Re: [PSES] EN 300 328 - Bluetooth testing

[Charlie Blackham]

Amund



If your Bluetooth device is < 10 dBm EIRP, it is exempt from some the 
requirements listed in the standard - some specifically given in various 
clauses, and I would expect the geo-location wouldn't be needed as I think a 
<10 dBm EIRP implementation can be certified for use everywhere.



The latest version 
v2.1.1<http://www.etsi.org/deliver/etsi_en/300300_300399/300328/02.01.01_60/en_300328v020101p.pdf>
 should be listed in the RED OJ later this month.



Regards

Charlie



-Original Message-
From: Amund Westin [mailto:am...@westin-emission.no]
Sent: 09 January 2017 08:24
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] EN 300 328 - Bluetooth testing



To you guys who have deep experience with Bluetooth test and approvals 
according to EN 300 328, are there any of the required tests that is really 
hard to fulfil and often fails during tests, and therefore should have special 
attention during the development phase?



... or requirements that often lead to discussions because it can have several 
interpretations 





Thanks for all feedbacks!





EN 300 328 requirements:

-RF output power

-Power Spectral Density

-Duty Cycle, Tx-sequence, Tx-gap

-Accumulated Transmit time,Frequency Occupation & Hopping Sequence

-Hopping Frequency Separation

-Medium Utilization (MU) factor

-Adaptivity

-Occupied Channel Bandwidth

-Transmitter unwanted emissions in the out-of-band domain

-Transmitter unwanted emissions in the spurious domain

-Receiver spurious emissions

-Receiver Blocking

-Geo-location capability







Best regards

Amund



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Re: [PSES] EN 300 328 - Bluetooth testing

[Brent DeWitt]

The two things I've found to be problematic are band edge and spurious emissions.  So many of the other characteristics are cast in silicon that they've alreeady been worked out.Brent-Original Message-
From: Jim Bacher 
Sent: Jan 9, 2017 9:04 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EN 300 328 - Bluetooth testing

I have only tested modules produced by others,  however I have never had a failure. The biggest issue has been getting the software to properly control the device so it could be tested easily. On Jan 9, 2017 3:41 AM, "Amund Westin" <am...@westin-emission.no> wrote:To you guys who have deep experience with Bluetooth test and approvals according to EN 300 328, are there any of the required tests that is really hard to fulfil and often fails during tests, and therefore should have special attention during the development phase?

... or requirements that often lead to discussions because it can have several interpretations 


Thanks for all feedbacks!


EN 300 328 requirements:
-RF output power
-Power Spectral Density
-Duty Cycle, Tx-sequence, Tx-gap
-Accumulated Transmit time,Frequency Occupation & Hopping Sequence
-Hopping Frequency Separation
-Medium Utilization (MU) factor
-Adaptivity
-Occupied Channel Bandwidth
-Transmitter unwanted emissions in the out-of-band domain
-Transmitter unwanted emissions in the spurious domain
-Receiver spurious emissions
-Receiver Blocking
-Geo-location capability



Best regards
Amund

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Re: [PSES] EN 300 328 - Bluetooth testing

[Jim Bacher]

I should have mentioned that I always asked the OEM for copies of at least
the FCC / IC and CE test reports.  Along with copies of certificates for
any other countries we were going to sell into to make sure it had been
through certification.  Once I had the reports I would review them to look
for issues.

I only remember one product that had issues.  They claimed it had the
Canadian certifications, when it didn't.  After a few days of arguing,
 they realized they failed to certify it and corrected the issue.

Jim

On Jan 9, 2017 9:04 AM, "Jim Bacher"  wrote:

> I have only tested modules produced by others,  however I have never had a
> failure. The biggest issue has been getting the software to properly
> control the device so it could be tested easily.
>
> On Jan 9, 2017 3:41 AM, "Amund Westin"  wrote:
>
>> To you guys who have deep experience with Bluetooth test and approvals
>> according to EN 300 328, are there any of the required tests that is really
>> hard to fulfil and often fails during tests, and therefore should have
>> special attention during the development phase?
>>
>> ... or requirements that often lead to discussions because it can have
>> several interpretations 
>>
>>
>> Thanks for all feedbacks!
>>
>>
>> EN 300 328 requirements:
>> -RF output power
>> -Power Spectral Density
>> -Duty Cycle, Tx-sequence, Tx-gap
>> -Accumulated Transmit time,Frequency Occupation & Hopping Sequence
>> -Hopping Frequency Separation
>> -Medium Utilization (MU) factor
>> -Adaptivity
>> -Occupied Channel Bandwidth
>> -Transmitter unwanted emissions in the out-of-band domain
>> -Transmitter unwanted emissions in the spurious domain
>> -Receiver spurious emissions
>> -Receiver Blocking
>> -Geo-location capability
>>
>>
>>
>> Best regards
>> Amund
>>
>> -
>> 
>> 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)
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>>
>> For help, send mail to the list administrators:
>> Scott Douglas 
>> Mike Cantwell 
>>
>> For policy questions, send mail to:
>> Jim Bacher:  
>> David Heald: 
>>
>

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Re: [PSES] EN 300 328 - Bluetooth testing

[Jim Bacher]

I have only tested modules produced by others,  however I have never had a
failure. The biggest issue has been getting the software to properly
control the device so it could be tested easily.

On Jan 9, 2017 3:41 AM, "Amund Westin"  wrote:

> To you guys who have deep experience with Bluetooth test and approvals
> according to EN 300 328, are there any of the required tests that is really
> hard to fulfil and often fails during tests, and therefore should have
> special attention during the development phase?
>
> ... or requirements that often lead to discussions because it can have
> several interpretations 
>
>
> Thanks for all feedbacks!
>
>
> EN 300 328 requirements:
> -RF output power
> -Power Spectral Density
> -Duty Cycle, Tx-sequence, Tx-gap
> -Accumulated Transmit time,Frequency Occupation & Hopping Sequence
> -Hopping Frequency Separation
> -Medium Utilization (MU) factor
> -Adaptivity
> -Occupied Channel Bandwidth
> -Transmitter unwanted emissions in the out-of-band domain
> -Transmitter unwanted emissions in the spurious domain
> -Receiver spurious emissions
> -Receiver Blocking
> -Geo-location capability
>
>
>
> Best regards
> Amund
>
> -
> 
> 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 
> Mike Cantwell 
>
> For policy questions, send mail to:
> Jim Bacher:  
> David Heald: 
>

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[PSES] EN 300 328 - Bluetooth testing

[Amund Westin]

To you guys who have deep experience with Bluetooth test and approvals 
according to EN 300 328, are there any of the required tests that is 
really hard to fulfil and often fails during tests, and therefore should 
have special attention during the development phase?


... or requirements that often lead to discussions because it can have 
several interpretations 



Thanks for all feedbacks!


EN 300 328 requirements:
-RF output power
-Power Spectral Density
-Duty Cycle, Tx-sequence, Tx-gap
-Accumulated Transmit time,Frequency Occupation & Hopping Sequence
-Hopping Frequency Separation
-Medium Utilization (MU) factor
-Adaptivity
-Occupied Channel Bandwidth
-Transmitter unwanted emissions in the out-of-band domain
-Transmitter unwanted emissions in the spurious domain
-Receiver spurious emissions
-Receiver Blocking
-Geo-location capability



Best regards
Amund

-

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Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements

[John Woodgate]

In message , dated Thu, 29 
Nov 2012, Mark Gandler  writes:


All text coming after it is the condition, and that INCLUDES the 
testing. See last sentence: “The efficiency of the various sharing 
mechanisms can be assessed using the appropriate clauses of EN 300 328 
version 1.8.1.” 



Mark Gandler: I still believe the word CAN is a key in 
this discussion, am trying to get final feedback from OJ on the word 
"can"


Not only that, can a NOTE in an ETSI standard include a requirement? It 
cannot in IEC and CENELEC standards.

--
OOO - Own Opinions Only. See www.jmwa.demon.co.uk
The longer it takes to make a point, the more obtuse it proves to be.
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements

[Dward]

Now if you were meditating on it, then it would be the u holtz coils

 

Dennis Ward

Senior Certification Engineer

PCTEST

This communication and its attachments contain information from PCTEST
Engineering Laboratory, Inc., and is intended 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.  

 

From: Michael Derby [mailto:micha...@acbcert.com] 
Sent: Thursday, November 29, 2012 1:55 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements

 

I blame too much time between the helmholz coils!!!

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: Nick Williams [mailto:nick.willi...@conformance.co.uk] 
Sent: 29 November 2012 21:32
To: Michael Derby
Cc: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements

 

You would not be alone if you did, Michael...

 

 

 

On 29 Nov 2012, at 20:01, Michael Derby  wrote:

 

 

 

Honestly, I don't actually hear these voices in my head.

 

 

 

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Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements

[Michael Derby]

If he had a kind of high pitched, squeaky voice, yes.

I do recall I did get a headache every time I put the surge generator
through the coils but perhaps that's to be expected.


Michael Derby
Regulatory Engineer
ACB Europe


-Original Message-
From: don_borow...@selinc.com [mailto:don_borow...@selinc.com] 
Sent: 29 November 2012 22:05
To: Michael Derby
Cc: emc-p...@ieee.org; 'Nick Williams'
Subject: RE: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements

So do you hear the voice of Helmholtz?

Donald Borowski
EMC Compliance Engineer
Schweitzer Engineering Labs
Pullman, Washington, USA



From:   Michael Derby 
To: "'Nick Williams'" 
Cc: 
Date:   11/29/2012 01:56 PM
Subject:RE: [PSES] EN 300 328 V1.8.1 new Adaptive equipment 
requirements
Sent by:emc-p...@ieee.org



I blame too much time between the helmholz coils!!!
 
 
Michael Derby
Regulatory Engineer
ACB Europe
 
From: Nick Williams [mailto:nick.willi...@conformance.co.uk]
Sent: 29 November 2012 21:32
To: Michael Derby
Cc: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements
 
You would not be alone if you did, Michael...
 
 
 
On 29 Nov 2012, at 20:01, Michael Derby  wrote:


 
 
Honestly, I don?t actually hear these voices in my head.
 
 
 
-

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Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements

[Don_Borowski]

So do you hear the voice of Helmholtz?

Donald Borowski
EMC Compliance Engineer
Schweitzer Engineering Labs
Pullman, Washington, USA



From:   Michael Derby 
To: "'Nick Williams'" 
Cc: 
Date:   11/29/2012 01:56 PM
Subject:        RE: [PSES] EN 300 328 V1.8.1 new Adaptive equipment 
requirements
Sent by:emc-p...@ieee.org



I blame too much time between the helmholz coils!!!
 
 
Michael Derby
Regulatory Engineer
ACB Europe
 
From: Nick Williams [mailto:nick.willi...@conformance.co.uk] 
Sent: 29 November 2012 21:32
To: Michael Derby
Cc: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements
 
You would not be alone if you did, Michael...
 
 
 
On 29 Nov 2012, at 20:01, Michael Derby  wrote:


 
 
Honestly, I don?t actually hear these voices in my head.
 
 
 
-

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Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements

[Nick Williams]

You would not be alone if you did, Michael...



On 29 Nov 2012, at 20:01, Michael Derby  wrote:

> 
>  
> Honestly, I don’t actually hear these voices in my head.
>  
>  


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Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements

[Michael Derby]

I blame too much time between the helmholz coils!!!

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: Nick Williams [mailto:nick.willi...@conformance.co.uk] 
Sent: 29 November 2012 21:32
To: Michael Derby
Cc: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements

 

You would not be alone if you did, Michael...

 

 

 

On 29 Nov 2012, at 20:01, Michael Derby  wrote:





 

 

Honestly, I don't actually hear these voices in my head.

 

 

 


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Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements

[Michael Derby]

I agree with Charlie that it is not saying you must test to V1.8.1.   It is
saying that you must have spectrum sharing mechanisms (we know that, it's in
V1.7.1) but we don't necessarily know what that means.   It gives examples,
followed by an idea of where to find tests if you want them.

 

 

Imagine the text from the OJ:

This version of the standard gives presumption of conformity with the
requirements of Article 3(2) of Directive 1999/5/EC under the following

condition: The equipment shall implement an adequate spectrum sharing
mechanism, e.g. LBT (Listen Before Talk), DAA (Detect And Avoid), etc., in

order to comply with the requirement specified in clause 4.3.5 of this
version. Such a mechanism shall facilitate sharing between the various

technologies and applications which currently exist and in case of
congestion, users will be ensured equal access (and as a consequence a
graceful

degradation of service to all users). The efficiency of the various sharing
mechanisms can be assessed using the appropriate clauses of EN 300328

version 1.8.1.

 

Now imagine a conversation between an industry person (let's call him "IP")
and the OJ itself.   For the OJ, I shall use only the text above..

 

OJ:   This version of the standard gives presumption of conformity with the
requirements of Article 3(2) of Directive 1999/5/EC under the following

condition: The equipment shall implement an adequate spectrum sharing
mechanism,

 

IP:   What is a "spectrum sharing mechanism"?

 

OJ:e.g. LBT (Listen Before Talk), DAA (Detect And Avoid), etc., in order
to comply with the requirement specified in clause 4.3.5 of this version. 

 

IP:   Oh, I see that, but what is it for?   If you explain it, maybe I can
use some other way to meet that requirement.

 

OJ:   Such a mechanism shall facilitate sharing between the various
technologies and applications which currently exist and in case of
congestion, users will be ensured equal access (and as a consequence a
graceful degradation of service to all users). 

 

IP:   I see.   That would be really easy if I had a WLAN or Bluetooth device
but I don't, I have this cool new technology I invented.   Are there any
tests I can follow?

 

OJ:   The efficiency of the various sharing mechanisms can be assessed using
the appropriate clauses of EN 300328 version 1.8.1.

 

IP:   Thank you, you've been very helpful.

 

 

 

Honestly, I don't actually hear these voices in my head.

 

 

Michael.

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: Charlie Blackham [mailto:char...@sulisconsultants.com] 
Sent: 29 November 2012 08:31
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements

 

Mark

 

Harmonised Standards don't always contain all the requirements - Spectrum
Requirements also apply and these are regulated by the various national
radio interface regulations and not in the standards.

The base for the use of the 2400-2483.5 MHz frequency band may be found in
Annex 3 of ERC/REC 70-03.

http://www.erodocdb.dk/Docs/doc98/official/pdf/REC7003e.pdf . This is the
latest, October 2012 version, but the previous February 2011 version
contained the following note: "The equipment shall implement an adequate
spectrum sharing mechanism in order to facilitate sharing between the
various technologies and applications covered by this annex 3." 

 

In other words  an "adequate spectrum sharing requirement" has been needed
for some time.

 

The wording in the OJ has changed (evolved) from, if you like, "pointing to
where ways for assessing this requirement could be found", to "telling you
where they can be found". It does not say that the Spectrum Sharing
requirements of V1.8.1 must be followed, it says can be found.

 

In my opinion, the note in the OJ referring to V1.8.1 is not mandatory.
Demonstration with requirement could be made through consideration of
sharing requirements already built in though conformity with relevant 802.11
requirements of WiFI or BT standards. But whatever you choose, you should be
prepared to justify it to a Spectrum Authority if required.

 

The manufacturer must fully apply the relevant Harmonised Standard if they
want to apply the CE mark without the use of a Notified Body and the
Spectrum Requirements must also be followed before the device is put into
service.

 

The requirement hasn't actually changed when applying V1.7.1 it's just that
the guidance has been improved as it has been found to be not as clear as it
might have been. Though whether it's completely clear now . . . . J

 

Regards

Charlie

 

 

 

From: Mark Gandler [mailto:markgand...@hotmail.com] 
Sent: 28 November 2012 19:51
To: Charlie Blackham; j...@jmwa.demon.co.uk; emc-pstc@listserv.ieee.org
Subject: RE: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements

 

Charlie,

current mandatory 

Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements

[Charlie Blackham]

Mark

Harmonised Standards don't always contain all the requirements - Spectrum 
Requirements also apply and these are regulated by the various national radio 
interface regulations and not in the standards.
The base for the use of the 2400-2483.5 MHz frequency band may be found in 
Annex 3 of ERC/REC 70-03.
http://www.erodocdb.dk/Docs/doc98/official/pdf/REC7003e.pdf . This is the 
latest, October 2012 version, but the previous February 2011 version contained 
the following note: "The equipment shall implement an adequate spectrum sharing 
mechanism in order to facilitate sharing between the various technologies and 
applications covered by this annex 3."

In other words  an "adequate spectrum sharing requirement" has been needed for 
some time.

The wording in the OJ has changed (evolved) from, if you like, "pointing to 
where ways for assessing this requirement could be found", to "telling you 
where they can be found". It does not say that the Spectrum Sharing 
requirements of V1.8.1 must be followed, it says can be found.

In my opinion, the note in the OJ referring to V1.8.1 is not mandatory. 
Demonstration with requirement could be made through consideration of sharing 
requirements already built in though conformity with relevant 802.11 
requirements of WiFI or BT standards. But whatever you choose, you should be 
prepared to justify it to a Spectrum Authority if required.

The manufacturer must fully apply the relevant Harmonised Standard if they want 
to apply the CE mark without the use of a Notified Body and the Spectrum 
Requirements must also be followed before the device is put into service.

The requirement hasn't actually changed when applying V1.7.1 it's just that the 
guidance has been improved as it has been found to be not as clear as it might 
have been. Though whether it's completely clear now . . . . :)

Regards
Charlie



From: Mark Gandler [mailto:markgand...@hotmail.com]
Sent: 28 November 2012 19:51
To: Charlie Blackham; j...@jmwa.demon.co.uk; emc-pstc@listserv.ieee.org
Subject: RE: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements

Charlie,
current mandatory version is 1.7.1. Future (2015) is 1.8.1. Both harmonized.

There is an application note in question which describes additional 
requirements. Only as of last month this Note became mandatory. Note in OJ from 
2009 was simply stating what actual tests been developed in draft 1.8.1.

Should the "note" be treated as any other new version of the standard, allowing 
grace period?

Better question: how does one challenge or ask for "official" clarification on 
the matter?

Mark

From: char...@sulisconsultants.com<mailto:char...@sulisconsultants.com>
To: j...@jmwa.demon.co.uk<mailto:j...@jmwa.demon.co.uk>; 
EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: RE: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements
Date: Wed, 28 Nov 2012 08:48:55 +
I'll write that correctly this time :)

UNLIKE many other Directives, the R&TTE Directive REQUIRES the use of a 
Notified Body where Radio Spectrum Standards are NOT applied in full.

Harmonised Standards are, in effect, mandatory unless you use a NB - and even 
then, you can't choose not to apply them because you don't like them

From: Charlie Blackham
Sent: 28 November 2012 08:47
To: 'John Woodgate'; 
EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: RE: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements

UNLIKE many other Directives, the R&TTE Directive REQUIRES the use of a 
Notified Body where Radio Spectrum Standards are applied in full.

Regards
Charlie

-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk]
Sent: 28 November 2012 08:23
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements

In message 
mailto:snt108-w4738469ded84b4fb7df60ad...@phx.gbl>>,
 dated Tue, 27 Nov 2012, Mark Gandler 
mailto:markgand...@hotmail.com>> writes:

> I'm not sure how anyone can justify this makes any sense and seems
>like going against the spirit of RTTE and any other EU Directives,
>allowing grace period for any requirement to take place. Simple
>mentioning of something been developed does not substitute a legal
>recruitment.

Agreed; this seems like an erosion of the protection of manufacturers against 
instant changes. Like other Directives, the RTTE Directive contains no 
mandatory requirement to apply harmonized standards and carry out tests (except 
in the case of Full Quality Control).
--
OOO - Own Opinions Only. See www.jmwa.demon.co.uk<http://www.jmwa.demon.co.uk> 
The longer it takes to make a point, the more obtuse it proves to be.
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

-

Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements

[Mark Gandler]

Charlie,current mandatory version is 1.7.1. Future (2015) is 1.8.1. Both 
harmonized. 
There is an application note in question which describes additional 
requirements. Only as of last month this Note became mandatory. Note in OJ from 
2009 was simply stating what actual tests been developed in draft 1.8.1. 
Should the "note" be treated as any other new version of the standard, allowing 
grace period? 
Better question: how does one challenge or ask for "official" clarification on 
the matter? 
Mark

From: char...@sulisconsultants.com
To: j...@jmwa.demon.co.uk; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements
Date: Wed, 28 Nov 2012 08:48:55 +









I’ll write that correctly this time
J
 
UNLIKE many other Directives, the R&TTE Directive REQUIRES the use of a 
Notified Body where Radio Spectrum Standards are NOT applied in full.
 
Harmonised Standards are, in effect, mandatory unless you use a NB – and even 
then, you can’t choose not to apply them because you don’t like them
 


From: Charlie
 Blackham 

Sent: 28 November 2012 08:47

To: 'John Woodgate'; EMC-PSTC@LISTSERV.IEEE.ORG

Subject: RE: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements


 
UNLIKE many other Directives, the R&TTE Directive REQUIRES the use of a 
Notified Body where Radio Spectrum Standards are applied in full.
 
Regards
Charlie
 
-Original Message-

From: John Woodgate [mailto:j...@jmwa.demon.co.uk]


Sent: 28 November 2012 08:23

To: EMC-PSTC@LISTSERV.IEEE.ORG

Subject: Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements
 
In message , dated Tue, 27 Nov 
2012, Mark Gandler 
 writes:
 
> I'm not sure how anyone can justify this makes any sense and seems

>like going against the spirit of RTTE and any other EU Directives,

>allowing grace period for any requirement to take place. Simple

>mentioning of something been developed does not substitute a legal 
>recruitment.
 
Agreed; this seems like an erosion of the protection of manufacturers against 
instant changes. Like other Directives, the RTTE Directive contains no 
mandatory requirement to apply harmonized standards and carry out tests (except 
in the
 case of Full Quality Control).
--
OOO - Own Opinions Only. See 
www.jmwa.demon.co.uk The longer it takes to make a point, the more obtuse it 
proves to be.
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK
 
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Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements

[Charlie Blackham]

I'll write that correctly this time :)

UNLIKE many other Directives, the R&TTE Directive REQUIRES the use of a 
Notified Body where Radio Spectrum Standards are NOT applied in full.

Harmonised Standards are, in effect, mandatory unless you use a NB - and even 
then, you can't choose not to apply them because you don't like them

From: Charlie Blackham
Sent: 28 November 2012 08:47
To: 'John Woodgate'; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements


UNLIKE many other Directives, the R&TTE Directive REQUIRES the use of a 
Notified Body where Radio Spectrum Standards are applied in full.



Regards

Charlie



-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk]
Sent: 28 November 2012 08:23
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements



In message 
mailto:snt108-w4738469ded84b4fb7df60ad...@phx.gbl>>,
 dated Tue, 27 Nov 2012, Mark Gandler 
mailto:markgand...@hotmail.com>> writes:



> I'm not sure how anyone can justify this makes any sense and seems

>like going against the spirit of RTTE and any other EU Directives,

>allowing grace period for any requirement to take place. Simple

>mentioning of something been developed does not substitute a legal

>recruitment.



Agreed; this seems like an erosion of the protection of manufacturers against 
instant changes. Like other Directives, the RTTE Directive contains no 
mandatory requirement to apply harmonized standards and carry out tests (except 
in the case of Full Quality Control).

--

OOO - Own Opinions Only. See www.jmwa.demon.co.uk<http://www.jmwa.demon.co.uk> 
The longer it takes to make a point, the more obtuse it proves to be.

John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK



-



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Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements

[Charlie Blackham]

UNLIKE many other Directives, the R&TTE Directive REQUIRES the use of a 
Notified Body where Radio Spectrum Standards are applied in full.



Regards

Charlie



-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk]
Sent: 28 November 2012 08:23
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements



In message 
mailto:snt108-w4738469ded84b4fb7df60ad...@phx.gbl>>,
 dated Tue, 27 Nov 2012, Mark Gandler 
mailto:markgand...@hotmail.com>> writes:



> I'm not sure how anyone can justify this makes any sense and seems

>like going against the spirit of RTTE and any other EU Directives,

>allowing grace period for any requirement to take place. Simple

>mentioning of something been developed does not substitute a legal

>recruitment.



Agreed; this seems like an erosion of the protection of manufacturers against 
instant changes. Like other Directives, the RTTE Directive contains no 
mandatory requirement to apply harmonized standards and carry out tests (except 
in the case of Full Quality Control).

--

OOO - Own Opinions Only. See www.jmwa.demon.co.uk<http://www.jmwa.demon.co.uk> 
The longer it takes to make a point, the more obtuse it proves to be.

John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK



-



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Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements

[John Woodgate]

In message , dated Tue, 27 
Nov 2012, Mark Gandler  writes:


I'm not sure how anyone can justify this makes any sense and seems 
like going against the spirit of RTTE and any other EU Directives, 
allowing grace period for any requirement to take place. Simple 
mentioning of something been developed does not substitute a 
legal recruitment.


Agreed; this seems like an erosion of the protection of manufacturers 
against instant changes. Like other Directives, the RTTE Directive 
contains no mandatory requirement to apply harmonized standards and 
carry out tests (except in the case of Full Quality Control).

--
OOO - Own Opinions Only. See www.jmwa.demon.co.uk
The longer it takes to make a point, the more obtuse it proves to be.
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.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/
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Scott Douglas 
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For policy questions, send mail to:
Jim Bacher:  
David Heald: 

Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements

[Mark Gandler]

Charlie,this comment is not the same note as published now under RTTE 
harmonized section and it did not require testing under 1.8.1 as current Note 
does. it merely mentioned harmonized ways are been developed in draft 1.8.1. 
1.8.1 goes in effect in 2 years, requirement for testing according to 1.8.1 
goes in effect immediately. I'm not sure how anyone can justify this makes any 
sense and seems like going against the spirit of RTTE and any other EU 
Directives, allowing grace period for any requirement to take place. Simple 
mentioning of something been developed does not substitute a legal 
recruitment.Mark

From: char...@sulisconsultants.com
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements
Date: Tue, 27 Nov 2012 11:36:26 +









There has been a comment in the OJ regarding requirement for spectrum sharing 
since December 2009:
 
This version of the standard gives presumption of conformity with the 
requirements of Article 3(2) of Directive 1999/5/EC under the following 
condition: The equipment shall implement an adequate
 spectrum sharing mechanism, e.g. LBT (Listen Before Talk), DAA (Detect And 
Avoid), etc., in order to comply with the requirement specified in clause 4.3.5 
of this version. Such a mechanism shall facilitate sharing between the various 
technologies and applications
 which currently exist and in case of congestion, users will be ensured equal 
access (and as a consequence a graceful degradation of service to all users). 
Harmonised ways for assessing the efficiency of various sharing mechanisms are 
currently been developed
 by ETSI in draft EN 300328 version 1.8.1.
 
V1.8.1 has brought in some additional requirements, but the draft standard has 
been around for years and the published standard added to the OJ with a 26 
month transition period.
 
Regards
Charlie
 
 
-Original Message-

From: John Woodgate [mailto:j...@jmwa.demon.co.uk] 

Sent: 27 November 2012 08:42

To: EMC-PSTC@LISTSERV.IEEE.ORG

Subject: Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements
 
In message , dated Mon, 26 Nov 
2012, Mark Gandler 
 writes:
 
>Bill,being struggling with the same question. 1.8.1 goes in effect only

>on 1.1.2015, but current 1.7.1 should be used with an adaptivity

>requirement from 1.8.1.It is very unusual circumstances where the

>requirement is pretty much "dropped" out of nowhere and looks like goes

>in effect immediately.Our test lab posted this question to an alleged

>author of the below note and his answer was "yes, it applies and must

>be tested". not sure how it all makes sense to etsi authors and RTTE

>committee. what about currently shipping equipment which been evaluated

>to 1.7.1 version, but before adaptivity note been posted?
 
It is indeed very unusual for a provision to come into effect without a 
transition period, and is normally not allowed. If it is allowed, there must be 
a safety or other over-riding issue to justify it and it must be explained 
publicly
 (at least according to many Directives).
 
Were manufacturer experts on the relevant ETSI standards committee unaware of 
this unusual development?
--
OOO - Own Opinions Only. See 
www.jmwa.demon.co.uk The longer it takes to make a point, the more obtuse it 
proves to be.
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK
 
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Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements

[Mark Gandler]

Bill,if it would be only logical assessment, then yes, you are correct. But the 
writers of the aforementioned Note had a different idea and according to their 
interpretation in order to prove compliance with 1.8.1 you MUST test. Previous 
1.7.1 did not address this and Medium Access Protocol was not the same 
requirement as Adaptivity with defined interference signals and test 
procedures. below is all what 1.7.1 had on MAP, no test requirements:
4.3.5 Medium access protocol4.3.5.1 DefinitionA medium access protocol is a 
mechanism designed to facilitate spectrum sharing with other devices in a 
wirelessnetwork.4.3.5.2 RequirementA medium access protocol shall be 
implemented by the equipmentMark

> From: bstu...@dlsemc.com
> To: EMC-PSTC@LISTSERV.IEEE.ORG
> Subject: RE: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements
> Date: Tue, 27 Nov 2012 19:36:49 +
> 
> Please forgive my ignorance, but as am I wrong in assuming that a device 
> designed to operate meeting IEEE 802.11 standards would already meet the 
> requirements for adaptive equipment introduced in the ETSI standard?
> 
> Bill
> 
> 
> 
> -Original Message-
> From: Michael Derby [mailto:micha...@acbcert.com] 
> Sent: Tuesday, November 27, 2012 8:03 AM
> To: EMC-PSTC@LISTSERV.IEEE.ORG
> Subject: Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements
> 
> Hello all,
> 
> A mandatory requirement to have a Medium Access Protocol has existed in EN
> 300 328 since V1.7.1, which was published in 2006, first introduced onto the
> Official Journal sometime soon after that.   (the oldest OJ I have on record
> is 2008 and it's on there).
> 
> There were a lot of complaints that the section on Medium Access Protocol
> was not clear enough and people did not know what it meant.   Or, they knew
> what it meant but didn't know how thorough it needed to be.   We knew that
> IEEE 802.11 had it and we knew that Bluetooth hopped away from trouble.
> Zigbee was listed in the scope of the standard so we all felt happy about
> IEEE 802.15.4.   But what about everything else?
> 
> Industry called out for a better explanation and more clarification, which
> is summarised as the text we are discussing below.
> So, it is simply a clarification of an existing requirement.   It's not some
> sudden new requirement.
> 
> EN 300 328 V1.8.1 makes it even more clear and removes the requirement for
> clarifications in the OJ.
> 
> As a final comment, yes, there are manufacturers involved in the ETSI group
> for EN 300 328. :-) 
> 
> 
> Thanks,   Michael.
> 
> 
> Michael Derby
> Regulatory Engineer
> ACB Europe
> 
> 
> -Original Message-
> From: John Woodgate [mailto:j...@jmwa.demon.co.uk] 
> Sent: 27 November 2012 13:25
> To: EMC-PSTC@LISTSERV.IEEE.ORG
> Subject: Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements
> 
> In message
> <3f0347ac6ed9504191f91f07629fbb0c014f0...@thhsle14mbx2.hslive.net>,
> dated Tue, 27 Nov 2012, Charlie Blackham 
> writes:
> 
> >The reference has been in public domain for some years, and whilst the 
> >ETSI website is not always the easiest thing to navigate, draft 
> >standards are available, free of charge.
> 
> Even to non-members? I tried to get a draft document and couldn't.
> --
> OOO - Own Opinions Only. See www.jmwa.demon.co.uk The longer it takes to
> make a point, the more obtuse it proves to be.
> 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.html
> 
> Attachments are not permitted but the IEEE PSES Online Communities site at
> http://product-compliance.oc.ieee.org/ can be used for graphics (in
> well-used formats), large files, etc.
> 
> Website:  http://www.ieee-pses.org/
> Instructions:  http://listserv.ieee.org/request/user-guide.html
> List rules: http://www.ieee-pses.org/listrules.html
> 
> For help, send mail to the list administrators:
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> Mike Cantwell 
> 
> For policy questions, send mail to:
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> David Heald: 
> 
> -
> 
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> 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.html
> 
>

Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements

[Bill Stumpf]

Please forgive my ignorance, but as am I wrong in assuming that a device 
designed to operate meeting IEEE 802.11 standards would already meet the 
requirements for adaptive equipment introduced in the ETSI standard?

Bill



-Original Message-
From: Michael Derby [mailto:micha...@acbcert.com] 
Sent: Tuesday, November 27, 2012 8:03 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements

Hello all,

A mandatory requirement to have a Medium Access Protocol has existed in EN
300 328 since V1.7.1, which was published in 2006, first introduced onto the
Official Journal sometime soon after that.   (the oldest OJ I have on record
is 2008 and it's on there).

There were a lot of complaints that the section on Medium Access Protocol
was not clear enough and people did not know what it meant.   Or, they knew
what it meant but didn't know how thorough it needed to be.   We knew that
IEEE 802.11 had it and we knew that Bluetooth hopped away from trouble.
Zigbee was listed in the scope of the standard so we all felt happy about
IEEE 802.15.4.   But what about everything else?

Industry called out for a better explanation and more clarification, which
is summarised as the text we are discussing below.
So, it is simply a clarification of an existing requirement.   It's not some
sudden new requirement.

EN 300 328 V1.8.1 makes it even more clear and removes the requirement for
clarifications in the OJ.

As a final comment, yes, there are manufacturers involved in the ETSI group
for EN 300 328. :-) 


Thanks,   Michael.


Michael Derby
Regulatory Engineer
ACB Europe


-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk] 
Sent: 27 November 2012 13:25
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements

In message
<3f0347ac6ed9504191f91f07629fbb0c014f0...@thhsle14mbx2.hslive.net>,
dated Tue, 27 Nov 2012, Charlie Blackham 
writes:

>The reference has been in public domain for some years, and whilst the 
>ETSI website is not always the easiest thing to navigate, draft 
>standards are available, free of charge.

Even to non-members? I tried to get a draft document and couldn't.
--
OOO - Own Opinions Only. See www.jmwa.demon.co.uk The longer it takes to
make a point, the more obtuse it proves to be.
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements

[John Woodgate]

In message <0fee01cdcca7$f69c8530$e3d58f90$@acbcert.com>, dated Tue, 27 
Nov 2012, Michael Derby  writes:




As a final comment, yes, there are manufacturers involved in the ETSI 
group

for EN 300 328. :-)


I asked when the thread context was that the new requirement (to apply a 
provision of s not-yet-published edition) had been introduced without a 
transition period of any sort. Manufacturers would normally object to 
that very strongly. It now appears that there is a transition period.


But manufacturers' representatives on standards committees must 
*disregard* the advance knowledge that they get from participation when 
considering the impact of a change to a standard on the industry as a 
whole, unless they have taken positive steps to inform their industry 
associations of the new development.

--
OOO - Own Opinions Only. See www.jmwa.demon.co.uk
The longer it takes to make a point, the more obtuse it proves to be.
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

-

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Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements

[Michael Derby]

Hello all,

A mandatory requirement to have a Medium Access Protocol has existed in EN
300 328 since V1.7.1, which was published in 2006, first introduced onto the
Official Journal sometime soon after that.   (the oldest OJ I have on record
is 2008 and it's on there).

There were a lot of complaints that the section on Medium Access Protocol
was not clear enough and people did not know what it meant.   Or, they knew
what it meant but didn't know how thorough it needed to be.   We knew that
IEEE 802.11 had it and we knew that Bluetooth hopped away from trouble.
Zigbee was listed in the scope of the standard so we all felt happy about
IEEE 802.15.4.   But what about everything else?

Industry called out for a better explanation and more clarification, which
is summarised as the text we are discussing below.
So, it is simply a clarification of an existing requirement.   It's not some
sudden new requirement.

EN 300 328 V1.8.1 makes it even more clear and removes the requirement for
clarifications in the OJ.

As a final comment, yes, there are manufacturers involved in the ETSI group
for EN 300 328. :-) 


Thanks,   Michael.


Michael Derby
Regulatory Engineer
ACB Europe


-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk] 
Sent: 27 November 2012 13:25
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements

In message
<3f0347ac6ed9504191f91f07629fbb0c014f0...@thhsle14mbx2.hslive.net>,
dated Tue, 27 Nov 2012, Charlie Blackham 
writes:

>The reference has been in public domain for some years, and whilst the 
>ETSI website is not always the easiest thing to navigate, draft 
>standards are available, free of charge.

Even to non-members? I tried to get a draft document and couldn't.
--
OOO - Own Opinions Only. See www.jmwa.demon.co.uk The longer it takes to
make a point, the more obtuse it proves to be.
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

-

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For policy questions, send mail to:
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Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements

[John Woodgate]

In message 
<3f0347ac6ed9504191f91f07629fbb0c014f0...@thhsle14mbx2.hslive.net>, 
dated Tue, 27 Nov 2012, Charlie Blackham  
writes:


The reference has been in public domain for some years, and whilst the 
ETSI website is not always the easiest thing to navigate, draft 
standards are available, free of charge.


Even to non-members? I tried to get a draft document and couldn't.
--
OOO - Own Opinions Only. See www.jmwa.demon.co.uk
The longer it takes to make a point, the more obtuse it proves to be.
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

-

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list. To post a message to the list, send your e-mail to 

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Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements

[Charlie Blackham]

> Not in the public domain, so that argument can't be used to hold that 
> everyone should have known about it.



The reference has been in public domain for some years, and whilst the ETSI 
website is not always the easiest thing to navigate, draft standards are 
available, free of charge.



Regards

Charlie



-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk]
Sent: 27 November 2012 12:04
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements



In message

<3f0347ac6ed9504191f91f07629fbb0c014f0...@thhsle14mbx2.hslive.net<mailto:3f0347ac6ed9504191f91f07629fbb0c014f0...@thhsle14mbx2.hslive.net>>,

dated Tue, 27 Nov 2012, Charlie Blackham 
mailto:char...@sulisconsultants.com>>

writes:



>

>V1.8.1 has brought in some additional requirements, but the draft

>standard has been around for years



Not in the public domain, so that argument can't be used to hold that everyone 
should have known about it.



>and the published standard added to the OJ with a 26 month transition

>period.



OK, so there IS a transition period, which the OP seemed to think was not so, 
but 26 months is odd - should it be 36, which is the normal 3 years?

--

OOO - Own Opinions Only. See www.jmwa.demon.co.uk<http://www.jmwa.demon.co.uk> 
The longer it takes to make a point, the more obtuse it proves to be.

John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK



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Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements

[John Woodgate]

In message 
<3f0347ac6ed9504191f91f07629fbb0c014f0...@thhsle14mbx2.hslive.net>, 
dated Tue, 27 Nov 2012, Charlie Blackham  
writes:




V1.8.1 has brought in some additional requirements, but the draft 
standard has been around for years


Not in the public domain, so that argument can't be used to hold that 
everyone should have known about it.


and the published standard added to the OJ with a 26 month transition 
period.


OK, so there IS a transition period, which the OP seemed to think was 
not so, but 26 months is odd - should it be 36, which is the normal 3 
years?

--
OOO - Own Opinions Only. See www.jmwa.demon.co.uk
The longer it takes to make a point, the more obtuse it proves to be.
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

-

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list. To post a message to the list, send your e-mail to 

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Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements

[Charlie Blackham]

There has been a comment in the OJ regarding requirement for spectrum sharing 
since December 2009:

This version of the standard gives presumption of conformity with the 
requirements of Article 3(2) of Directive 1999/5/EC under the following 
condition: The equipment shall implement an adequate spectrum sharing 
mechanism, e.g. LBT (Listen Before Talk), DAA (Detect And Avoid), etc., in 
order to comply with the requirement specified in clause 4.3.5 of this version. 
Such a mechanism shall facilitate sharing between the various technologies and 
applications which currently exist and in case of congestion, users will be 
ensured equal access (and as a consequence a graceful degradation of service to 
all users). Harmonised ways for assessing the efficiency of various sharing 
mechanisms are currently been developed by ETSI in draft EN 300328 version 
1.8.1.

V1.8.1 has brought in some additional requirements, but the draft standard has 
been around for years and the published standard added to the OJ with a 26 
month transition period.

Regards
Charlie





-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk]
Sent: 27 November 2012 08:42
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements



In message 
mailto:snt108-w48a92b45f82f55a03910b9ad...@phx.gbl>>,
 dated Mon, 26 Nov 2012, Mark Gandler 
mailto:markgand...@hotmail.com>> writes:



>Bill,being struggling with the same question. 1.8.1 goes in effect only

>on 1.1.2015, but current 1.7.1 should be used with an adaptivity

>requirement from 1.8.1.It is very unusual circumstances where the

>requirement is pretty much "dropped" out of nowhere and looks like goes

>in effect immediately.Our test lab posted this question to an alleged

>author of the below note and his answer was "yes, it applies and must

>be tested". not sure how it all makes sense to etsi authors and RTTE

>committee. what about currently shipping equipment which been evaluated

>to 1.7.1 version, but before adaptivity note been posted?



It is indeed very unusual for a provision to come into effect without a 
transition period, and is normally not allowed. If it is allowed, there must be 
a safety or other over-riding issue to justify it and it must be explained 
publicly (at least according to many Directives).



Were manufacturer experts on the relevant ETSI standards committee unaware of 
this unusual development?

--

OOO - Own Opinions Only. See www.jmwa.demon.co.uk<http://www.jmwa.demon.co.uk> 
The longer it takes to make a point, the more obtuse it proves to be.

John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK



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Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements

[John Woodgate]

In message , dated Mon, 26 
Nov 2012, Mark Gandler  writes:


Bill,being struggling with the same question. 1.8.1 goes in effect only 
on 1.1.2015, but current 1.7.1 should be used with an adaptivity 
requirement from 1.8.1.It is very unusual circumstances where the 
requirement is pretty much "dropped" out of nowhere and looks like goes 
in effect immediately.Our test lab posted this question to an alleged 
author of the below note and his answer was "yes, it applies and must 
be tested". not sure how it all makes sense to etsi authors and RTTE 
committee. what about currently shipping equipment which been evaluated 
to 1.7.1 version, but before adaptivity note been posted?


It is indeed very unusual for a provision to come into effect without a 
transition period, and is normally not allowed. If it is allowed, there 
must be a safety or other over-riding issue to justify it and it must be 
explained publicly (at least according to many Directives).


Were manufacturer experts on the relevant ETSI standards committee 
unaware of this unusual development?

--
OOO - Own Opinions Only. See www.jmwa.demon.co.uk
The longer it takes to make a point, the more obtuse it proves to be.
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements

[Mark Gandler]

Bill,being struggling with the same question. 1.8.1 goes in effect only on 
1.1.2015, but current 1.7.1 should be used with an adaptivity requirement from 
1.8.1.It is very unusual circumstances where the requirement is pretty much 
"dropped" out of nowhere and looks like goes in effect immediately.Our test lab 
posted this question to an alleged author of the below note and his answer was 
"yes, it applies and must be tested". 
not sure how it all makes sense to etsi authors and RTTE committee. what about 
currently shipping equipment which been evaluated to 1.7.1 version, but before 
adaptivity note been posted? 
Mark
EN 300 328 V1.7.1Electromagnetic compatibility and Radio spectrum Matters 
(ERM); Wideband transmission systems; Data transmission equipment operating in 
the 2,4 GHz ISM band and using wide band modulation techniques; Harmonized EN 
covering essential requirements under article 3.2 of the R&TTE DirectiveEN 300 
328 V1.6.1

Note 2.1 Date expired
(30/06/2008) Article 3(2) This version of the standard gives presumption of 
conformity with the requirements of Article 3(2) of Directive 1999/5/EC under 
the following condition: The equipment shall implement an adequate spectrum 
sharing mechanism, e.g. LBT (Listen Before Talk), DAA (Detect And Avoid), etc., 
in order to comply with the requirement specified in clause 4.3.5 of this 
version. Such a mechanism shall facilitate sharing between the various 
technologies and applications which currently exist and in case of congestion, 
users will be ensured equal access (and as a consequence a graceful degradation 
of service to all users). The efficiency of the various sharing mechanisms can 
be assessed using the appropriate clauses of EN 300 328 version 1.8.1.ETSIEN 
300 328 V1.8.1 (new)Electromagnetic compatibility and Radio spectrum Matters 
(ERM); Wideband transmission systems; Data transmission equipment operating in 
the 2,4 GHz ISM band and using wide band modulation techniques; Harmonized EN 
covering the essential requirements of article 3.2 of the R&TTE DirectiveEN 300 
328 V1.7.1

Note 2.1 31/12/2014 Article 3(2) 
From: bstu...@dlsemc.com
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: EN 300 328 V1.8.1 new Adaptive equipment requirements
Date: Mon, 26 Nov 2012 16:08:18 +









Hello group,
ETSI 300 328 V1.8.1 adds a new set of requirements for adaptive radio 
equipment.  This will certainly put more of a burden on test labs, including 
additional
 test equipment needed to generate the “interference signal”.  Has anyone 
reviewed these new requirements that wishes to offer their opinion or guidance?
 
 
Bill Stumpf
D.L.S. Electronic Systems, Inc.
166 South Carter Street
Genoa City WI 53128
Ph: 262-279-0210
Email: bstu...@dlsemc.com
 



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[PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements

[Bill Stumpf]

Hello group,
ETSI 300 328 V1.8.1 adds a new set of requirements for adaptive radio 
equipment.  This will certainly put more of a burden on test labs, including 
additional test equipment needed to generate the “interference signal”.  Has 
anyone reviewed these new requirements that wishes to offer their opinion or 
guidance?


Bill Stumpf
D.L.S. Electronic Systems, Inc.
166 South Carter Street
Genoa City WI 53128
Ph: 262-279-0210
Email: bstu...@dlsemc.com


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R&TTE: Revision of ETSI EN 300 328

[emc-p...@ieee.org]

It came to my attention that (copied from the 2011-02-18 ZVEI presentation,
which I can share with those who are interested in the subject)

/Start quote: TCAM decided in the 26th meeting, to revise the above standard
in the following points: 

*   not only to restrict the application area to wide band data systems
*   the ensured, equal media usage (especially when the band is congested 
*   and for that purpose suited, verifiable media access mechanisms

ETSI TC ERM restricts the implementation of the above TCAM demands solely to
automatic adaptive mechanisms in every device (read: Automatic Adaptivity
orients itself to the requirements of consumer end-products, thereby
performance and application area for industrial products is significantly
reduced, so that wireless cannot be used anymore in Europe for many
applications.

/End quote.

Question: anyone knows why this has been promoted at this point? When will it
take effect, if adopted?
The ZVEI presentation hints at the possibility of a solution (establish an
Industrial Class within EN 300 328).

Thanks,
N. Shani
Ottawa, ON

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300 328

[reheller]

Does ETSI EN 300 328 cover voice transmission?

Thanks,
Bob Heller
St. Paul, MN 55107-1208
Tel:  651- 778-6336
Fax:  651-778-6252

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RE: EN 300 328-1

[Sam Wismer]

This is a multi-part message in MIME format.
Thanks for the information and clarification.  
 
What about narrow band signals such as frequency hoppers where the bandwidth
is at most 1MHz?  These signals are well within the RBW range of most spectrum
analyzers and power meters  Is the diode detector necessary?
 

 

 

Kind Regards,

 

 

Sam Wismer

Engineering Manager

ACS, Inc.

 

(Tel: (770) 831-8048

ÊFax: (770) 831-8598

:Web:  www.acstestlab.com <http://www.acstestlab.com/> 

* <mailto:*swis...@acstestlab.com> swis...@acstestlab.com

 


From: owner-emc-p...@majordomo.ieee.org
[mailto:owner-emc-p...@majordomo.ieee.org] On Behalf Of Rachid Sehb
Sent: Monday, October 06, 2003 11:03 AM
To: 'Sam Wismer'; EMC 2
Subject: RE: EN 300 328-1


Hello Sam, 
The diode detector is used to trigger  the envelope of the signal. Actually
this diode has to be used to determine the power output of the unit since the
802.11(b) would have BW around 10 MHz( the duty cycle would be used to correct
the peak power that needs to be below 20 dBm). The FCC recommends to use this
method to determine the power output of any large BW signal( the power meter
sensor's would not be able to do so)
I would not recommend to determine the duty cycle of your unit by using a
direct connection on your SA or oscilloscope. In any case, it would be up to
your reviewer to accept this kind of method.
 


From: Sam Wismer [mailto:swis...@acstestlab.com]
Sent: Monday, October 06, 2003 10:43 AM
To: EMC 2
Subject: EN 300 328-1


Hi All,
Section 7.2.1.2 step 1 seems to be a method of determining the duty cycle of
the EUT.  This step calls for a diode detector for the measurement.  My quick
research shows this to be a fairly expensive accessory piece of equipment.  I
have a couple of questions.
 
1)  What is the purpose of the diode detector?  Normally I use a direct
connection when measuring duty cycle?
2)  I have tested RLAN products in Europe to this standard before, and the
test house over there simply asked me what my duty cycle was.  They never
measured it.  Is it permissible to show the duty cycle in the form of timing
diagram instead.  The FCC allows this. 
 

 

 

Kind Regards,

 

 

Sam Wismer

Engineering Manager

ACS, Inc.

 

(Tel: (770) 831-8048

ÊFax: (770) 831-8598

:Web:  www.acstestlab.com <http://www.acstestlab.com/> 

* <mailto:*swis...@acstestlab.com> swis...@acstestlab.com

 

 


<>

RE: EN 300 328-1

[Rachid Sehb]

This is a multi-part message in MIME format.
Hello Sam, 
The diode detector is used to trigger  the envelope of the signal. Actually
this diode has to be used to determine the power output of the unit since the
802.11(b) would have BW around 10 MHz( the duty cycle would be used to correct
the peak power that needs to be below 20 dBm). The FCC recommends to use this
method to determine the power output of any large BW signal( the power meter
sensor's would not be able to do so)
I would not recommend to determine the duty cycle of your unit by using a
direct connection on your SA or oscilloscope. In any case, it would be up to
your reviewer to accept this kind of method.
 


From: Sam Wismer [mailto:swis...@acstestlab.com]
Sent: Monday, October 06, 2003 10:43 AM
To: EMC 2
Subject: EN 300 328-1


Hi All,
Section 7.2.1.2 step 1 seems to be a method of determining the duty cycle of
the EUT.  This step calls for a diode detector for the measurement.  My quick
research shows this to be a fairly expensive accessory piece of equipment.  I
have a couple of questions.
 
1)  What is the purpose of the diode detector?  Normally I use a direct
connection when measuring duty cycle?
2)  I have tested RLAN products in Europe to this standard before, and the
test house over there simply asked me what my duty cycle was.  They never
measured it.  Is it permissible to show the duty cycle in the form of timing
diagram instead.  The FCC allows this. 
 

 

 

Kind Regards,

 

 

Sam Wismer

Engineering Manager

ACS, Inc.

 

(Tel: (770) 831-8048

ÊFax: (770) 831-8598

:Web:  www.acstestlab.com <http://www.acstestlab.com/> 

* <mailto:*swis...@acstestlab.com> swis...@acstestlab.com

 

 


<>

EN 300 328-1

[Sam Wismer]

This is a multi-part message in MIME format.
Hi All,
Section 7.2.1.2 step 1 seems to be a method of determining the duty cycle of
the EUT.  This step calls for a diode detector for the measurement.  My quick
research shows this to be a fairly expensive accessory piece of equipment.  I
have a couple of questions.
 
1)  What is the purpose of the diode detector?  Normally I use a direct
connection when measuring duty cycle?
2)  I have tested RLAN products in Europe to this standard before, and the
test house over there simply asked me what my duty cycle was.  They never
measured it.  Is it permissible to show the duty cycle in the form of timing
diagram instead.  The FCC allows this. 
 

 

 

Kind Regards,

 

 

Sam Wismer

Engineering Manager

ACS, Inc.

 

(Tel: (770) 831-8048

ÊFax: (770) 831-8598

:Web:  www.acstestlab.com  

*  swis...@acstestlab.com

 

 


<>

Re: ETS 300 328

[Theo Hildering]

To:  Lizette de Vries-Venter

KTL is accredited to do the required testing & type-approval for 
your client, based upon the following ETSI standards:

- ETS 300 328 for the radio-specific requirements ( for 2.4 GHz 
band)

- ETS 300 826 for the EMC specific requirements.

With regard to the 5.8 GHz Rx,  other standards apply
 please contact our specialists:

Henry Rutjes e-mail: hrut...@ktl.com
Olaf van den Berg e-mail: ovdb...@ktl.com

(also for other radio/emc/maritime/mobile radio testing)


Kind regards,

Theo Hildering


H.T. Hildering,
KTL Arnhem bv,
P.O. box 60004, 6800JA Arnhem, The Netherlands.
Tel. +31263780780, Fax. +31263780789,

e-mail: h.t.hilder...@ktl.com
Internet: http://www.ktl.com


Tel.no. +31263780730, Fax no. +31263780789

e-mail: h.t.hilder...@ktl.com



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FW: ETS 300 328

[UMBDENSTOCK, DON]

Senton GmbH is a test lab in Germany that is certified for ETS 300328
testing.  Contact Johann Roidt at 

Senton GmbH
EMI/EMC Test Center
Aeussere Fruehlingsstrasse 45
D - 94315 Straubing
Germany

49 - 9421/5522 13

j.ro...@senton.de


Hope this helps.

Don Umbdenstock
Sensormatic



> > --
> > From:   DVVENTL Lizette de Vries-Vente[SMTP:dvve...@mail.sabs.co.za]
> > Reply To:   DVVENTL Lizette de Vries-Vente
> > Sent:   Thursday, May 06, 1999 10:47 AM
> > To: emc-p...@ieee.org
> > Subject:ETS 300 328
> > 
> > Hi Group
> > 
> > I have a client who needs to have ETS 300 328 type approval testing
> done. 
> >  It is some kind of tag that uses 2.4 or 5.8 GHz RX frequencies.  The
> lab 
> > also needs to be accredited for this specification by the national 
> > accreditation body of the country.
> > 
> > Can anybody make suggestions for European or US labs.  
> > 
> > Thanks,
> > Lizette de Vries-Venter
> > SENIOR ENGINEER
> > Division of Electronics and Appliances
> > SABS
> > 
> > Tel : +27 12 428 6990
> > Fax : +27 12 428 6523
> > Email : dvve...@sabs.co.za
> > 
> > 
> > -
> > This message is coming from the emc-pstc discussion list.
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> > with the single line: "unsubscribe emc-pstc" (without the
> > quotes).  For help, send mail to ed.pr...@cubic.com,
> > jim_bac...@monarch.com, ri...@sdd.hp.com, or
> > roger.volgst...@compaq.com (the list administrators).
> > 
> 
> 
> 

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ETS 300 328

[DVVENTL Lizette de Vries-Vente]

Hi Group

I have a client who needs to have ETS 300 328 type approval testing done. 
 It is some kind of tag that uses 2.4 or 5.8 GHz RX frequencies.  The lab 
also needs to be accredited for this specification by the national 
accreditation body of the country.

Can anybody make suggestions for European or US labs.  

Thanks,
Lizette de Vries-Venter
SENIOR ENGINEER
Division of Electronics and Appliances
SABS

Tel : +27 12 428 6990
Fax : +27 12 428 6523
Email : dvve...@sabs.co.za


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