivery of the message to such person), you may not copy or deliver this message to anyone. In such case, you should destroy this message and kindly notify the sender by reply email. Please advise immediately if you or your employer do not consent to Internet email for messages of this kind. Opinions, conclusions and other information in this message that do not relate to the official business of my firm shall be understood as neither given nor endorsed by it. -----Original Message----- From: Carl Newton [mailto:[email protected]] Sent: Wednesday, November 19, 2014 3:10 PM To: [email protected] Subject: [PSES] TTE Equipment and R&TTE Directive Dear List Members, I haven't worked with land-line telecom hardware for many years. I have a device intended for use by handicapped persons that will enable a visual alarm if the land-line phone is ringing, so the device is listen-only. I've found what appears to be good and reliable guidance concerning TTE equipment at this link which indicates that TTE equipment need only comply with the EMCD and LVD: http://ec.europa.eu/enterprise/sectors/rtte/regulatory-framework/index_e n.htm However, I'm seeing DoCs and product specs for current TTE equipment that reference the ETSI 201 703 and "TBR" series of standards, and those standards are not listed under the R&TTED, EMCD, or LVD on the Europa Harmonized Standards pages. Can someone shed some light on this confusing issue? Is TTE really not required to meet a line connection standard of some type as the Europa link above indicates? Thanks very much, Carl -- - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. 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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://www.ieee-pses.org/list.html (including how to unsubscribe) 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://www.ieee-pses.org/list.html (including how to unsubscribe) 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]>
