Re: [PSES] New Radio Equipment Directive (RED) - please read if you sell wireless devices into Europe
Also, if an NB did such a thing, I would think (hope) their AB would not only slap their hands, but either suspend them or remove their accreditation as an NB. Dennis Ward This communication and its attachements contain information from PCTEST Engineering Laboratory, Inc., and I sintended for the exclusive use of the recipient(s) named above. It may contain information that is confidential and/or legally privileged. Any unauthorized use that may compromise that confidentiality via distribution or disclosure is prohibited. Please notify the sender immediately if you receive this communication in error, and delete it from your computer system. Usage of PCTEST email addresses for non-business related activities is strictly prohibited. No warranty is made that the e-mail or attachments(s) are free from computer virus or other defect. Thank you. -Original Message- From: Charlie Blackham [mailto:char...@sulisconsultants.com] Sent: Thursday, October 30, 2014 4:43 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] New Radio Equipment Directive (RED) - please read if you sell wireless devices into Europe I think Nick was being diplomatic - they can do no such thing, any more than they could give a certificate to the ATEX or MDD directives unless suitably appointed. Charlie -Original Message- From: John Woodgate [mailto:j...@jmwa.demon.co.uk] Sent: 30 October 2014 11:26 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] New Radio Equipment Directive (RED) - please read if you sell wireless devices into Europe In message 2655b21dc209421abdc4eeb95de1a...@bn1pr04mb309.namprd04.prod.outlook.com , dated Thu, 30 Oct 2014, Hooper, Nick nick.hoo...@ul.com writes: So a RTTE NB has no appointment (NANDO database listing) to issue a NB EU type examination Certificate for the RED, they are, at best, misleading their customers, they cannot give such a certificate. True, of course, but they can issue a certificate with a suitable disclaimer, so as not to mislead. -- OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk Quid faciamus nisi sit? John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - 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 - 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 - 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
Re: [PSES] New Radio Equipment Directive (RED) - please read if you sell wireless devices into Europe
Competent and reliable = interesting concept. Until the RED is actually usable existing means of NB appointments do not do a lot in the area of competence. For example, a TCB has to show competence in the area they certify. They must prove that reviewers can actually do the testing and they need to show more than just average knowledge. The same cannot really be said about NBs. While it may be assumed all NBs have the same level of competence, that simply is not the case. The RED, to its credit, does try to address this situation by requiring significantly more expertise to be shown by both the Notifying Authorities and Notified Bodies. By putting more stringent requirements and more uniform requirements on all Notifying Authorities this at least levels the playing field and will prevent or slow down the approval of less competent NBs. Thanks Dennis Ward This communication and its attachements contain information from PCTEST Engineering Laboratory, Inc., and I sintended for the exclusive use of the recipient(s) named above. It may contain information that is confidential and/or legally privileged. Any unauthorized use that may compromise that confidentiality via distribution or disclosure is prohibited. Please notify the sender immediately if you receive this communication in error, and delete it from your computer system. Usage of PCTEST email addresses for non-business related activities is strictly prohibited. No warranty is made that the e-mail or attachments(s) are free from computer virus or other defect. Thank you. From: Anthony Thomson [mailto:ton...@europe.com] Sent: Thursday, October 30, 2014 2:16 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] New Radio Equipment Directive (RED) - please read if you sell wireless devices into Europe But the thread started with Nick Hooper saying that Notified Body's were already, and have issued opinions against the RED. This is where my interest lies, in finding a NB to issue an opinion against the RED in the coming weeks, when I stumbled across Nicks post questioning the validity of these NB opinions. I though NB's were supposed to be competent and reliable. I often rely on them to ratify and confirm our regulatory position. Sounds pretty serious to me and I find my confidence in the whole NB system waning! T Sent: Thursday, October 30, 2014 at 8:52 AM From: Michael Derby micha...@acbcert.com mailto:micha...@acbcert.com To: EMC-PSTC@LISTSERV.IEEE.ORG mailto:EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] New Radio Equipment Directive (RED) - please read if you sell wireless devices into Europe Just to add to the conversation, I will throw in a little practicality……. There are two primary compliance routes for manufacturers to use the RE Directive, as with the RTTE Directive. A manufacturer can fully apply the harmonised standards. Or, a manufacturer can consult a Notified Body to obtain an opinion when harmonised standards are not fully applied. (I guess you could also add that there is the option for a quality assessment (Annex V of RTTE), using a Notified Body). For the RE Directive: There are no harmonised standards. There are no Notified Bodies. So, from a practical point of view, it is also impossible. Michael. Michael Derby Senior Regulatory Engineer Director ACB Europe From: Anthony Thomson [mailto:ton...@europe.com] Sent: 29 October 2014 15:00 To: EMC-PSTC@LISTSERV.IEEE.ORG mailto:EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] New Radio Equipment Directive (RED) - please read if you sell wireless devices into Europe Hi Charlie, Thanks for your assistance, but I still can't see anything preventing one claiming compliance to the RED. It's an EU directive which does appear to be currently 'in force' across Europe, though not yet 'enforceable' by law. So why can't you claim compliance to the RED (assuming you do)? To coin a phrase... there's no law against it. Or is there? See my ongoing questions below. Regards, Tony Sent: Wednesday, October 29, 2014 at 12:59 PM From: Charlie Blackham char...@sulisconsultants.com To: Anthony Thomson ton...@europe.com, EMC-PSTC@LISTSERV.IEEE.ORG EMC-PSTC@LISTSERV.IEEE.ORG Subject: RE: [PSES] New Radio Equipment Directive (RED) - please read if you sell wireless devices into Europe Tony Article 48 says that the existing legislation (RTTE or EMC+LVD) may be used for equipment within scope of RED until 13 June 2017, provided it was on the market before 16 June 2016. T: Yes, I can see that Article 48 permits optionally applying the RTTED (et. al.), to new products, for 1 year after the RED becomes enforceable under law on 13 June 2016. However, I can't see how this sets the earliest date that compliance against the RED can be claimed, and this is what I'm trying to get to. Article 49 says that RED shall be applied from 13 June 2016 (in other words, it is won’t
Re: [PSES] New Radio Equipment Directive (RED) - please read if you sell wireless devices into Europe
In a perfect world, all Authorizing Bodies, NBs, TCBs and test labs would do everything right. Alas, they world is far less than perfect and errors abound. Accreditation helps, but it is only paper and does not monitor the actual work involved. It relies on the integrity and reliability of the entity accredited. However, as long as the push is cheaper, faster and less testing, many will feed at the bottom of the barrel where these traits seem to fester. There are many good NBs, many good TCBs and many good CBs in the world and it only takes one or two ‘bottom feeder’ to spoil the entire taste of the pie. Thanks Dennis Ward This communication and its attachements contain information from PCTEST Engineering Laboratory, Inc., and I sintended for the exclusive use of the recipient(s) named above. It may contain information that is confidential and/or legally privileged. Any unauthorized use that may compromise that confidentiality via distribution or disclosure is prohibited. Please notify the sender immediately if you receive this communication in error, and delete it from your computer system. Usage of PCTEST email addresses for non-business related activities is strictly prohibited. No warranty is made that the e-mail or attachments(s) are free from computer virus or other defect. Thank you. From: Michael Derby [mailto:micha...@acbcert.com] Sent: Thursday, October 30, 2014 2:26 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] New Radio Equipment Directive (RED) - please read if you sell wireless devices into Europe It’s a valid concern Tony. I imagine that ADCO in Europe are probably (hopefully) looking closely at any Notified Body who would issue a certificate for a Directive if they are not authorised to. There are no Notified Bodies designated to the RE Directive. I would like to think your waning confidence is in questionable Notified Bodies, rather than in the whole NB system. In the same way as you might be happy with the idea of FCC TCBs, despite the fact that some TCBs get it wrong. In the same way as you might be happy with the idea of test labs, despite the fact that some of them don’t seem to know how to test. Michael. Michael Derby Senior Regulatory Engineer Director ACB Europe From: Anthony Thomson [mailto:ton...@europe.com] Sent: 30 October 2014 09:16 To: EMC-PSTC@LISTSERV.IEEE.ORG mailto:EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] New Radio Equipment Directive (RED) - please read if you sell wireless devices into Europe But the thread started with Nick Hooper saying that Notified Body's were already, and have issued opinions against the RED. This is where my interest lies, in finding a NB to issue an opinion against the RED in the coming weeks, when I stumbled across Nicks post questioning the validity of these NB opinions. I though NB's were supposed to be competent and reliable. I often rely on them to ratify and confirm our regulatory position. Sounds pretty serious to me and I find my confidence in the whole NB system waning! T Sent: Thursday, October 30, 2014 at 8:52 AM From: Michael Derby micha...@acbcert.com mailto:micha...@acbcert.com To: EMC-PSTC@LISTSERV.IEEE.ORG mailto:EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] New Radio Equipment Directive (RED) - please read if you sell wireless devices into Europe Just to add to the conversation, I will throw in a little practicality……. There are two primary compliance routes for manufacturers to use the RE Directive, as with the RTTE Directive. A manufacturer can fully apply the harmonised standards. Or, a manufacturer can consult a Notified Body to obtain an opinion when harmonised standards are not fully applied. (I guess you could also add that there is the option for a quality assessment (Annex V of RTTE), using a Notified Body). For the RE Directive: There are no harmonised standards. There are no Notified Bodies. So, from a practical point of view, it is also impossible. Michael. Michael Derby Senior Regulatory Engineer Director ACB Europe From: Anthony Thomson [mailto:ton...@europe.com] Sent: 29 October 2014 15:00 To: EMC-PSTC@LISTSERV.IEEE.ORG mailto:EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] New Radio Equipment Directive (RED) - please read if you sell wireless devices into Europe Hi Charlie, Thanks for your assistance, but I still can't see anything preventing one claiming compliance to the RED. It's an EU directive which does appear to be currently 'in force' across Europe, though not yet 'enforceable' by law. So why can't you claim compliance to the RED (assuming you do)? To coin a phrase... there's no law against it. Or is there? See my ongoing questions below. Regards, Tony Sent: Wednesday, October 29, 2014 at 12:59 PM From: Charlie Blackham char...@sulisconsultants.com To: Anthony Thomson ton...@europe.com, EMC-PSTC
Re: [PSES] New Radio Equipment Directive (RED) - please read if you sell wireless devices into Europe
I love mixed metaphors Dennis Ward This communication and its attachements contain information from PCTEST Engineering Laboratory, Inc., and I sintended for the exclusive use of the recipient(s) named above. It may contain information that is confidential and/or legally privileged. Any unauthorized use that may compromise that confidentiality via distribution or disclosure is prohibited. Please notify the sender immediately if you receive this communication in error, and delete it from your computer system. Usage of PCTEST email addresses for non-business related activities is strictly prohibited. No warranty is made that the e-mail or attachments(s) are free from computer virus or other defect. Thank you. From: dward [mailto:dw...@pctestlab.com] Sent: Friday, October 31, 2014 10:30 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] New Radio Equipment Directive (RED) - please read if you sell wireless devices into Europe In a perfect world, all Authorizing Bodies, NBs, TCBs and test labs would do everything right. Alas, they world is far less than perfect and errors abound. Accreditation helps, but it is only paper and does not monitor the actual work involved. It relies on the integrity and reliability of the entity accredited. However, as long as the push is cheaper, faster and less testing, many will feed at the bottom of the barrel where these traits seem to fester. There are many good NBs, many good TCBs and many good CBs in the world and it only takes one or two ‘bottom feeder’ to spoil the entire taste of the pie. Thanks Dennis Ward This communication and its attachements contain information from PCTEST Engineering Laboratory, Inc., and I sintended for the exclusive use of the recipient(s) named above. It may contain information that is confidential and/or legally privileged. Any unauthorized use that may compromise that confidentiality via distribution or disclosure is prohibited. Please notify the sender immediately if you receive this communication in error, and delete it from your computer system. Usage of PCTEST email addresses for non-business related activities is strictly prohibited. No warranty is made that the e-mail or attachments(s) are free from computer virus or other defect. Thank you. From: Michael Derby [mailto:micha...@acbcert.com] Sent: Thursday, October 30, 2014 2:26 AM To: EMC-PSTC@LISTSERV.IEEE.ORG mailto:EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] New Radio Equipment Directive (RED) - please read if you sell wireless devices into Europe It’s a valid concern Tony. I imagine that ADCO in Europe are probably (hopefully) looking closely at any Notified Body who would issue a certificate for a Directive if they are not authorised to. There are no Notified Bodies designated to the RE Directive. I would like to think your waning confidence is in questionable Notified Bodies, rather than in the whole NB system. In the same way as you might be happy with the idea of FCC TCBs, despite the fact that some TCBs get it wrong. In the same way as you might be happy with the idea of test labs, despite the fact that some of them don’t seem to know how to test. Michael. Michael Derby Senior Regulatory Engineer Director ACB Europe From: Anthony Thomson [mailto:ton...@europe.com] Sent: 30 October 2014 09:16 To: EMC-PSTC@LISTSERV.IEEE.ORG mailto:EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] New Radio Equipment Directive (RED) - please read if you sell wireless devices into Europe But the thread started with Nick Hooper saying that Notified Body's were already, and have issued opinions against the RED. This is where my interest lies, in finding a NB to issue an opinion against the RED in the coming weeks, when I stumbled across Nicks post questioning the validity of these NB opinions. I though NB's were supposed to be competent and reliable. I often rely on them to ratify and confirm our regulatory position. Sounds pretty serious to me and I find my confidence in the whole NB system waning! T Sent: Thursday, October 30, 2014 at 8:52 AM From: Michael Derby micha...@acbcert.com mailto:micha...@acbcert.com To: EMC-PSTC@LISTSERV.IEEE.ORG mailto:EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] New Radio Equipment Directive (RED) - please read if you sell wireless devices into Europe Just to add to the conversation, I will throw in a little practicality……. There are two primary compliance routes for manufacturers to use the RE Directive, as with the RTTE Directive. A manufacturer can fully apply the harmonised standards. Or, a manufacturer can consult a Notified Body to obtain an opinion when harmonised standards are not fully applied. (I guess you could also add that there is the option for a quality assessment (Annex V of RTTE), using a Notified Body). For the RE Directive: There are no harmonised standards
Re: [PSES] New Radio Equipment Directive (RED) - please read if you sell wireless devices into Europe
Just to add to the conversation, I will throw in a little practicality……. There are two primary compliance routes for manufacturers to use the RE Directive, as with the RTTE Directive. A manufacturer can fully apply the harmonised standards. Or, a manufacturer can consult a Notified Body to obtain an opinion when harmonised standards are not fully applied. (I guess you could also add that there is the option for a quality assessment (Annex V of RTTE), using a Notified Body). For the RE Directive: There are no harmonised standards. There are no Notified Bodies. So, from a practical point of view, it is also impossible. Michael. Michael Derby Senior Regulatory Engineer Director ACB Europe From: Anthony Thomson [mailto:ton...@europe.com] Sent: 29 October 2014 15:00 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] New Radio Equipment Directive (RED) - please read if you sell wireless devices into Europe Hi Charlie, Thanks for your assistance, but I still can't see anything preventing one claiming compliance to the RED. It's an EU directive which does appear to be currently 'in force' across Europe, though not yet 'enforceable' by law. So why can't you claim compliance to the RED (assuming you do)? To coin a phrase... there's no law against it. Or is there? See my ongoing questions below. Regards, Tony Sent: Wednesday, October 29, 2014 at 12:59 PM From: Charlie Blackham char...@sulisconsultants.com To: Anthony Thomson ton...@europe.com, EMC-PSTC@LISTSERV.IEEE.ORG EMC-PSTC@LISTSERV.IEEE.ORG Subject: RE: [PSES] New Radio Equipment Directive (RED) - please read if you sell wireless devices into Europe Tony Article 48 says that the existing legislation (RTTE or EMC+LVD) may be used for equipment within scope of RED until 13 June 2017, provided it was on the market before 16 June 2016. T: Yes, I can see that Article 48 permits optionally applying the RTTED (et. al.), to new products, for 1 year after the RED becomes enforceable under law on 13 June 2016. However, I can't see how this sets the earliest date that compliance against the RED can be claimed, and this is what I'm trying to get to. Article 49 says that RED shall be applied from 13 June 2016 (in other words, it is won’t be applicable until then). T: Does Article 49 say the RED applies from 13 June 2016? To me, it tells Member States to have everything in place to comply with the directive by 12 June 2016 and start enforcement on 13 June 2016. It does not prevent companies complying before that date, does it? I'd have thought that companies are at liberty to comply with requirements before thay becomes legally mandatory and enforceable. T: Article 51 says the RED enters into force 20 days after publication in the OJ which equates to 11 June 2014. So the RED is currently in force. Sadly there is no definitions of in force or into force within the directive, so common definitions needs to apply. So from Article 51, isn't the RED already 'in force', though not yet enforceable under law?. T: So I can see that under Article 49 that there cannot be any laws in place to enforce the RED's application until 13 June 2016. Surely however you can claim conformance before then, you just cant be penalised for not doing so (considering the limitation of enforcement of Article 48). However . . . . It’s “only” a Directives. Directives have to be implemented into National Law, in at least one member state, before they can be used – that’s the part that currently stops you. T: Isn't that what stops Member States enforcing a Directive? Surely companies can still optionally conform to it, after all the RED seems to have been in force since 11 June 2014 (albeit not enforceable until 13 June 2016 or 13 June 2017 if you chose to apply the RTTED). T: Where does this thing about at least one member state come from? I'd like a black and white reference for this. It seems to be something lots of people say without any solid foundation. How can an EU directive be legally enforceable in one EU country and not another? Isn't it 'all or nothing' (hence the 13 June 2016 date in the RED). RED is not a simple NLF alignment like 2014/30/EU and 2014/35/EU because there is also a change of scope and a number of items are moving into RED from EMC/LVD and out of RTTE into EMC/LVD. There are commission workshops on RED and EMCD planned for November, and issues around transition are on the agenda. Regards Charlie From: Anthony Thomson [mailto:ton...@europe.com] Sent: 29 October 2014 12:34 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] New Radio Equipment Directive (RED) - please read if you sell wireless devices into Europe All, I'm completely confused by this situation and some clarity really would be appreciated. Where in the directive does it say you that can't currently claim compliance to the RED (well, as of 11 June 2015 - see below). I've heard
Re: [PSES] New Radio Equipment Directive (RED) - please read if you sell wireless devices into Europe
But the thread started with Nick Hooper saying that Notified Bodys were already, and have issued opinions against the RED. This is where my interest lies, in finding a NB to issue an opinion against the RED in the coming weeks, when I stumbled across Nicks post questioning the validity of these NB opinions. I though NBs were supposed to be competent and reliable. I often rely on them to ratify and confirm our regulatory position. Sounds pretty serious to me and I find my confidence in the whole NB system waning! T Sent:Thursday, October 30, 2014 at 8:52 AM From:Michael Derby micha...@acbcert.com To:EMC-PSTC@LISTSERV.IEEE.ORG Subject:Re: [PSES] New Radio Equipment Directive (RED) - please read if you sell wireless devices into Europe Just to add to the conversation, I will throw in a little practicality. There are two primary compliance routes for manufacturers to use the RE Directive, as with the RTTE Directive. A manufacturer can fully apply the harmonised standards. Or, a manufacturer can consult a Notified Body to obtain an opinion when harmonised standards are not fully applied. (I guess you could also add that there is the option for a quality assessment (Annex V of RTTE), using a Notified Body). For the RE Directive: There are no harmonised standards. There are no Notified Bodies. So, from a practical point of view, it is also impossible. Michael. Michael Derby Senior Regulatory Engineer Director ACB Europe From: Anthony Thomson [mailto:ton...@europe.com] Sent: 29 October 2014 15:00 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] New Radio Equipment Directive (RED) - please read if you sell wireless devices into Europe Hi Charlie, Thanks for your assistance, but I still cant see anything preventing one claiming compliance to the RED. Its an EU directive which does appear to be currently in force across Europe, though not yet enforceable by law. So why cant you claim compliance to the RED (assuming you do)?To coin a phrase... theres no law against it. Or is there? See my ongoing questions below. Regards, Tony Sent:Wednesday, October 29, 2014 at 12:59 PM From:Charlie Blackham char...@sulisconsultants.com To:Anthony Thomson ton...@europe.com, EMC-PSTC@LISTSERV.IEEE.ORG EMC-PSTC@LISTSERV.IEEE.ORG Subject:RE: [PSES] New Radio Equipment Directive (RED) - please read if you sell wireless devices into Europe Tony Article 48 says that the existing legislation (RTTE or EMC+LVD) may be used for equipment within scope of RED until 13 June 2017, provided it was on the market before 16 June 2016. T:Yes, I can see that Article 48 permits optionally applying the RTTED (et. al.), to new products, for 1 year after the RED becomes enforceable under law on 13 June 2016. However, I cant see how this sets the earliest date that compliance against the RED can be claimed, and this is what Im trying to get to. Article 49 says that RED shall be applied from 13 June 2016 (in other words, it is wont be applicable until then). T: Does Article 49 say the RED applies from 13 June 2016?To me, it tellsMember Statesto have everything in place to comply with the directive by 12 June 2016 and start enforcement on 13 June 2016. It does not preventcompaniescomplying before that date, does it? Id have thought that companies are at liberty to comply with requirements before thay becomes legally mandatory and enforceable. T: Article 51 says the RED enters into force 20 days after publication in the OJ which equates to 11 June 2014. So the RED is currently in force. Sadly there is no definitions of in force or into force within the directive, so common definitions needs to apply. So fromArticle 51, isnt the RED already in force, though not yet enforceable under law?. T: So I can see that under Article 49 that there cannot be any laws in place to enforce the REDs application until 13 June 2016. Surely however you can claim conformance before then, you just cant be penalised for not doing so (considering the limitation of enforcement of Article 48). However . . . . Its only a Directives. Directives have to be implemented into National Law, in at least one member state, before they can be used thats the part that currently stops you. T: Isnt that what stops Member States enforcing a Directive? Surely companies can still optionally conform to it, after all the RED seems to have been in force since 11 June 2014 (albeit not enforceable until 13 June 2016 or 13 June 2017 if you chose to apply the RTTED). T: Where does this thing about at least one member state come from? Id like a black and white reference for this. It seems to be something lots of people say without any solid foundation. How can an EU directive be legally enforceable in one EU country and not another? Isnt it all or nothing (hence the 13 June 2016 date in the RED). RED is not a simple NLF alignment like 2014/30/EU and 2014/35/EU because there is also a change
Re: [PSES] New Radio Equipment Directive (RED) - please read if you sell wireless devices into Europe
It’s a valid concern Tony. I imagine that ADCO in Europe are probably (hopefully) looking closely at any Notified Body who would issue a certificate for a Directive if they are not authorised to. There are no Notified Bodies designated to the RE Directive. I would like to think your waning confidence is in questionable Notified Bodies, rather than in the whole NB system. In the same way as you might be happy with the idea of FCC TCBs, despite the fact that some TCBs get it wrong. In the same way as you might be happy with the idea of test labs, despite the fact that some of them don’t seem to know how to test. Michael. Michael Derby Senior Regulatory Engineer Director ACB Europe From: Anthony Thomson [mailto:ton...@europe.com] Sent: 30 October 2014 09:16 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] New Radio Equipment Directive (RED) - please read if you sell wireless devices into Europe But the thread started with Nick Hooper saying that Notified Body's were already, and have issued opinions against the RED. This is where my interest lies, in finding a NB to issue an opinion against the RED in the coming weeks, when I stumbled across Nicks post questioning the validity of these NB opinions. I though NB's were supposed to be competent and reliable. I often rely on them to ratify and confirm our regulatory position. Sounds pretty serious to me and I find my confidence in the whole NB system waning! T Sent: Thursday, October 30, 2014 at 8:52 AM From: Michael Derby micha...@acbcert.com To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] New Radio Equipment Directive (RED) - please read if you sell wireless devices into Europe Just to add to the conversation, I will throw in a little practicality……. There are two primary compliance routes for manufacturers to use the RE Directive, as with the RTTE Directive. A manufacturer can fully apply the harmonised standards. Or, a manufacturer can consult a Notified Body to obtain an opinion when harmonised standards are not fully applied. (I guess you could also add that there is the option for a quality assessment (Annex V of RTTE), using a Notified Body). For the RE Directive: There are no harmonised standards. There are no Notified Bodies. So, from a practical point of view, it is also impossible. Michael. Michael Derby Senior Regulatory Engineer Director ACB Europe From: Anthony Thomson [mailto:ton...@europe.com] Sent: 29 October 2014 15:00 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] New Radio Equipment Directive (RED) - please read if you sell wireless devices into Europe Hi Charlie, Thanks for your assistance, but I still can't see anything preventing one claiming compliance to the RED. It's an EU directive which does appear to be currently 'in force' across Europe, though not yet 'enforceable' by law. So why can't you claim compliance to the RED (assuming you do)? To coin a phrase... there's no law against it. Or is there? See my ongoing questions below. Regards, Tony Sent: Wednesday, October 29, 2014 at 12:59 PM From: Charlie Blackham char...@sulisconsultants.com To: Anthony Thomson ton...@europe.com, EMC-PSTC@LISTSERV.IEEE.ORG EMC-PSTC@LISTSERV.IEEE.ORG Subject: RE: [PSES] New Radio Equipment Directive (RED) - please read if you sell wireless devices into Europe Tony Article 48 says that the existing legislation (RTTE or EMC+LVD) may be used for equipment within scope of RED until 13 June 2017, provided it was on the market before 16 June 2016. T: Yes, I can see that Article 48 permits optionally applying the RTTED (et. al.), to new products, for 1 year after the RED becomes enforceable under law on 13 June 2016. However, I can't see how this sets the earliest date that compliance against the RED can be claimed, and this is what I'm trying to get to. Article 49 says that RED shall be applied from 13 June 2016 (in other words, it is won’t be applicable until then). T: Does Article 49 say the RED applies from 13 June 2016? To me, it tells Member States to have everything in place to comply with the directive by 12 June 2016 and start enforcement on 13 June 2016. It does not prevent companies complying before that date, does it? I'd have thought that companies are at liberty to comply with requirements before thay becomes legally mandatory and enforceable. T: Article 51 says the RED enters into force 20 days after publication in the OJ which equates to 11 June 2014. So the RED is currently in force. Sadly there is no definitions of in force or into force within the directive, so common definitions needs to apply. So from Article 51, isn't the RED already 'in force', though not yet enforceable under law?. T: So I can see that under Article 49 that there cannot be any laws in place to enforce the RED's application until 13 June 2016. Surely however you can claim conformance before then, you just
Re: [PSES] New Radio Equipment Directive (RED) - please read if you sell wireless devices into Europe
Thank you Charlie and Michael for your comments For clarity: If you read my original email, I stated there will NOT be a RED NB NANDO database until the end of 2015/early 2016 at the earliest, there is NO formal date yet, it may be later, the EU accreditation bodies have a lot of work to do on this. It seems some NB have made Opinions/certificates against the RED, and as the MSA (Member State Authorities) find evidence, they ARE being “taken to task”, as they are not appointed as NB for the RED, yet. So a RTTE NB has no appointment (NANDO database listing) to issue a NB EU type examination Certificate for the RED, they are, at best, misleading their customers, they cannot give such a certificate. If a manufacturer signs a DoC for the RED, then they can be (and some MSA are) challenged, as Michael correctly pointed out, there are no harmonised standards for the RED (needed to self-declare for Article 3.2) or a NB EU Type Examination Certificate (and there are no RED NBs. The RED has additional technical requirements (in most cases) over the RTTE ones, so the current RTTE OJEU cannot be used. Once published by a country the RED is legal, but not applicable until the 13 June 2016. I have requested the EU commission add some explanation on the timeline for the RED implementation to the Europa web page, I wait in hope…. Regards Nick Nick Hooper BSc(Eng) CEng MIET Chairman RTTE CA UL Grove House Business Centre, Chineham Court, Lutyens, Basingstoke, Hampshire, RG24 8AG, England T: +44 1256 31 2097 | F: +44 1256 31 2001 | M: +44 7970 429 665 E: nick.hoo...@ul.commailto:nick.hoo...@ul.com | W: www.ul.comhttp://www.ul.com/ This email and any files transmitted with it are confidential and intended solely for the use of the individual or entity to whom they are addressed. If you have received this email in error please delete it, destroy all copies of it and notify the sender. From: Anthony Thomson [mailto:ton...@europe.com] Sent: 30 October 2014 09:16 To: EMC-PSTC@LISTSERV.IEEE.ORGmailto:EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] New Radio Equipment Directive (RED) - please read if you sell wireless devices into Europe But the thread started with Nick Hooper saying that Notified Body's were already, and have issued opinions against the RED. This is where my interest lies, in finding a NB to issue an opinion against the RED in the coming weeks, when I stumbled across Nicks post questioning the validity of these NB opinions. I though NB's were supposed to be competent and reliable. I often rely on them to ratify and confirm our regulatory position. Sounds pretty serious to me and I find my confidence in the whole NB system waning! T Sent: Thursday, October 30, 2014 at 8:52 AM From: Michael Derby micha...@acbcert.commailto:micha...@acbcert.com To: EMC-PSTC@LISTSERV.IEEE.ORGmailto:EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] New Radio Equipment Directive (RED) - please read if you sell wireless devices into Europe Just to add to the conversation, I will throw in a little practicality……. There are two primary compliance routes for manufacturers to use the RE Directive, as with the RTTE Directive. A manufacturer can fully apply the harmonised standards. Or, a manufacturer can consult a Notified Body to obtain an opinion when harmonised standards are not fully applied. (I guess you could also add that there is the option for a quality assessment (Annex V of RTTE), using a Notified Body). For the RE Directive: There are no harmonised standards. There are no Notified Bodies. So, from a practical point of view, it is also impossible. Michael. Michael Derby Senior Regulatory Engineer Director ACB Europe From: Anthony Thomson [mailto:ton...@europe.com] Sent: 29 October 2014 15:00 To: EMC-PSTC@LISTSERV.IEEE.ORGmailto:EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] New Radio Equipment Directive (RED) - please read if you sell wireless devices into Europe Hi Charlie, Thanks for your assistance, but I still can't see anything preventing one claiming compliance to the RED. It's an EU directive which does appear to be currently 'in force' across Europe, though not yet 'enforceable' by law. So why can't you claim compliance to the RED (assuming you do)? To coin a phrase... there's no law against it. Or is there? See my ongoing questions below. Regards, Tony Sent: Wednesday, October 29, 2014 at 12:59 PM From: Charlie Blackham char...@sulisconsultants.com To: Anthony Thomson ton...@europe.com, EMC-PSTC@LISTSERV.IEEE.ORG EMC-PSTC@LISTSERV.IEEE.ORG Subject: RE: [PSES] New Radio Equipment Directive (RED) - please read if you sell wireless devices into Europe Tony Article 48 says that the existing legislation (RTTE or EMC+LVD) may be used for equipment within scope of RED until 13 June 2017, provided it was on the market before 16 June 2016. T: Yes, I can see that Article 48 permits optionally applying the RTTED
Re: [PSES] New Radio Equipment Directive (RED) - please read if you sell wireless devices into Europe
In message trinity-c7f8980a-c01d-4abe-893f-a806ac973fc9-1414660564674@3capp-mailcom -lxa01, dated Thu, 30 Oct 2014, Anthony Thomson ton...@europe.com writes: But the thread started with Nick Hooper saying that Notified Body's were already, and have issued opinions against the RED. This is where my interest lies, in finding a NB to issue an opinion against the RED in the coming weeks, when I stumbled across Nicks post questioning the validity of these NB opinions. I though NB's were supposed to be competent and reliable. I often rely on them to ratify and confirm our regulatory position. Sounds pretty serious to me and I find my confidence in the whole NB system waning! Misunderstanding. Due to some problems with below-par notified bodies in some countries, all NBs have to re-register for RED (and this applies to some other Directives, I think). So, NBs exist but they are not yet registered under the RED (and it is alleged that the process may have run into difficulties). The same applies to notified standards. There is no OJ list for the RED yet. But the existing harmonized standards have not been withdrawn. -- OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk Quid faciamus nisi sit? John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - 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
Re: [PSES] New Radio Equipment Directive (RED) - please read if you sell wireless devices into Europe
In message 2655b21dc209421abdc4eeb95de1a...@bn1pr04mb309.namprd04.prod.outlook.com , dated Thu, 30 Oct 2014, Hooper, Nick nick.hoo...@ul.com writes: So a RTTE NB has no appointment (NANDO database listing) to issue a NB EU type examination Certificate for the RED, they are, at best, misleading their customers, they cannot give such a certificate. True, of course, but they can issue a certificate with a suitable disclaimer, so as not to mislead. -- OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk Quid faciamus nisi sit? John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - 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
Re: [PSES] New Radio Equipment Directive (RED) - please read if you sell wireless devices into Europe
Hi John, What would the disclaimer be in this case? Disclaimer: We are not a Notified Body to the RE Directive and this document is legally invalid as a Notified Body certificate ? It doesn't sound like a very useful certificate. Michael. Michael Derby Senior Regulatory Engineer Director ACB Europe -Original Message- From: John Woodgate [mailto:j...@jmwa.demon.co.uk] Sent: 30 October 2014 11:26 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] New Radio Equipment Directive (RED) - please read if you sell wireless devices into Europe In message 2655b21dc209421abdc4eeb95de1a...@bn1pr04mb309.namprd04.prod.outlook.com , dated Thu, 30 Oct 2014, Hooper, Nick nick.hoo...@ul.com writes: So a RTTE NB has no appointment (NANDO database listing) to issue a NB EU type examination Certificate for the RED, they are, at best, misleading their customers, they cannot give such a certificate. True, of course, but they can issue a certificate with a suitable disclaimer, so as not to mislead. -- OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk Quid faciamus nisi sit? John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - 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 - 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
Re: [PSES] New Radio Equipment Directive (RED) - please read if you sell wireless devices into Europe
I think Nick was being diplomatic - they can do no such thing, any more than they could give a certificate to the ATEX or MDD directives unless suitably appointed. Charlie -Original Message- From: John Woodgate [mailto:j...@jmwa.demon.co.uk] Sent: 30 October 2014 11:26 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] New Radio Equipment Directive (RED) - please read if you sell wireless devices into Europe In message 2655b21dc209421abdc4eeb95de1a...@bn1pr04mb309.namprd04.prod.outlook.com , dated Thu, 30 Oct 2014, Hooper, Nick nick.hoo...@ul.com writes: So a RTTE NB has no appointment (NANDO database listing) to issue a NB EU type examination Certificate for the RED, they are, at best, misleading their customers, they cannot give such a certificate. True, of course, but they can issue a certificate with a suitable disclaimer, so as not to mislead. -- OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk Quid faciamus nisi sit? John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - 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 - 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
Re: [PSES] New Radio Equipment Directive (RED) - please read if you sell wireless devices into Europe
Very interesting topic. I am of the opinion that until the NB is NANDO listed, they could not offer a NB Type Examination Certificate against the RED. He/she may offer an opinion as a consultant - for what it may be worth. I agree with Michael's comments with regard to waning confidence in labs, TCB's and NB's. Fortunately the members of this forum are not likely the ones to be concerned about, as they are likely the ones who make an attempt at understanding their responsibilities by staying involved in relevant groups, committees and activities. Bill Stumpf D.L.S. Electronic Systems, Inc. 166 South Carter Street Genoa City WI 53128 -Original Message- From: Michael Derby [mailto:micha...@acbcert.com] Sent: Thursday, October 30, 2014 6:41 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] New Radio Equipment Directive (RED) - please read if you sell wireless devices into Europe Hi John, What would the disclaimer be in this case? Disclaimer: We are not a Notified Body to the RE Directive and this document is legally invalid as a Notified Body certificate ? It doesn't sound like a very useful certificate. Michael. Michael Derby Senior Regulatory Engineer Director ACB Europe -Original Message- From: John Woodgate [mailto:j...@jmwa.demon.co.uk] Sent: 30 October 2014 11:26 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] New Radio Equipment Directive (RED) - please read if you sell wireless devices into Europe In message 2655b21dc209421abdc4eeb95de1a...@bn1pr04mb309.namprd04.prod.outlook.com , dated Thu, 30 Oct 2014, Hooper, Nick nick.hoo...@ul.com writes: So a RTTE NB has no appointment (NANDO database listing) to issue a NB EU type examination Certificate for the RED, they are, at best, misleading their customers, they cannot give such a certificate. True, of course, but they can issue a certificate with a suitable disclaimer, so as not to mislead. -- OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk Quid faciamus nisi sit? John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - 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 - 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 - 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
Re: [PSES] New Radio Equipment Directive (RED) - please read if you sell wireless devices into Europe
That raises a question for hopefully not only me. Is, or will, ETSI be revising it's RTTE referenced standards? And if so, does anyone have any information as to when that will be completed? Hopefully it'll be completed before the RTTE to RED transition ends. I look forward to your reply. Best regards,Ron PickardSent from my smartphone -- Original message--From: John WoodgateDate: Thu, Oct 30, 2014 4:40 AMTo: EMC-PSTC@LISTSERV.IEEE.ORG;Subject:Re: [PSES] New Radio Equipment Directive (RED) - please read if you sell wireless devices into EuropeIn message , dated Thu, 30 Oct 2014, Anthony Thomson writes:But the thread started with Nick Hooper saying that Notified Body's were already, and have issued opinions against the RED. This is where my interest lies, in finding a NB to issue an opinion against the RED in the coming weeks, when I stumbled across Nicks post questioning the validity of these NB opinions. I though NB's were supposed to be competent and reliable. I often rely on them to ratify and confirm our regulatory position. Sounds pretty serious to me and I find my confidence in the whole NB system waning!Misunderstanding. Due to some problems with below-par notified bodies in some countries, all NBs have to re-register for RED (and this applies to some other Directives, I think). So, NBs exist but they are not yet registered under the RED (and it is alleged that the process may have run into difficulties).The same applies to notified standards. There is no OJ list for the RED yet. But the existing harmonized standards have not been withdrawn.-- OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.ukQuid faciamus nisi sit?John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK-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 All emc-pstc postings are archived and searchable on the web at:http://www.ieee-pses.org/emc-pstc.htmlAttachments 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.htmlFor help, send mail to the list administrators:Scott Douglas Mike Cantwell For policy questions, send mail to:Jim Bacher: David Heald: - 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
Re: [PSES] New Radio Equipment Directive (RED) - please read if you sell wireless devices into Europe
Yes, ETSI are working on new standards and updates to old standards. As you say, they do have a timeline goal to work towards! Michael. Michael Derby Senior Regulatory Engineer Director ACB Europe From: rpick...@rpqconsulting.com [mailto:rpick...@rpqconsulting.com] Sent: 30 October 2014 19:25 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] New Radio Equipment Directive (RED) - please read if you sell wireless devices into Europe That raises a question for hopefully not only me. Is, or will, ETSI be revising it's RTTE referenced standards? And if so, does anyone have any information as to when that will be completed? Hopefully it'll be completed before the RTTE to RED transition ends. I look forward to your reply. Best regards, Ron Pickard Sent from my smartphone -- Original message-- From: John Woodgate Date: Thu, Oct 30, 2014 4:40 AM To: EMC-PSTC@LISTSERV.IEEE.ORG; Subject:Re: [PSES] New Radio Equipment Directive (RED) - please read if you sell wireless devices into Europe In message , dated Thu, 30 Oct 2014, Anthony Thomson writes:But the thread started with Nick Hooper saying that Notified Body's were already, and have issued opinions against the RED. This is where my interest lies, in finding a NB to issue an opinion against the RED in the coming weeks, when I stumbled across Nicks post questioning the validity of these NB opinions. I though NB's were supposed to be competent and reliable. I often rely on them to ratify and confirm our regulatory position. Sounds pretty serious to me and I find my confidence in the whole NB system waning!Misunderstanding. Due to some problems with below-par notified bodies in some countries, all NBs have to re-register for RED (and this applies to some other Directives, I think). So, NBs exist but they are not yet registered under the RED (and it is alleged that the process may have run into difficulties).The same applies to notified standards. There is no OJ list for the RED yet. But the existing harmonized standards have not been withdrawn.-- OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.ukQuid faciamus nisi sit?John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK-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 All emc-pstc postings are archived and searchable on the web at:http://www.ieee-pses.org/emc-pstc.htmlAttachments 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.htmlFor help, send mail to the list administrators:Scott Douglas Mike Cantwell For policy questions, send mail to:Jim Bacher: David Heald: - 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) 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 Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher j.bac...@ieee.org David Heald 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
Re: [PSES] New Radio Equipment Directive (RED) - please read if you sell wireless devices into Europe
In message 000f424e.68967bf92ace4...@rpqconsulting.com, dated Thu, 30 Oct 2014, rpick...@rpqconsulting.com rpick...@rpqconsulting.com writes: Is, or will, ETSI be revising it's RTTE referenced standards? And if so, does anyone have any information as to when that will be completed? Hopefully it'll be completed before the RTTE to RED transition ends. That's just another elephant in the room. It's a huge job. -- OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk Quid faciamus nisi sit? John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - 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
Re: [PSES] New Radio Equipment Directive (RED) - please read if you sell wireless devices into Europe
In message 17fe01cff478$206e8300$614b8900$@acbcert.com, dated Thu, 30 Oct 2014, Michael Derby micha...@acbcert.com writes: As you say, they do have a timeline goal to work towards! A goal, yes, but scoring it is another matter entirely. -- OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk Quid faciamus nisi sit? John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - 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
[PSES] SV: [PSES] New Radio Equipment Directive (RED) - please read if you sell wireless devices into Europe
RED applies from when the first EU/EEA member state has implemented the directive into national law? #Amund Fra: Hooper, Nick [mailto:nick.hoo...@ul.com] Sendt: 28. oktober 2014 12:04 Til: EMC-PSTC@LISTSERV.IEEE.ORG Emne: [PSES] New Radio Equipment Directive (RED) - please read if you sell wireless devices into Europe Hello everyone. I have been in discussion with the EU Commission and ADCO chairman as there seems to be an amount of misunderstanding on when you can declare compliance to the RED. I explained to Lucio that we have seen a few cases of DoC and NB opinions to the new RED, and therefore had a question on the validity of these documents. Below is the response received from the ADCO RTTE Chairman. Dear Nick We have already had such problems and administrative non compliances :) The new Directive (RED) is currently not applicable (will be applicable to products first placed on market as of 13 June 2016). Hence the manufacturers cannot use, right now (i.e. for products placed on market before 13 June 2016), the references of RED (new Directive). Best regards Lucio Lucio Cocciantelli ADCO RTTE Chairman Please ensure you read Artcile 48 to 50 of the RED, and pass this information on asap. Notified Bodies should not be issuing Opinions to the RED until they are listed, on the yet to be published, NANDO database for RED Notified Bodies. As the accreditation assessments will be taking place over the next year, it is unlikely the RED NANDO list will be published until late 2015 / early 2016 Nick Hooper BSc(Eng) CEng MIET Chairman RTTE CA UL Grove House Business Centre, Chineham Court, Lutyens, Basingstoke, Hampshire, RG24 8AG, England This e-mail may contain privileged or confidential information. If you are not the intended recipient: (1) you may not disclose, use, distribute, copy or rely upon this message or attachment(s); and (2) please notify the sender by reply e-mail, and then delete this message and its attachment(s). Underwriters Laboratories Inc. and its affiliates disclaim all liability for any errors, omissions, corruption or virus in this message or any attachments. - 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 emcp...@radiusnorth.net mailto:emcp...@radiusnorth.net 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
Re: [PSES] New Radio Equipment Directive (RED) - please read if you sell wireless devices into Europe
Hi Articles 48 to 50 will also be implemented as part of the National Law, hence enforcing the dates below Best regards Nick From: Amund Westin [mailto:am...@westin-emission.no] Sent: 29 October 2014 07:52 To: Hooper, Nick; EMC-PSTC@LISTSERV.IEEE.ORG Subject: SV: [PSES] New Radio Equipment Directive (RED) - please read if you sell wireless devices into Europe RED applies from when the first EU/EEA member state has implemented the directive into national law? #Amund Fra: Hooper, Nick [mailto:nick.hoo...@ul.com] Sendt: 28. oktober 2014 12:04 Til: EMC-PSTC@LISTSERV.IEEE.ORGmailto:EMC-PSTC@LISTSERV.IEEE.ORG Emne: [PSES] New Radio Equipment Directive (RED) - please read if you sell wireless devices into Europe Hello everyone. I have been in discussion with the EU Commission and ADCO chairman as there seems to be an amount of misunderstanding on when you can declare compliance to the RED. I explained to Lucio that we have seen a few cases of DoC and NB opinions to the new RED, and therefore had a question on the validity of these documents. Below is the response received from the ADCO RTTE Chairman. Dear Nick We have already had such problems and administrative non compliances :) The new Directive (RED) is currently not applicable (will be applicable to products first placed on market as of 13 June 2016). Hence the manufacturers cannot use, right now (i.e. for products placed on market before 13 June 2016), the references of RED (new Directive). Best regards Lucio Lucio Cocciantelli ADCO RTTE Chairman Please ensure you read Artcile 48 to 50 of the RED, and pass this information on asap. Notified Bodies should not be issuing Opinions to the RED until they are listed, on the yet to be published, NANDO database for RED Notified Bodies. As the accreditation assessments will be taking place over the next year, it is unlikely the RED NANDO list will be published until late 2015 / early 2016 Nick Hooper BSc(Eng) CEng MIET Chairman RTTE CA UL Grove House Business Centre, Chineham Court, Lutyens, Basingstoke, Hampshire, RG24 8AG, England This e-mail may contain privileged or confidential information. If you are not the intended recipient: (1) you may not disclose, use, distribute, copy or rely upon this message or attachment(s); and (2) please notify the sender by reply e-mail, and then delete this message and its attachment(s). Underwriters Laboratories Inc. and its affiliates disclaim all liability for any errors, omissions, corruption or virus in this message or any attachments. - 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.orgmailto: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 emcp...@radiusnorth.netmailto:emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.orgmailto:mcantw...@ieee.org For policy questions, send mail to: Jim Bacher j.bac...@ieee.orgmailto:j.bac...@ieee.org David Heald dhe...@gmail.commailto:dhe...@gmail.com This e-mail may contain privileged or confidential information. If you are not the intended recipient: (1) you may not disclose, use, distribute, copy or rely upon this message or attachment(s); and (2) please notify the sender by reply e-mail, and then delete this message and its attachment(s). Underwriters Laboratories Inc. and its affiliates disclaim all liability for any errors, omissions, corruption or virus in this message or any attachments. - 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
Re: [PSES] New Radio Equipment Directive (RED) - please read if you sell wireless devices into Europe
All, Im completely confused by this situation and some clarity really would be appreciated. Where in the directive does it say you that cant currently claim compliance to the RED (well, as of 11 June 2015 - see below). Ive heard Amunds comments below from other sources too, but I cannot find any basis for this in the directive. Articles 48 through 50 mentioned by Nick merely state: 1. That the authorities cannot impede goods based on the RED until 13 June 2016 (Article 48). 2. That EU countries RED enforcement laws shall be in place before, and applied from 13 June 2016 (Article 49). 3. The RTTED is repealed on 13June 2016. None say you cant claim compliance to the RED. Now... Article 51 states that the RED shall enter into force on the 20th day following its publication in the OJ. Correct me if I am wrong, but I believe the RED was published in the the OJ on 22 May 2014 and has therefore been in force from the 11June 2015. So if its in force, providing you meet the provisions of the RED, which article(s) prevents claiming conformity? After all, it is (interpretation, which may well be wrong) in force? I admit that I havent scrutinised the whole document and all its references, so I presume that I have missed some key facts.The benefit of greater experience really would be appreciated. Tony Sent:Wednesday, October 29, 2014 at 8:08 AM From:Hooper, Nick nick.hoo...@ul.com To:EMC-PSTC@LISTSERV.IEEE.ORG Subject:Re: [PSES] New Radio Equipment Directive (RED) - please read if you sell wireless devices into Europe Hi Articles 48 to 50 will also be implemented as part of the National Law, hence enforcing the dates below Best regards Nick From: Amund Westin [mailto:am...@westin-emission.no] Sent: 29 October 2014 07:52 To: Hooper, Nick; EMC-PSTC@LISTSERV.IEEE.ORG Subject: SV: [PSES] New Radio Equipment Directive (RED) - please read if you sell wireless devices into Europe RED applies from when the first EU/EEA member state has implemented the directive into national law? #Amund Fra: Hooper, Nick [mailto:nick.hoo...@ul.com] Sendt: 28. oktober 2014 12:04 Til: EMC-PSTC@LISTSERV.IEEE.ORG Emne: [PSES] New Radio Equipment Directive (RED) - please read if you sell wireless devices into Europe Hello everyone. I have been in discussion with the EU Commission and ADCO chairman as there seems to be an amount of misunderstanding on when you can declare compliance to the RED. I explained to Lucio that we have seen a few cases of DoC and NB opinions to the new RED, and therefore had a question on the validity of these documents. Below is the response received from the ADCO RTTE Chairman. Dear Nick We have already had such problems and administrative non compliances J The new Directive (RED) is currently not applicable (will be applicable to products first placed on market as of 13 June 2016). Hence the manufacturers cannot use, right now (i.e. for products placed on market before 13 June 2016), the references of RED (new Directive). Best regards Lucio Lucio Cocciantelli ADCO RTTE Chairman Please ensure you read Artcile 48 to 50 of the RED, and pass this information on asap. Notified Bodies should not be issuing Opinions to the RED until they are listed, on the yet to be published, NANDO database for RED Notified Bodies. As the accreditation assessments will be taking place over the next year, it is unlikely the RED NANDO list will be published until late 2015 / early 2016 Nick Hooper BSc(Eng) CEng MIET Chairman RTTE CA UL Grove House Business Centre, Chineham Court, Lutyens, Basingstoke, Hampshire, RG24 8AG, England This e-mail may contain privileged or confidential information. If you are not the intended recipient: (1) you may not disclose, use, distribute, copy or rely upon this message or attachment(s); and (2) please notify the sender by reply e-mail, and then delete this message and its attachment(s). Underwriters Laboratories Inc. and its affiliates disclaim all liability for any errors, omissions, corruption or virus in this message or any attachments. - 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 emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send
Re: [PSES] New Radio Equipment Directive (RED) - please read if you sell wireless devices into Europe
Tony Article 48 says that the existing legislation (RTTE or EMC+LVD) may be used for equipment within scope of RED until 13 June 2017, provided it was on the market before 16 June 2016. Article 49 says that RED shall be applied from 13 June 2016 (in other words, it is won’t be applicable until then). However . . . . It’s “only” a Directives. Directives have to be implemented into National Law, in at least one member state, before they can be used – that’s the part that currently stops you. RED is not a simple NLF alignment like 2014/30/EU and 2014/35/EU because there is also a change of scope and a number of items are moving into RED from EMC/LVD and out of RTTE into EMC/LVD. There are commission workshops on RED and EMCD planned for November, and issues around transition are on the agenda. Regards Charlie From: Anthony Thomson [mailto:ton...@europe.com] Sent: 29 October 2014 12:34 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] New Radio Equipment Directive (RED) - please read if you sell wireless devices into Europe All, I'm completely confused by this situation and some clarity really would be appreciated. Where in the directive does it say you that can't currently claim compliance to the RED (well, as of 11 June 2015 - see below). I've heard Amund's comments below from other sources too, but I cannot find any basis for this in the directive. Articles 48 through 50 mentioned by Nick merely state: 1. That the authorities cannot impede goods based on the RED until 13 June 2016 (Article 48). 2. That EU countries RED enforcement laws shall be in place before, and applied from 13 June 2016 (Article 49). 3. The RTTED is repealed on 13 June 2016. None say you can't claim compliance to the RED. Now... Article 51 states that the RED shall enter into force on the 20th day following its publication in the OJ. Correct me if I am wrong, but I believe the RED was published in the the OJ on 22 May 2014 and has therefore been in force from the 11 June 2015. So if it's in force, providing you meet the provisions of the RED, which article(s) prevents claiming conformity? After all, it is (interpretation, which may well be wrong) in force? I admit that I haven't scrutinised the whole document and all its references, so I presume that I have missed some key facts. The benefit of greater experience really would be appreciated. Tony Sent: Wednesday, October 29, 2014 at 8:08 AM From: Hooper, Nick nick.hoo...@ul.commailto:nick.hoo...@ul.com To: EMC-PSTC@LISTSERV.IEEE.ORGmailto:EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] New Radio Equipment Directive (RED) - please read if you sell wireless devices into Europe Hi Articles 48 to 50 will also be implemented as part of the National Law, hence enforcing the dates below Best regards Nick From: Amund Westin [mailto:am...@westin-emission.no] Sent: 29 October 2014 07:52 To: Hooper, Nick; EMC-PSTC@LISTSERV.IEEE.ORGmailto:EMC-PSTC@LISTSERV.IEEE.ORG Subject: SV: [PSES] New Radio Equipment Directive (RED) - please read if you sell wireless devices into Europe RED applies from when the first EU/EEA member state has implemented the directive into national law? #Amund Fra: Hooper, Nick [mailto:nick.hoo...@ul.comnick.hoo...@ul.com] Sendt: 28. oktober 2014 12:04 Til: EMC-PSTC@LISTSERV.IEEE.ORG Emne: [PSES] New Radio Equipment Directive (RED) - please read if you sell wireless devices into Europe Hello everyone. I have been in discussion with the EU Commission and ADCO chairman as there seems to be an amount of misunderstanding on when you can declare compliance to the RED. I explained to Lucio that we have seen a few cases of DoC and NB opinions to the new RED, and therefore had a question on the validity of these documents. Below is the response received from the ADCO RTTE Chairman. “Dear Nick We have already had such problems and administrative non compliances ☺ The new Directive (RED) is currently not applicable (will be applicable to products first placed on market as of 13 June 2016). Hence the manufacturers cannot use, right now (i.e. for products placed on market before 13 June 2016), the references of RED (new Directive). Best regards Lucio Lucio Cocciantelli ADCO RTTE Chairman” Please ensure you read Artcile 48 to 50 of the RED, and pass this information on asap. Notified Bodies should not be issuing Opinions to the RED until they are listed, on the yet to be published, NANDO database for RED Notified Bodies. As the accreditation assessments will be taking place over the next year, it is unlikely the RED NANDO list will be published until late 2015 / early 2016 Nick Hooper BSc(Eng) CEng MIET Chairman RTTE CA UL Grove House Business Centre, Chineham Court, Lutyens, Basingstoke, Hampshire, RG24 8AG, England This e-mail may contain privileged or confidential information. If you are not the intended recipient: (1) you may not disclose, use, distribute, copy
Re: [PSES] New Radio Equipment Directive (RED) - please read if you sell wireless devices into Europe
Tony, The ‘trick’ is that directives are not “addressed” to manufacturers, or any other economic actor, but rather they are addressed to member states of the EU. Therefore, ‘coming into effect’ means member states have to consider themselves put on notice to do what the directive instructs them to do from the given entry into force date. The RED says (Art 49.1) that member states have to adopt legislative instruments to realize the directive and have such instruments apply from 13Jun2016. Therefore all member states are expected to begin enforcement on commerce on that date, but If no member state does this (highly unlikely), then the RED will have no impact on commerce. The best plan is to declare to RED on or after 13Jun2016 (just assume some member state is going to follow their instructions), but Art. 48 says that stuff conforming to the old rules (e.g., RTTED) should be allowed in commerce until 13Jun2017. Regards, Lauren Crane KLA-Tencor From: Anthony Thomson [mailto:ton...@europe.com] Sent: Wednesday, October 29, 2014 7:34 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] New Radio Equipment Directive (RED) - please read if you sell wireless devices into Europe All, I'm completely confused by this situation and some clarity really would be appreciated. Where in the directive does it say you that can't currently claim compliance to the RED (well, as of 11 June 2015 - see below). I've heard Amund's comments below from other sources too, but I cannot find any basis for this in the directive. Articles 48 through 50 mentioned by Nick merely state: 1. That the authorities cannot impede goods based on the RED until 13 June 2016 (Article 48). 2. That EU countries RED enforcement laws shall be in place before, and applied from 13 June 2016 (Article 49). 3. The RTTED is repealed on 13 June 2016. None say you can't claim compliance to the RED. Now... Article 51 states that the RED shall enter into force on the 20th day following its publication in the OJ. Correct me if I am wrong, but I believe the RED was published in the the OJ on 22 May 2014 and has therefore been in force from the 11 June 2015. So if it's in force, providing you meet the provisions of the RED, which article(s) prevents claiming conformity? After all, it is (interpretation, which may well be wrong) in force? I admit that I haven't scrutinised the whole document and all its references, so I presume that I have missed some key facts. The benefit of greater experience really would be appreciated. Tony Sent: Wednesday, October 29, 2014 at 8:08 AM From: Hooper, Nick nick.hoo...@ul.commailto:nick.hoo...@ul.com To: EMC-PSTC@LISTSERV.IEEE.ORGmailto:EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] New Radio Equipment Directive (RED) - please read if you sell wireless devices into Europe Hi Articles 48 to 50 will also be implemented as part of the National Law, hence enforcing the dates below Best regards Nick From: Amund Westin [mailto:am...@westin-emission.no] Sent: 29 October 2014 07:52 To: Hooper, Nick; EMC-PSTC@LISTSERV.IEEE.ORGmailto:EMC-PSTC@LISTSERV.IEEE.ORG Subject: SV: [PSES] New Radio Equipment Directive (RED) - please read if you sell wireless devices into Europe RED applies from when the first EU/EEA member state has implemented the directive into national law? #Amund Fra: Hooper, Nick [mailto:nick.hoo...@ul.comnick.hoo...@ul.com] Sendt: 28. oktober 2014 12:04 Til: EMC-PSTC@LISTSERV.IEEE.ORG Emne: [PSES] New Radio Equipment Directive (RED) - please read if you sell wireless devices into Europe Hello everyone. I have been in discussion with the EU Commission and ADCO chairman as there seems to be an amount of misunderstanding on when you can declare compliance to the RED. I explained to Lucio that we have seen a few cases of DoC and NB opinions to the new RED, and therefore had a question on the validity of these documents. Below is the response received from the ADCO RTTE Chairman. “Dear Nick We have already had such problems and administrative non compliances ☺ The new Directive (RED) is currently not applicable (will be applicable to products first placed on market as of 13 June 2016). Hence the manufacturers cannot use, right now (i.e. for products placed on market before 13 June 2016), the references of RED (new Directive). Best regards Lucio Lucio Cocciantelli ADCO RTTE Chairman” Please ensure you read Artcile 48 to 50 of the RED, and pass this information on asap. Notified Bodies should not be issuing Opinions to the RED until they are listed, on the yet to be published, NANDO database for RED Notified Bodies. As the accreditation assessments will be taking place over the next year, it is unlikely the RED NANDO list will be published until late 2015 / early 2016 Nick Hooper BSc(Eng) CEng MIET Chairman RTTE CA UL Grove House Business Centre, Chineham Court, Lutyens, Basingstoke, Hampshire, RG24 8AG, England
Re: [PSES] New Radio Equipment Directive (RED) - please read if you sell wireless devices into Europe
Hi Charlie, Thanks for your assistance, but I still cant see anything preventing one claiming compliance to the RED. Its an EU directive which does appear to be currently in force across Europe, though not yet enforceable by law. So why cant you claim compliance to the RED (assuming you do)?To coin a phrase... theres no law against it. Or is there? See my ongoing questions below. Regards, Tony Sent:Wednesday, October 29, 2014 at 12:59 PM From:Charlie Blackham char...@sulisconsultants.com To:Anthony Thomson ton...@europe.com, EMC-PSTC@LISTSERV.IEEE.ORG EMC-PSTC@LISTSERV.IEEE.ORG Subject:RE: [PSES] New Radio Equipment Directive (RED) - please read if you sell wireless devices into Europe Tony Article 48 says that the existing legislation (RTTE or EMC+LVD) may be used for equipment within scope of RED until 13 June 2017, provided it was on the market before 16 June 2016. T:Yes, I can see that Article 48 permits optionally applying the RTTED (et. al.), to new products, for 1 year after the RED becomes enforceable under law on 13 June 2016. However, I cant see how this sets the earliest date that compliance against the RED can be claimed, and this is what Im trying to get to. Article 49 says that RED shall be applied from 13 June 2016 (in other words, it is wont be applicable until then). T: Does Article 49 say the RED applies from 13 June 2016?To me, it tellsMember Statesto have everything in place to comply with the directive by 12 June 2016 and start enforcement on 13 June 2016. It does not preventcompaniescomplying before that date, does it? Id have thought that companies are at liberty to comply with requirements before thay becomes legally mandatory and enforceable. T: Article 51 says the RED enters into force 20 days after publication in the OJ which equates to 11 June 2014. So the RED is currently in force. Sadly there is no definitions of in force or into force within the directive, so common definitions needs to apply. So fromArticle 51, isnt the RED already in force, though not yet enforceable under law?. T: So I can see that under Article 49 that there cannot be any laws in place to enforce the REDs application until 13 June 2016. Surely however you can claim conformance before then, you just cant be penalised for not doing so (considering the limitation of enforcement of Article 48). However . . . . Its only a Directives. Directives have to be implemented into National Law, in at least one member state, before they can be used thats the part that currently stops you. T: Isnt that what stops Member States enforcing a Directive? Surely companies can still optionally conform to it, after all the RED seems to have been in force since 11 June 2014 (albeit not enforceable until 13 June 2016 or 13 June 2017 if you chose to apply the RTTED). T: Where does this thing about at least one member state come from? Id like a black and white reference for this. It seems to be something lots of people say without any solid foundation. How can an EU directive be legally enforceable in one EU country and not another? Isnt it all or nothing (hence the 13 June 2016 date in the RED). RED is not a simple NLF alignment like 2014/30/EU and 2014/35/EU because there is also a change of scope and a number of items are moving into RED from EMC/LVD and out of RTTE into EMC/LVD. There are commission workshops on RED and EMCD planned for November, and issues around transition are on the agenda. Regards Charlie From: Anthony Thomson [mailto:ton...@europe.com] Sent: 29 October 2014 12:34 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] New Radio Equipment Directive (RED) - please read if you sell wireless devices into Europe All, Im completely confused by this situation and some clarity really would be appreciated. Where in the directive does it say you that cant currently claim compliance to the RED (well, as of 11 June 2015 - see below). Ive heard Amunds comments below from other sources too, but I cannot find any basis for this in the directive. Articles 48 through 50 mentioned by Nick merely state: 1. That the authorities cannot impede goods based on the RED until 13 June 2016 (Article 48). 2. That EU countries RED enforcement laws shall be in place before, and applied from 13 June 2016 (Article 49). 3. The RTTED is repealed on 13June 2016. None say you cant claim compliance to the RED. Now... Article 51 states that the RED shall enter into force on the 20th day following its publication in the OJ. Correct me if I am wrong, but I believe the RED was published in the the OJ on 22 May 2014 and has therefore been in force from the 11June 2015. So if its in force, providing you meet the provisions of the RED, which article(s) prevents claiming conformity? After all, it is (interpretation, which may well be wrong) in force? I admit that I havent scrutinised the whole document and all its references, so I presume that I
Re: [PSES] New Radio Equipment Directive (RED) - please read if you sell wireless devices into Europe
In message trinity-0b223d46-8d35-4e7c-b9ef-c0e83470a3fb-1414586057530@3capp-mailcom -lxa15, dated Wed, 29 Oct 2014, Anthony Thomson ton...@europe.com writes: I'm completely confused by this situation and some clarity really would be appreciated. Where in the directive does it say you that can't currently claim compliance to the RED (well, as of 11 June 2015 - see below). It is very confusing and that affects even government agencies. Many things in EU legislation are not explicit, so for those things a legal opinion is required. But legal opinions can be abstruse and even inconsistent. I am told that the British government works on the basis of Directives being instructions to member states to make laws, not laws in themselves (as EU Regulations are). So no *law* exists until a Directive has been implemented in national law by at least one member state. Until that happens, RED has no significance to industry, national regulatory bodies or the public. -- OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk Quid faciamus nisi sit? John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - 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
Re: [PSES] New Radio Equipment Directive (RED) - please read if you sell wireless devices into Europe
In message trinity-8c6816f3-df1d-4c5f-b2c0-41691b856a66-1414594781031@3capp-mailcom -lxa05, dated Wed, 29 Oct 2014, Anthony Thomson ton...@europe.com writes: So why can't you claim compliance to the RED (assuming you do)? To coin a phrase... there's no law against it. Or is there False advertising? The point is that since RED isn't a law and there is no law derived from it until one member state makes one, claiming compliance with it is of no meaning. You might as well claim compliance with Magna Carta. -- OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk Quid faciamus nisi sit? John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - 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
Re: [PSES] New Radio Equipment Directive (RED) - please read if you sell wireless devices into Europe
Tony Some definitive statement regarding implementation of Directives” is at http://ec.europa.eu/eu_law/directives/directives_en.htm What is a directive? EU directives lay down certain end results that must be achieved in every Member State. National authorities have to adapt their laws to meet these goals, but are free to decide how to do so. Directives may concern one or more EU countries, or all of them. Each directive specifies the date by which the national laws must be adapted - giving national authorities the room for manoeuvre within the deadlines necessary to take account of differing national situations. Directives are used to bring different national laws into line with each other, and are particularly common in matters that affect the operation of the single market (e.g. product safety standards). What are national implementing measures? These are texts officially adopted by the authorities in a Member State to incorporate the provisions in a directive into national law. All such texts sent to us by national authorities are scrutinised to ensure that they will actually implement in that Member State all the measures required in the directive Also, https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/229763/bis-13-775-transposition-guidance-how-to-implement-european-directives-effectively-revised.pdf Unlike Directives, EU “regulations” are law from moment they are published and do not need implementation. I don’t have a definitive reference for the “minimum one member state” comment, but it was in a new EMC Directive presentation given by UK government BIS department to IEEE meeting March. Regards Charlie From: Anthony Thomson [mailto:ton...@europe.com] Sent: 29 October 2014 15:00 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] New Radio Equipment Directive (RED) - please read if you sell wireless devices into Europe Hi Charlie, Thanks for your assistance, but I still can't see anything preventing one claiming compliance to the RED. It's an EU directive which does appear to be currently 'in force' across Europe, though not yet 'enforceable' by law. So why can't you claim compliance to the RED (assuming you do)? To coin a phrase... there's no law against it. Or is there? See my ongoing questions below. Regards, Tony Sent: Wednesday, October 29, 2014 at 12:59 PM From: Charlie Blackham char...@sulisconsultants.commailto:char...@sulisconsultants.com To: Anthony Thomson ton...@europe.commailto:ton...@europe.com, EMC-PSTC@LISTSERV.IEEE.ORGmailto:EMC-PSTC@LISTSERV.IEEE.ORG EMC-PSTC@LISTSERV.IEEE.ORGmailto:EMC-PSTC@LISTSERV.IEEE.ORG Subject: RE: [PSES] New Radio Equipment Directive (RED) - please read if you sell wireless devices into Europe Tony Article 48 says that the existing legislation (RTTE or EMC+LVD) may be used for equipment within scope of RED until 13 June 2017, provided it was on the market before 16 June 2016. T: Yes, I can see that Article 48 permits optionally applying the RTTED (et. al.), to new products, for 1 year after the RED becomes enforceable under law on 13 June 2016. However, I can't see how this sets the earliest date that compliance against the RED can be claimed, and this is what I'm trying to get to. Article 49 says that RED shall be applied from 13 June 2016 (in other words, it is won’t be applicable until then). T: Does Article 49 say the RED applies from 13 June 2016? To me, it tells Member States to have everything in place to comply with the directive by 12 June 2016 and start enforcement on 13 June 2016. It does not prevent companies complying before that date, does it? I'd have thought that companies are at liberty to comply with requirements before thay becomes legally mandatory and enforceable. T: Article 51 says the RED enters into force 20 days after publication in the OJ which equates to 11 June 2014. So the RED is currently in force. Sadly there is no definitions of in force or into force within the directive, so common definitions needs to apply. So from Article 51, isn't the RED already 'in force', though not yet enforceable under law?. T: So I can see that under Article 49 that there cannot be any laws in place to enforce the RED's application until 13 June 2016. Surely however you can claim conformance before then, you just cant be penalised for not doing so (considering the limitation of enforcement of Article 48). However . . . . It’s “only” a Directives. Directives have to be implemented into National Law, in at least one member state, before they can be used – that’s the part that currently stops you. T: Isn't that what stops Member States enforcing a Directive? Surely companies can still optionally conform to it, after all the RED seems to have been in force since 11 June 2014 (albeit not enforceable until 13 June 2016 or 13 June 2017 if you chose to apply the RTTED). T: Where does this thing about at least one member state come from? I'd like a black and white
Re: [PSES] New Radio Equipment Directive (RED) - please read if you sell wireless devices into Europe
The cause of this confusion is that we are used to declare conformity with a directive, where IMHO one should declare conformity with the implementation thereof in law in a member state. Gert Gremmen ce-test Van: Charlie Blackham [mailto:char...@sulisconsultants.com] Verzonden: woensdag 29 oktober 2014 21:01 Aan: EMC-PSTC@LISTSERV.IEEE.ORG Onderwerp: Re: [PSES] New Radio Equipment Directive (RED) - please read if you sell wireless devices into Europe Tony Some definitive statement regarding implementation of Directives” is at http://ec.europa.eu/eu_law/directives/directives_en.htm What is a directive? EU directives lay down certain end results that must be achieved in every Member State. National authorities have to adapt their laws to meet these goals, but are free to decide how to do so. Directives may concern one or more EU countries, or all of them. Each directive specifies the date by which the national laws must be adapted - giving national authorities the room for manoeuvre within the deadlines necessary to take account of differing national situations. Directives are used to bring different national laws into line with each other, and are particularly common in matters that affect the operation of the single market (e.g. product safety standards). What are national implementing measures? These are texts officially adopted by the authorities in a Member State to incorporate the provisions in a directive into national law. All such texts sent to us by national authorities are scrutinised to ensure that they will actually implement in that Member State all the measures required in the directive Also, https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/229763/bis-13-775-transposition-guidance-how-to-implement-european-directives-effectively-revised.pdf Unlike Directives, EU “regulations” are law from moment they are published and do not need implementation. I don’t have a definitive reference for the “minimum one member state” comment, but it was in a new EMC Directive presentation given by UK government BIS department to IEEE meeting March. Regards Charlie From: Anthony Thomson [mailto:ton...@europe.com] Sent: 29 October 2014 15:00 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] New Radio Equipment Directive (RED) - please read if you sell wireless devices into Europe Hi Charlie, Thanks for your assistance, but I still can't see anything preventing one claiming compliance to the RED. It's an EU directive which does appear to be currently 'in force' across Europe, though not yet 'enforceable' by law. So why can't you claim compliance to the RED (assuming you do)? To coin a phrase... there's no law against it. Or is there? See my ongoing questions below. Regards, Tony Sent: Wednesday, October 29, 2014 at 12:59 PM From: Charlie Blackham char...@sulisconsultants.com To: Anthony Thomson ton...@europe.com, EMC-PSTC@LISTSERV.IEEE.ORG EMC-PSTC@LISTSERV.IEEE.ORG Subject: RE: [PSES] New Radio Equipment Directive (RED) - please read if you sell wireless devices into Europe Tony Article 48 says that the existing legislation (RTTE or EMC+LVD) may be used for equipment within scope of RED until 13 June 2017, provided it was on the market before 16 June 2016. T: Yes, I can see that Article 48 permits optionally applying the RTTED (et. al.), to new products, for 1 year after the RED becomes enforceable under law on 13 June 2016. However, I can't see how this sets the earliest date that compliance against the RED can be claimed, and this is what I'm trying to get to. Article 49 says that RED shall be applied from 13 June 2016 (in other words, it is won’t be applicable until then). T: Does Article 49 say the RED applies from 13 June 2016? To me, it tells Member States to have everything in place to comply with the directive by 12 June 2016 and start enforcement on 13 June 2016. It does not prevent companies complying before that date, does it? I'd have thought that companies are at liberty to comply with requirements before thay becomes legally mandatory and enforceable. T: Article 51 says the RED enters into force 20 days after publication in the OJ which equates to 11 June 2014. So the RED is currently in force. Sadly there is no definitions of in force or into force within the directive, so common definitions needs to apply. So from Article 51, isn't the RED already 'in force', though not yet enforceable under law?. T: So I can see that under Article 49 that there cannot be any laws in place to enforce the RED's application until 13 June 2016. Surely however you can claim conformance before then, you just cant be penalised for not doing so (considering the limitation of enforcement of Article 48). However . . . . It’s “only” a Directives. Directives have to be implemented into National Law, in at least one member state, before they can be used – that’s
Re: [PSES] New Radio Equipment Directive (RED) - please read if you sell wireless devices into Europe
In message dbd259dff17c47778ee24dfe2bef5...@thhste15d1be4.hs20.net, dated Wed, 29 Oct 2014, Charlie Blackham char...@sulisconsultants.com writes: I don’t have a definitive reference for the “minimum one member state” comment, but it was in a new EMC Directive presentation given by UK government BIS department to IEEE meeting March. I asked for the provenance for that, and was told unofficially that it's a legal opinion. -- OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk Quid faciamus nisi sit? John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - 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
Re: [PSES] New Radio Equipment Directive (RED) - please read if you sell wireless devices into Europe
In message FCA549BE3ECF9D4CB8CB8576837EA48920AAB7@ZEUS.cetest.local, dated Wed, 29 Oct 2014, ce-test, qualified testing bv - Gert Gremmen g.grem...@cetest.nl writes: The cause of this confusion is that we are used to declare conformity with a directive, where IMHO one should declare conformity with the implementation thereof in law in a member state. It is forbidden to apply logic to EU administration. -- OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk Quid faciamus nisi sit? John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - 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
[PSES] New Radio Equipment Directive (RED) - please read if you sell wireless devices into Europe
Hello everyone. I have been in discussion with the EU Commission and ADCO chairman as there seems to be an amount of misunderstanding on when you can declare compliance to the RED. I explained to Lucio that we have seen a few cases of DoC and NB opinions to the new RED, and therefore had a question on the validity of these documents. Below is the response received from the ADCO RTTE Chairman. Dear Nick We have already had such problems and administrative non compliances :) The new Directive (RED) is currently not applicable (will be applicable to products first placed on market as of 13 June 2016). Hence the manufacturers cannot use, right now (i.e. for products placed on market before 13 June 2016), the references of RED (new Directive). Best regards Lucio Lucio Cocciantelli ADCO RTTE Chairman Please ensure you read Artcile 48 to 50 of the RED, and pass this information on asap. Notified Bodies should not be issuing Opinions to the RED until they are listed, on the yet to be published, NANDO database for RED Notified Bodies. As the accreditation assessments will be taking place over the next year, it is unlikely the RED NANDO list will be published until late 2015 / early 2016 Nick Hooper BSc(Eng) CEng MIET Chairman RTTE CA UL Grove House Business Centre, Chineham Court, Lutyens, Basingstoke, Hampshire, RG24 8AG, England This e-mail may contain privileged or confidential information. If you are not the intended recipient: (1) you may not disclose, use, distribute, copy or rely upon this message or attachment(s); and (2) please notify the sender by reply e-mail, and then delete this message and its attachment(s). Underwriters Laboratories Inc. and its affiliates disclaim all liability for any errors, omissions, corruption or virus in this message or any attachments. - 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
