Hi Dave,
It would be wrong of me to comment on this, as I would effectively be saying “I think Michael was correct during the TCB Council training” :) But, I just want to confirm that nothing significant has changed since May on this topic, and so my presentation still applies, in my opinion. However, please note that my presentation was based on the Draft RED Guide, issued on 22nd September 2016. Now we have the first published version of the RED Guide, published on 19th May 2017. (That was after my presentation). The text to describe this situation was clear in the draft guide, but was removed (not changed or contradicted, just removed) for the published version of the RED Guide. I believe the plan is to confirm the exact text to use, and include the final conclusions into version 2 of the RED Guide. Personally, I think it sounds to me like you are doing the correct thing. If your system is comprised of two parts (host + modem) which can only operate together and only operate as a radio system, then I think you would consider them as one radio product. But it sounds to me like your host could operate alone as a non-radio product, and could even be shipped without the USB modem as a non-radio product, if you so desired. This sounds to me like the host is not a radio/RED product, and it should be ok to ship it with (in the same box as) a RED product, without making the host itself a radio/RED product. In such a case, perhaps the EMCD+LVD would apply to your host product. There is guidance on the topic of “devices shipped together”; but that is focusing on a mobile phone which is shipped with a mains charger. (If they are shipped together, they can be one radio product. If the charger could be shipped separately, it must be a non-radio product). Maybe you want to consider similar guidance? I would be very interested to hear if anyone has any real evidence or experience of market surveillance problems when shipping radio products with non-radio products, in this way. Thanks, Michael. Michael Derby Senior Regulatory Engineer Director ACB Europe Certification Resource for the Wireless Industry Web: www.acbcert.com <http://www.acbcert.com/> e-mail: <mailto:micha...@acbcert.com> micha...@acbcert.com Mobile phone: (+44) 7939 880829 (UK area code) Corporate office phone: USA: (+1) 703 847 4700 From: Dave Heald [mailto:emcp...@gmail.com] Sent: 20 September 2017 16:47 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] RED and customer removable/replaceable USB radio modules in a host 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 <emc-p...@ieee.org <mailto:emc-p...@ieee.org> > 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) <http://www.ieee-pses.org/list.html> List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <sdoug...@ieee.org <mailto:sdoug...@ieee.org> > Mike Cantwell <mcantw...@ieee.org <mailto:mcantw...@ieee.org> > For policy questions, send mail to: Jim Bacher <j.bac...@ieee.org <mailto:j.bac...@ieee.org> > David Heald <dhe...@gmail.com <mailto:dhe...@gmail.com> > - ---------------------------------------------------------------- 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 <emc-p...@ieee.org> 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 <sdoug...@ieee.org> Mike Cantwell <mcantw...@ieee.org> For policy questions, send mail to: Jim Bacher: <j.bac...@ieee.org> David Heald: <dhe...@gmail.com>
