Hi All, I am trying to confirm my understanding of the correct path for creating DoCs for hosts and USB radio modules under RED.
In our case, we make a few LTE USB modems that are specifically for use with our full range of branch and mobile routers. (i.e. the form factor is one designed to slide into customer accessible slots on most of our devices). Simply put, we sell packages of hosts (roughly 9 options) + optional USB modems (currently 2 options in the EU), and these modems are co-packaged in the same cardboard box, but not installed. We currently issue DoCs for each host, as well as DoCs for each USB modem. We do not issue DoCs for the combined host + USB modem, as the modems are customer removable and are often moved between hosts as needed in customer deployments. Note that testing is performed on fully populated systems of host + modems in the modem slots. The last guidance I have is from Michael Derby at this Spring's TCB Council traning, and it states that when a radio module is installed in a host, it becomes a new device under RED if the module is combined at or before the time of placing on the market, and not easily removed. This would not apply to us as the customer needs to install SIMs in the USB radio module before using the host+modem combination. However, there was apparently some legal action in Denmark (?) regarding connected appliances, where the courts ruled that a manufacturer had to consider a refrigerator as a RED device despite use of a USB WiFi modem (I suspect this was "manufactured in" and "not easily removable", but cannot find details on this case). My question is if anything has changed since May, where I would be legally obligated to consider the co-packaged host + USB modem as a single "device" and issue an EU DoC for the varying combinations of the host + modems. I don't think this is the case. Thanks! -David Heald Cradlepoint, Inc. - ---------------------------------------------------------------- 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]>
