RE: Using RTTE directive before April 2000?

1999-12-10 Thread H.T. Hildering

As I stated before, the RTTE directive is fully in force from the 8th of
April 2000.
The TTE/SES directive (98/13/EG) is withdrawn at the same moment, so there
is NO overlap (Articl. 20).

In some specific cases (e.g. voice-telephony, Articl. 18.3) member states
can  request for a 30 months delay on a national basis, but I haven't seen
something in that direction up to now. So let's stick to the basics of the
RTTE directive:

- There is a transition regime which allows manufacturers to continue with
the older approvals, set BEFORE the 8th of April 2000 (under  TTE/SES
procedures and marking OR under national regimes), but NOT longer than 1
year. After the 8th of April 2001 even these older products shall enter the
EU market according to the new rules of the RTTE directive.

- However, when it relates to NEW products  market access (not second
hand),  the RTTE is FULLY in force from the 8th of April 2000. So there is
no choice.

- When it concerns radio (transmitter apparatus), to be used with
NON-harmonised frequencies (country-specific) , there should be a warning
signal on the equipment, so that the USER is aware (The special sign, 0 with
a diagonal line, see Annex VII, (5)). The user manual should describe
clearly in which countries it is allowed to use. This warning signal shall
be stated on the package as well.

After the 8th of April 2001 ALL PRODUCTS entering the EU market must satisfy
the RTTE procedures AND marking.

-
How to deal with the RTTE?

The RTTE directive put a high pressure now on the EN Standardisation bodies
to generate new Harmonised Standards, based upon the Essential
requirements. (CEN, CENELEC, ETSI). For most  products this Harmonised
Standards will come too late.  To cope with the situation, it is allowed for
telecom equipment to use the present CTR's  - as far as the equipment falls
under its scope, as a presumption of conformity to the essential RTTE
requirements. Generally speaking the new requirements are less stringent, so
it is technically justified to use the older Standards.

However, a warning should be given for safety matters.
The RTTE directive has a new approach towards safety. It includes also the
requirements of directive 73/23/EEG, WITHOUT the supply restrictions, so
battery operated equipment is included now (Artcl.3.1a). That means that ALL
risks arising from the use shall be covered as well, e.g.  acoustical shock,
and EMF (!) etc. With regard to EMF we have seen the impact already with the
mandate to the EU Standardisation bodies to define new requirements, first
for GSM and other mobile equipment (before April 2000 !)

So, after the 8th of April, manufacturers can better choose the Technical
Construction File  (TCF) approach as described under Annex IV, and ask an
RTTE  Notified Body (see Annex IV and V)  for an Opinion. (A written
statement about your TCF).  This gives no guarantee in liability issues, but
in case that it goes wrong, you can show in a fair way your careful and
prudent approach.

Best regards,

Theo Hildering,

Senior Consultant,
KTL-Arnhem, The Netherlands
Web-site:  www.ktl.com








-Original Message-
From:   Leslie Bai [mailto:leslie_...@yahoo.com]
Sent:   10 December 1999 02:20
To: H.T. Hildering; j...@aol.com; emc-p...@majordomo.ieee.org;
t...@world.std.com
Subject:RE: Using RTTE directive before April 2000?

There is a transition regime applies.

Before April 8, 2000, we knew what we should do

Between April 8, 2000 and April 7, 2001, the
transition
regime applies and manufacturers can place on the
market
and put into service equipment which
Case 1. complies with Directive 99/5/EC
Case 2. complies with Directive 98/13/EC (for
equipment
within its scope)
Case 3. complies with national regulations (for radio
equipment, which don't fall within teh scope of
Directive
98/13/EC).

In Case 1 and Case 2, equipment can freeely move
according to the provisions of the Directives.
In Case 3, Articles 28 and 30 apply.

As of April 8, 2001, ONLY Directive 99/5/EC applies.

Rgds,
Leslie



--- H.T. Hildering h.t.hilder...@ktl.com wrote:

 The situation is simple,

 The European Commission has stated that the RTTE
 directive will come
 effectively in force on the 8th of April 2000 for
 all EU countries.
 Therefore all member countries are obliged to
 transpose it into their
 national regulation before that date.
 All member countries shall start to use the RTTE
 directive at the 8th of
 April.

 Best regards

 Theo Hildering








 -Original Message-
 From: owner-emc-p...@ieee.org
 [mailto:owner-emc-p...@ieee.org] On Behalf Of
 j...@aol.com
 Sent: 08 December 1999 22:13
 To:   emc-p...@majordomo.ieee.org; t...@world.std.com
 Subject:  Using RTTE directive before April 2000?


 Listmembers:

 I have a question that perhaps some of you can help
 me with.  I'm developing
 a regulatory compliance plan for a new telecom
 product that is scheduled to
 begin shipping in the first quarter of 2000

RE: Using RTTE directive before April 2000?

1999-12-10 Thread Victor L. Boersma
Message text written by Roger Magnuson
 As you know, the current Directive took much too long
to implement in certain countries (no names...) and I guess this is the
reason for this unusal
approach.

Roger,


the approach is not unusual under the terms of the Treaty of Maastricht
which no longer requires that the member states must transpose the
Directive before it is implemented.  That was one of the victories of that
Treaty (some will not see it that way).

The only thing unusual is that the RTTE Directive is implemented, 
POST MAASTRICHT, all the other ones so far were PRE MAASTRICHT.
This will be the norm in the future, in particular for the new EMC
Directive.


Ciao,


Vic


RE: Using RTTE directive before April 2000?

1999-12-10 Thread Leslie Bai

There is a transition regime applies.

Before April 8, 2000, we knew what we should do

Between April 8, 2000 and April 7, 2001, the
transition
regime applies and manufacturers can place on the
market
and put into service equipment which
Case 1. complies with Directive 99/5/EC
Case 2. complies with Directive 98/13/EC (for
equipment
within its scope)
Case 3. complies with national regulations (for radio 
equipment, which don't fall within teh scope of
Directive
98/13/EC).

In Case 1 and Case 2, equipment can freeely move 
according to the provisions of the Directives.
In Case 3, Articles 28 and 30 apply.

As of April 8, 2001, ONLY Directive 99/5/EC applies.

Rgds,
Leslie

 

--- H.T. Hildering h.t.hilder...@ktl.com wrote:
 
 The situation is simple,
 
 The European Commission has stated that the RTTE
 directive will come
 effectively in force on the 8th of April 2000 for
 all EU countries.
 Therefore all member countries are obliged to
 transpose it into their
 national regulation before that date.
 All member countries shall start to use the RTTE
 directive at the 8th of
 April.
 
 Best regards
 
 Theo Hildering
 
 
 
 
 
 
 
 
 -Original Message-
 From: owner-emc-p...@ieee.org
 [mailto:owner-emc-p...@ieee.org] On Behalf Of
 j...@aol.com
 Sent: 08 December 1999 22:13
 To:   emc-p...@majordomo.ieee.org; t...@world.std.com
 Subject:  Using RTTE directive before April 2000?
 
 
 Listmembers:
 
 I have a question that perhaps some of you can help
 me with.  I'm developing
 a regulatory compliance plan for a new telecom
 product that is scheduled to
 begin shipping in the first quarter of 2000.  The
 exact date is not certain,
 but it is likely to be before the April 8, 2000 date
 that appears in the
 RTTE
 directive.
 
 If possible, I would like to avoid the whole
 notified body route called out
 by the current directive 98/13/EC, especially since
 it would only be
 required
 for the brief period until April 2000.
 
 I seem to recall that a new directive can be used as
 soon as *any* member
 state has transposed it into national law.  If so,
 this suggests that the
 RTTE directive could be used prior to April 2000 if
 at least one member
 state
 has transposed it into national law.
 
 In the case of the UK, however, recent postings on
 the emc-pstc listserver
 indicate that the draft legislation for the UK calls
 out an effective date
 of
 April 8, 2000.  In other words, even if the UK
 transposes the directive
 prior
 to April 2000, the national law itself will call out
 an effective date of
 April 8.  I do not know what the other member states
 are planning to do.
 
 So, am I stuck with using directive 98/13/EC and the
 notified body route if
 the product ships prior to April 8, 2000?
 
 
 Joe Randolph
 Telecom Design Consultant
 Randolph Telecom, Inc.
 
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RE: Using RTTE directive before April 2000?

1999-12-09 Thread Roger Magnuson
Joe,

To the best of my knowledge, the implementation of RTTE differs from all 
previous telecoms
directives as *all* Member States *must* start using it on April 8, 2000. The 
current TTE
Directive   is valid until April 7, 2000. As you know, the current Directive 
took much too long
to implement in certain countries (no names...) and I guess this is the reason 
for this unusal
approach.


Roger Magnuson
Manager, Marketing  Business Development

TGC AB
Dalvagen 28, 169 56 SOLNA, Sweden
TEL: +46 856250050 (direct)
FAX: +46 856250045
mobile: +46 707770594
mailto:ro...@tgc.se
internet: http://www.tgc.se




-Original Message-
From: treg-appro...@world.std.com [mailto:treg-appro...@world.std.com]On
Behalf Of j...@aol.com
Sent: Wednesday, December 08, 1999 10:13 PM
To: emc-p...@majordomo.ieee.org; t...@world.std.com
Subject: Using RTTE directive before April 2000?


Listmembers:

I have a question that perhaps some of you can help me with.  I'm developing
a regulatory compliance plan for a new telecom product that is scheduled to
begin shipping in the first quarter of 2000.  The exact date is not certain,
but it is likely to be before the April 8, 2000 date that appears in the RTTE
directive.

If possible, I would like to avoid the whole notified body route called out
by the current directive 98/13/EC, especially since it would only be required
for the brief period until April 2000.

I seem to recall that a new directive can be used as soon as *any* member
state has transposed it into national law.  If so, this suggests that the
RTTE directive could be used prior to April 2000 if at least one member state
has transposed it into national law.

In the case of the UK, however, recent postings on the emc-pstc listserver
indicate that the draft legislation for the UK calls out an effective date of
April 8, 2000.  In other words, even if the UK transposes the directive prior
to April 2000, the national law itself will call out an effective date of
April 8.  I do not know what the other member states are planning to do.

So, am I stuck with using directive 98/13/EC and the notified body route if
the product ships prior to April 8, 2000?


Joe Randolph
Telecom Design Consultant
Randolph Telecom, Inc.


RE: Using RTTE directive before April 2000?

1999-12-09 Thread H.T. Hildering

The situation is simple,

The European Commission has stated that the RTTE directive will come
effectively in force on the 8th of April 2000 for all EU countries.
Therefore all member countries are obliged to transpose it into their
national regulation before that date.
All member countries shall start to use the RTTE directive at the 8th of
April.

Best regards

Theo Hildering








-Original Message-
From:   owner-emc-p...@ieee.org [mailto:owner-emc-p...@ieee.org] On Behalf Of
j...@aol.com
Sent:   08 December 1999 22:13
To: emc-p...@majordomo.ieee.org; t...@world.std.com
Subject:Using RTTE directive before April 2000?


Listmembers:

I have a question that perhaps some of you can help me with.  I'm developing
a regulatory compliance plan for a new telecom product that is scheduled to
begin shipping in the first quarter of 2000.  The exact date is not certain,
but it is likely to be before the April 8, 2000 date that appears in the
RTTE
directive.

If possible, I would like to avoid the whole notified body route called out
by the current directive 98/13/EC, especially since it would only be
required
for the brief period until April 2000.

I seem to recall that a new directive can be used as soon as *any* member
state has transposed it into national law.  If so, this suggests that the
RTTE directive could be used prior to April 2000 if at least one member
state
has transposed it into national law.

In the case of the UK, however, recent postings on the emc-pstc listserver
indicate that the draft legislation for the UK calls out an effective date
of
April 8, 2000.  In other words, even if the UK transposes the directive
prior
to April 2000, the national law itself will call out an effective date of
April 8.  I do not know what the other member states are planning to do.

So, am I stuck with using directive 98/13/EC and the notified body route if
the product ships prior to April 8, 2000?


Joe Randolph
Telecom Design Consultant
Randolph Telecom, Inc.

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