RE: R&TTE Directive Member States Notification

[fdev...@assaabloyitg.com]

Rich,

Inductive Devices operating at 13.56 MHz are Class 1 and are therefore
harmonized in the EU.

Non-specific 13.56 MHz devices are not Class 1 and are therefore not
harmonized.  See http://www.ero.dk/rtte

Regards,

Frank de Vall
Assa Abloy ITG



  

  richwo...@tycoint.com   

  Sent by:  To:  
emc-p...@majordomo.ieee.org  
  owner-emc-pstc@majordocc:   

  mo.ieee.org   Subject:  RE: R&TTE
Directive Member States Notification   
  

  

  07/02/2003 08:51 AM 

  Please respond to   

  richwoods   

  

  






I understand that Class 1 products use harmonized bands. 13.56 MHz is not
harmonized. Sigh!

Richard Woods
Sensormatic Electronics
Tyco International



From: rehel...@mmm.com [mailto:rehel...@mmm.com]
Sent: Wednesday, July 02, 2003 10:05 AM
To: emc-p...@majordomo.ieee.org
Subject: RE: R&TTE Directive Member States Notification



Out of curiosity...are there ANY harmonized frequencies in Europe?
Is 13.56 MHz harmonized?

Bob Heller
3M EMC Laboratory, 76-1-01
St. Paul, MN 55107-1208
Tel:  651- 778-6336
Fax:  651-778-6252




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RE: R&TTE Directive Member States Notification

[Bill Stumpf]

Bob,
Go to the ERO website www.ero.dk and download ERC report 25. It's a big
help when determining frequency allocation/use in the EU.

Bill Stumpf
William M Stumpf
DLS Electronics
166 South Carter St.
Genoa City WI 53128
ph: 262-279-0210
fx: 262-279-3630
email: bstu...@dlsemc.com



From: rehel...@mmm.com [mailto:rehel...@mmm.com]
Sent: Wednesday, July 02, 2003 9:05 AM
To: emc-p...@majordomo.ieee.org
Subject: RE: R&TTE Directive Member States Notification



Out of curiosity...are there ANY harmonized frequencies in
Europe?
Is 13.56 MHz harmonized?

Bob Heller
3M EMC Laboratory, 76-1-01
St. Paul, MN 55107-1208
Tel:  651- 778-6336
Fax:  651-778-6252




This message is from the IEEE EMC Society Product Safety
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RE: R&TTE Directive Member States Notification

[richwo...@tycoint.com]

Ah, you have hit upon a problem that I see with the Directive. When the
spectrum is not harmonized and Notification is required, who is responsible
for ensuring that the equipment operates according to the spectrum usage
requirements of the Notified country. Is it the responsibility of the
manufacturer or the country spectrum authorities? If I fail to receive a
reply from my Notification, the Directive says I am free to market the
equipment after the Notifcation period has elapsed. But what if the country
failed to reply and yet the country has a spectrum restriction? I have
received some replies that say they have received my Notification and I can
market the equipment if it conforms with the spectrum regulations. Huh? They
may as well have said "We received your Notification but did not read it.
This reply is just a formality and all of the conformity responsiblity
belongs to you." 

My understanding of the Directive is that I can market my product unless the
spectrum authority specifically says NO. Of course, the spectrum authority
who sent the crazy worded message probably thinks otherwise.

Richard Woods
Sensormatic Electronics
Tyco International





From: Barker, Neil [mailto:neil.bar...@e2vtechnologies.com]
Sent: Wednesday, July 02, 2003 10:11 AM
To: 'Bill Stumpf'; emc-p...@majordomo.ieee.org
Subject: RE: R&TTE Directive Member States Notification



My understanding is that where there is a harmonised standard, but the
spectrum usage is not harmonised, then there is no need to involve a
Notified Body for any of the testing, but you do need a Spectrum Usage
Report from a Notified Body to ratify the intended usage of the device in
the target destination. I have had such reports produced by BABT, and the
cost is quite minimal, probably equivalent to about one man-day's effort,
which is about all that it should take to review the documentation. In this
instance, I would suggest that it is perfectly legitimate to place the NB
number alongside the CE marking to indicate their involvement in determining
the product's suitability for the intended market.
Broadly speaking, it seems to me that for a Class 1 device (harmonised
standards and spectrum usage) there is no need for a NB, but for Class 2
devices, a NB will need to be involved for the spectrum usage at least.

Best regards,

Neil R. Barker
Compliance Engineering Manager
e2v technologies ltd
Waterhouse Lane
Chelmsford
Essex
CM1 2QU
U.K.

Tel: +44 (01245) 453616
Fax: +44 (01245) 453410
E-mail: neil.bar...@e2vtechnologies.com


> -Original Message-
> From: Bill Stumpf [mailto:bstu...@dlsemc.com]
> Sent: 02 July 2003 13:59
> To: emc-p...@majordomo.ieee.org
> Subject: RE: R&TTE Directive Member States Notification
> 
> 
> 
> Richard Woods wrote: Gerald, please explain why a Notified Body number
> is required? I thought that a harmonized ETSI standard exists.
> 
> A Notified Body number is not required unless a Notified Body (NB or
> CAB) is consulted for the job. Since there are Harmonized 
> standards that
> can be used for this type of product, a NB/CAB is not required. The
> manufacturer is responsible for compliance with the Essential
> Requirements of the Directives, therefore they are responsible for
> notifying the different Member States of the EU of their intent to
> market the device in their country.
> 
> William M Stumpf
> DLS Electronics
> 166 South Carter St.
> Genoa City WI 53128
> ph: 262-279-0210
> fx: 262-279-3630
> email: bstu...@dlsemc.com
> EU CAB for EMC and R&TTE
> 
> -Original Message-
> From: richwo...@tycoint.com [mailto:richwo...@tycoint.com]
> Sent: Tuesday, July 01, 2003 1:32 PM
> To: emc-p...@majordomo.ieee.org
> Subject: RE: R&TTE Directive Member States Notification
> 
> 
> 
> Gerald, please explain why a Notified Body number is 
> required? I thought
> that a harmonized ETSI standard exists.
> 
> Richard Woods
> Sensormatic Electronics
> Tyco International
> 
> 
> -Original Message-
> From: Gerald Tammi [mailto:gera...@zoom.com]
> Sent: Tuesday, July 01, 2003 12:52 PM
> To: 'Jan Heffken'; emc-p...@majordomo.ieee.org
> Subject: RE: R&TTE Directive Member States Notification
> 
> 
> 
> I have gone through the process of a 802.11 WLAN.
> 
> France is not harmonized to the rest on the EU in the 2.4Ghz spread
> spectrum.
> 
> Yes you will need a NOTIFIED BODY number to submit with the country
> notifications
> 
> Yes you need to send notification to each country that you 
> want to sell
> into.
> 
> There is a 30 day waiting period for each country to reply before you
> can
> sell into that market.  {they may respond sooner that the 30 
> days}  They
> may
> reject especially if there is an external antenna.
> 
> If 

RE: R&TTE Directive Member States Notification

[Lothar Schmidt]

Yes there are harmonized bands

E.g. cellular bands for GSM in the 900 and 1800 MHz range, some satellite
services.

These are bands were the different member states didn't had other radio
services before. For this reason this was easy to harmonize. But if some
member states had radio services in certain areas this will take time to
remove these services, since there are users having devices which can't be
used after changing this.


Lothar Schmidt
BQB & Technical Manager 
EMC/Radio/SAR

CETECOM Inc.
411 Dixon Landing Road 
Milpitas, CA 95035

' +1 408 586 6214
7 +1 408 586 6299






From: rehel...@mmm.com [mailto:rehel...@mmm.com]
Sent: Wednesday, July 02, 2003 7:05 AM
To: emc-p...@majordomo.ieee.org
Subject: RE: R&TTE Directive Member States Notification



Out of curiosity...are there ANY harmonized frequencies in Europe?
Is 13.56 MHz harmonized?

Bob Heller
3M EMC Laboratory, 76-1-01
St. Paul, MN 55107-1208
Tel:  651- 778-6336
Fax:  651-778-6252




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>>> Download free spam killer at http://eliminatespam.com



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RE: R&TTE Directive Member States Notification

[richwo...@tycoint.com]

I understand that Class 1 products use harmonized bands. 13.56 MHz is not
harmonized. Sigh!

Richard Woods
Sensormatic Electronics
Tyco International



From: rehel...@mmm.com [mailto:rehel...@mmm.com]
Sent: Wednesday, July 02, 2003 10:05 AM
To: emc-p...@majordomo.ieee.org
Subject: RE: R&TTE Directive Member States Notification



Out of curiosity...are there ANY harmonized frequencies in Europe?
Is 13.56 MHz harmonized?

Bob Heller
3M EMC Laboratory, 76-1-01
St. Paul, MN 55107-1208
Tel:  651- 778-6336
Fax:  651-778-6252




This message is from the IEEE EMC Society Product Safety
Technical Committee emc-pstc discussion list.

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RE: R&TTE Directive Member States Notification

[Barker, Neil]

My understanding is that where there is a harmonised standard, but the
spectrum usage is not harmonised, then there is no need to involve a
Notified Body for any of the testing, but you do need a Spectrum Usage
Report from a Notified Body to ratify the intended usage of the device in
the target destination. I have had such reports produced by BABT, and the
cost is quite minimal, probably equivalent to about one man-day's effort,
which is about all that it should take to review the documentation. In this
instance, I would suggest that it is perfectly legitimate to place the NB
number alongside the CE marking to indicate their involvement in determining
the product's suitability for the intended market.
Broadly speaking, it seems to me that for a Class 1 device (harmonised
standards and spectrum usage) there is no need for a NB, but for Class 2
devices, a NB will need to be involved for the spectrum usage at least.

Best regards,

Neil R. Barker
Compliance Engineering Manager
e2v technologies ltd
Waterhouse Lane
Chelmsford
Essex
CM1 2QU
U.K.

Tel: +44 (01245) 453616
Fax: +44 (01245) 453410
E-mail: neil.bar...@e2vtechnologies.com


> -Original Message-
> From: Bill Stumpf [mailto:bstu...@dlsemc.com]
> Sent: 02 July 2003 13:59
> To: emc-p...@majordomo.ieee.org
> Subject: RE: R&TTE Directive Member States Notification
> 
> 
> 
> Richard Woods wrote: Gerald, please explain why a Notified Body number
> is required? I thought that a harmonized ETSI standard exists.
> 
> A Notified Body number is not required unless a Notified Body (NB or
> CAB) is consulted for the job. Since there are Harmonized 
> standards that
> can be used for this type of product, a NB/CAB is not required. The
> manufacturer is responsible for compliance with the Essential
> Requirements of the Directives, therefore they are responsible for
> notifying the different Member States of the EU of their intent to
> market the device in their country.
> 
> William M Stumpf
> DLS Electronics
> 166 South Carter St.
> Genoa City WI 53128
> ph: 262-279-0210
> fx: 262-279-3630
> email: bstu...@dlsemc.com
> EU CAB for EMC and R&TTE
> 
> -Original Message-
> From: richwo...@tycoint.com [mailto:richwo...@tycoint.com]
> Sent: Tuesday, July 01, 2003 1:32 PM
> To: emc-p...@majordomo.ieee.org
> Subject: RE: R&TTE Directive Member States Notification
> 
> 
> 
> Gerald, please explain why a Notified Body number is 
> required? I thought
> that a harmonized ETSI standard exists.
> 
> Richard Woods
> Sensormatic Electronics
> Tyco International
> 
> 
> -Original Message-
> From: Gerald Tammi [mailto:gera...@zoom.com]
> Sent: Tuesday, July 01, 2003 12:52 PM
> To: 'Jan Heffken'; emc-p...@majordomo.ieee.org
> Subject: RE: R&TTE Directive Member States Notification
> 
> 
> 
> I have gone through the process of a 802.11 WLAN.
> 
> France is not harmonized to the rest on the EU in the 2.4Ghz spread
> spectrum.
> 
> Yes you will need a NOTIFIED BODY number to submit with the country
> notifications
> 
> Yes you need to send notification to each country that you 
> want to sell
> into.
> 
> There is a 30 day waiting period for each country to reply before you
> can
> sell into that market.  {they may respond sooner that the 30 
> days}  They
> may
> reject especially if there is an external antenna.
> 
> If you are shipping out of the United States, and the product has an
> embedded encryption engine; you need to file for an export 
> license with
> the
> US BXA.  Also you need to comply with control of export to the T7
> terrorist
> countries ban.
> 
> Gerald Tammi
> Zoom Telephonics.
> Boston, MA
> 
> 
> -Original Message-
> From: Jan Heffken [mailto:jheff...@core.com]
> Sent: Tuesday, July 01, 2003 10:04 AM
> To: emc-p...@majordomo.ieee.org
> Subject: R&TTE Directive Member States Notification
> 
> 
> 
> I am a little confused about paragraph 31 of the R&TTE Directive. I 
> have copied it below. My understanding is that if our 
> equipment (2.4GHz 
> outdoor WLAN) operates in a non-harmonised frequency band, 
> then we have 
> to Notify Member States where it is not harmonised.
> 
> Where can I find answers to the following questions.
> 
> Is the 2,4GHz. spread spectum band harmonized through the EU?
> 
> Which Member States have not harmonized?
> 
> Do I have to go through a Notified Body to Notify?
> 
> Since paragraph 31 uses "should" and not "shall" do I have to 
> do it all?
> 
> Paragraph 31 from the R&TTE Directive.
> (31) Whereas manufacturers should notify Member States
> of their intention to place radio equipment

RE: R&TTE Directive Member States Notification

[rehel...@mmm.com]

Out of curiosity...are there ANY harmonized frequencies in Europe?
Is 13.56 MHz harmonized?

Bob Heller
3M EMC Laboratory, 76-1-01
St. Paul, MN 55107-1208
Tel:  651- 778-6336
Fax:  651-778-6252




This message is from the IEEE EMC Society Product Safety
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Visit our web site at:  http://www.ewh.ieee.org/soc/emcs/pstc/

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For help, send mail to the list administrators:
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Archive is being moved, we will announce when it is back on-line.
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RE: R&TTE Directive Member States Notification

[richwo...@tycoint.com]

My company has notified many products to all of the EU and EFTA member
countries based upon using a harmonized standard and a non-harmonized band
and we have never needed to add a Notified Body number to the form. Indeed,
in the beginning when we left that part blank, some countries asked for the
information. Then we got smart and indicated on the form that the number was
not required because we applied a harmonized standard. After that, we had no
problems.

Regards, 

Richard Woods
Sensormatic Electronics
Tyco International



From: alain.sam...@gigabyte.com.tw [mailto:alain.sam...@gigabyte.com.tw]
Sent: Tuesday, July 01, 2003 9:51 PM
To: jheff...@core.com; emc-p...@majordomo.ieee.org
Subject: RE: R&TTE Directive Member States Notification



Even though individual country forms do not explicitly suggest the "if
applicable" condition, just take the initiative to put "not considered" or
"not considered - the product is conformed to harmonized standards" in place
of the number of the NB.
I guess many of us tried it, and it worked.

Alain
Giga-Byte



From: Gerald Tammi [mailto:gera...@zoom.com] 
Sent: Wednesday, July 02, 2003 4:35 AM
To: 'richwo...@tycoint.com'; emc-p...@majordomo.ieee.org
Subject: RE: R&TTE Directive Member States Notification


The 2.4 Ghz frequency spectrum is NOT harmonized. France is one of the
countries that has a restricted band allocation

It may not be true per the a directive, however if you download the required
individual notification forms by country; you will see that there is an
entry required for the notified body name and number. The general form in
the EU catalog says "if applicable.  the individual country forms are
similar but customized to that country.  Many of the forms are in the
language of the country only, with no English version.


From: richwo...@tycoint.com [mailto:richwo...@tycoint.com]
Sent: Tuesday, July 01, 2003 2:32 PM
To: emc-p...@majordomo.ieee.org
Subject: RE: R&TTE Directive Member States Notification



Gerald, please explain why a Notified Body number is required? I thought
that a harmonized ETSI standard exists.

Richard Woods
Sensormatic Electronics
Tyco International



From: Gerald Tammi [mailto:gera...@zoom.com]
Sent: Tuesday, July 01, 2003 12:52 PM
To: 'Jan Heffken'; emc-p...@majordomo.ieee.org
Subject: RE: R&TTE Directive Member States Notification



I have gone through the process of a 802.11 WLAN.

France is not harmonized to the rest on the EU in the 2.4Ghz spread
spectrum.

Yes you will need a NOTIFIED BODY number to submit with the country
notifications

Yes you need to send notification to each country that you want to sell
into.

There is a 30 day waiting period for each country to reply before you can
sell into that market.  {they may respond sooner that the 30 days}  They may
reject especially if there is an external antenna.

If you are shipping out of the United States, and the product has an
embedded encryption engine; you need to file for an export license with the
US BXA.  Also you need to comply with control of export to the T7 terrorist
countries ban.

Gerald Tammi
Zoom Telephonics.
Boston, MA



From: Jan Heffken [mailto:jheff...@core.com]
Sent: Tuesday, July 01, 2003 10:04 AM
To: emc-p...@majordomo.ieee.org
Subject: R&TTE Directive Member States Notification



I am a little confused about paragraph 31 of the R&TTE Directive. I 
have copied it below. My understanding is that if our equipment (2.4GHz 
outdoor WLAN) operates in a non-harmonised frequency band, then we have 
to Notify Member States where it is not harmonised.

Where can I find answers to the following questions.

Is the 2,4GHz. spread spectum band harmonized through the EU?

Which Member States have not harmonized?

Do I have to go through a Notified Body to Notify?

Since paragraph 31 uses "should" and not "shall" do I have to do it all?

Paragraph 31 from the R&TTE Directive.
(31) Whereas manufacturers should notify Member States
of their intention to place radio equipment on the
market using frequency bands whose use is not
harmonised throughout the Community; whereas
Member States therefore need to put in place procedures
for such notification; whereas such procedures
should be proportionate and should not constitute a
conformity assessment procedure additional to those
provided for in Annexes IV or V; whereas it is desirable
that those notification procedures should be
harmonised and preferably implemented by electronic
means and one-stop-shopping;

Thanks in advance,

Jan Heffken
-- 
CoreComm Webmail. 
http://home.core.com



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RE: R&TTE Directive Member States Notification

[Bill Stumpf]

Richard Woods wrote: Gerald, please explain why a Notified Body number
is required? I thought that a harmonized ETSI standard exists.

A Notified Body number is not required unless a Notified Body (NB or
CAB) is consulted for the job. Since there are Harmonized standards that
can be used for this type of product, a NB/CAB is not required. The
manufacturer is responsible for compliance with the Essential
Requirements of the Directives, therefore they are responsible for
notifying the different Member States of the EU of their intent to
market the device in their country.

William M Stumpf
DLS Electronics
166 South Carter St.
Genoa City WI 53128
ph: 262-279-0210
fx: 262-279-3630
email: bstu...@dlsemc.com
EU CAB for EMC and R&TTE


From: richwo...@tycoint.com [mailto:richwo...@tycoint.com]
Sent: Tuesday, July 01, 2003 1:32 PM
To: emc-p...@majordomo.ieee.org
Subject: RE: R&TTE Directive Member States Notification



Gerald, please explain why a Notified Body number is required? I thought
that a harmonized ETSI standard exists.

Richard Woods
Sensormatic Electronics
Tyco International



From: Gerald Tammi [mailto:gera...@zoom.com]
Sent: Tuesday, July 01, 2003 12:52 PM
To: 'Jan Heffken'; emc-p...@majordomo.ieee.org
Subject: RE: R&TTE Directive Member States Notification



I have gone through the process of a 802.11 WLAN.

France is not harmonized to the rest on the EU in the 2.4Ghz spread
spectrum.

Yes you will need a NOTIFIED BODY number to submit with the country
notifications

Yes you need to send notification to each country that you want to sell
into.

There is a 30 day waiting period for each country to reply before you
can
sell into that market.  {they may respond sooner that the 30 days}  They
may
reject especially if there is an external antenna.

If you are shipping out of the United States, and the product has an
embedded encryption engine; you need to file for an export license with
the
US BXA.  Also you need to comply with control of export to the T7
terrorist
countries ban.

Gerald Tammi
Zoom Telephonics.
Boston, MA



From: Jan Heffken [mailto:jheff...@core.com]
Sent: Tuesday, July 01, 2003 10:04 AM
To: emc-p...@majordomo.ieee.org
Subject: R&TTE Directive Member States Notification



I am a little confused about paragraph 31 of the R&TTE Directive. I 
have copied it below. My understanding is that if our equipment (2.4GHz 
outdoor WLAN) operates in a non-harmonised frequency band, then we have 
to Notify Member States where it is not harmonised.

Where can I find answers to the following questions.

Is the 2,4GHz. spread spectum band harmonized through the EU?

Which Member States have not harmonized?

Do I have to go through a Notified Body to Notify?

Since paragraph 31 uses "should" and not "shall" do I have to do it all?

Paragraph 31 from the R&TTE Directive.
(31) Whereas manufacturers should notify Member States
of their intention to place radio equipment on the
market using frequency bands whose use is not
harmonised throughout the Community; whereas
Member States therefore need to put in place procedures
for such notification; whereas such procedures
should be proportionate and should not constitute a
conformity assessment procedure additional to those
provided for in Annexes IV or V; whereas it is desirable
that those notification procedures should be
harmonised and preferably implemented by electronic
means and one-stop-shopping;

Thanks in advance,

Jan Heffken
-- 
CoreComm Webmail. 
http://home.core.com



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htt

RE: R&TTE Directive Member States Notification

[alain.sam...@gigabyte.com.tw]

Even though individual country forms do not explicitly suggest the "if
applicable" condition, just take the initiative to put "not considered" or
"not considered - the product is conformed to harmonized standards" in place
of the number of the NB.
I guess many of us tried it, and it worked.

Alain
Giga-Byte



From: Gerald Tammi [mailto:gera...@zoom.com] 
Sent: Wednesday, July 02, 2003 4:35 AM
To: 'richwo...@tycoint.com'; emc-p...@majordomo.ieee.org
Subject: RE: R&TTE Directive Member States Notification


The 2.4 Ghz frequency spectrum is NOT harmonized. France is one of the
countries that has a restricted band allocation

It may not be true per the a directive, however if you download the required
individual notification forms by country; you will see that there is an
entry required for the notified body name and number. The general form in
the EU catalog says "if applicable.  the individual country forms are
similar but customized to that country.  Many of the forms are in the
language of the country only, with no English version.


From: richwo...@tycoint.com [mailto:richwo...@tycoint.com]
Sent: Tuesday, July 01, 2003 2:32 PM
To: emc-p...@majordomo.ieee.org
Subject: RE: R&TTE Directive Member States Notification



Gerald, please explain why a Notified Body number is required? I thought
that a harmonized ETSI standard exists.

Richard Woods
Sensormatic Electronics
Tyco International



From: Gerald Tammi [mailto:gera...@zoom.com]
Sent: Tuesday, July 01, 2003 12:52 PM
To: 'Jan Heffken'; emc-p...@majordomo.ieee.org
Subject: RE: R&TTE Directive Member States Notification



I have gone through the process of a 802.11 WLAN.

France is not harmonized to the rest on the EU in the 2.4Ghz spread
spectrum.

Yes you will need a NOTIFIED BODY number to submit with the country
notifications

Yes you need to send notification to each country that you want to sell
into.

There is a 30 day waiting period for each country to reply before you can
sell into that market.  {they may respond sooner that the 30 days}  They may
reject especially if there is an external antenna.

If you are shipping out of the United States, and the product has an
embedded encryption engine; you need to file for an export license with the
US BXA.  Also you need to comply with control of export to the T7 terrorist
countries ban.

Gerald Tammi
Zoom Telephonics.
Boston, MA



From: Jan Heffken [mailto:jheff...@core.com]
Sent: Tuesday, July 01, 2003 10:04 AM
To: emc-p...@majordomo.ieee.org
Subject: R&TTE Directive Member States Notification



I am a little confused about paragraph 31 of the R&TTE Directive. I 
have copied it below. My understanding is that if our equipment (2.4GHz 
outdoor WLAN) operates in a non-harmonised frequency band, then we have 
to Notify Member States where it is not harmonised.

Where can I find answers to the following questions.

Is the 2,4GHz. spread spectum band harmonized through the EU?

Which Member States have not harmonized?

Do I have to go through a Notified Body to Notify?

Since paragraph 31 uses "should" and not "shall" do I have to do it all?

Paragraph 31 from the R&TTE Directive.
(31) Whereas manufacturers should notify Member States
of their intention to place radio equipment on the
market using frequency bands whose use is not
harmonised throughout the Community; whereas
Member States therefore need to put in place procedures
for such notification; whereas such procedures
should be proportionate and should not constitute a
conformity assessment procedure additional to those
provided for in Annexes IV or V; whereas it is desirable
that those notification procedures should be
harmonised and preferably implemented by electronic
means and one-stop-shopping;

Thanks in advance,

Jan Heffken
-- 
CoreComm Webmail. 
http://home.core.com



This message is from the IEEE EMC Society Product Safety
Technical Committee emc-pstc discussion list.

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Archive is being moved, we will announce when it is back on-line.
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Technical Committee emc-pstc discussion list.

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 Ron Pickard

Re: R&TTE Directive Member States Notification

[fdev...@assaabloyitg.com]

All,

Now, I have to chime in too.  Article 12 (1) of the Directive states,
"Where the procedures identified in Annex III, IV, or V are used, the
marking [CE] shall be accompanied by the identification number of the
notified body..."

The Directive Introduction (31) states, "...manufacturers should notify
Member States of their intention to place radio equipment on the market
using frequency bands whose use is not harmonised throughout the
Community;..."

Article 6 (4) states, "...radio equipment using frequency bands whose use
is not harmonised throughout the Community, the manufacturer or his
authorised representative established within the Community or the person
responsible for placing the equipment on the market shall notify the
national authority responsible in the relevant Member State for spectrum
management of the intention to place such equipment on its national
market."

There is no stated exception for testing to harmonized standards.  If a
particular frequency or frequency band is not harmonized, a Notified Body
must issue a Certificate of Conformity and each Member State must be
notified 4 weeks prior to placing the product on the market in each
country.  This is true even if only one Member State disallows a frequency.

Frank de Vall
Manager Compliance Engineering
Assa Abloy ITG



  

  stillin...@aol.com  

  Sent by:  To:  
gera...@zoom.com, richwo...@tycoint.com, 
  owner-emc-pstc@majordo
emc-p...@majordomo.ieee.org   
  mo.ieee.org   cc:   

            Subject:  Re: R&TTE
Directive Member States Notification   
  

  07/01/2003 04:02 PM 

  Please respond to   

  Stillingsl  

  

  





Gerald, Richard, All
   Ok, I have to chime in here. You do not need a Notified Body when
there is a Harmonized Standard published in the OJ. I understand that the
frequency is not harmonized (france because of their Military band), but
there is a harmonized standard and therefore no Notified Body is needed,
period. The point of the Notified body and number on the form is when there
is no harmonized standard and at this point I don't see how that could
happen with respect to Short Range Devices (SRDs) since the publication of
the three generic standards EN 300 220, EN 300 330 and EN 300 440 covers
basically 9 kHz to 40 GHz SRDs.

Europa's web site has more information on this at

http://europa.eu.int/comm/enterprise/rtte/infor.htm

Harmonised standards

The easiest route to demonstrate compliance with the Directive is to comply
with Harmonised Standards. For this Directive these are developed mostly by
ETSI. Some safety and health standards have been developed by CENELEC. The
3rd European Standardisation Organisation (CEN), doesn't cover this sector.
These standards are developed upon a request from the European Commission
and once adopted are published by the European Commission in the Official
Journal of the European Union (OJEU).

Notified bodies

When harmonised standards aren't available or when a manufacturer considers
them inappropriate for his product, he must seek the opinion of an
independent 3rd party, a notified body. These are appointed by the Member
States after having proven that they have the relevant expertise to provide
such an opinion. Although a Notified Body has various responsibilities
under the Directive, the manufacturer (or authorised representative) always
remains responsible for the compliance of the equipment.

Larry K. Stillings
Compliance Worldwide, Inc.
357 Main Street
Sandown, NH 03873
(603) 887 3903 Fax 887-6445
www.complianceworldwide.com

Privileged/Confidential Information may be contained in this message.  If
you are not the addressee indicated in this message (or responsible for
delivery of the message to such person), you may not copy or deliver this
message to anyone. In such case, you should destroy this message and kindly
notify the sender by 

Re: R&TTE Directive Member States Notification

[stillin...@aol.com]

Gerald, Richard, All
   Ok, I have to chime in here. You do not need a Notified Body when there 
is a Harmonized Standard published in the OJ. I understand that the frequency 
is not harmonized (france because of their Military band), but there is a 
harmonized standard and therefore no Notified Body is needed, period. The point 
of the Notified body and number on the form is when there is no harmonized 
standard and at this point I don't see how that could happen with respect to 
Short Range Devices (SRDs) since the publication of the three generic standards 
EN 300 220, EN 300 330 and EN 300 440 covers basically 9 kHz to 40 GHz SRDs. 

Europa's web site has more information on this at

http://europa.eu.int/comm/enterprise/rtte/infor.htm

Harmonised standards 

The easiest route to demonstrate compliance with the Directive is to comply 
with Harmonised Standards. For this Directive these are developed mostly by 
ETSI. Some safety and health standards have been developed by CENELEC. The 3rd 
European Standardisation Organisation (CEN), doesn’t cover this sector. These 
standards are developed upon a request from the European Commission and once 
adopted are published by the European Commission in the Official Journal of the 
European Union (OJEU).

Notified bodies 

When harmonised standards aren’t available or when a manufacturer considers 
them inappropriate for his product, he must seek the opinion of an independent 
3rd party, a notified body. These are appointed by the Member States after 
having proven that they have the relevant expertise to provide such an opinion. 
Although a Notified Body has various responsibilities under the Directive, the 
manufacturer (or authorised representative) always remains responsible for the 
compliance of the equipment.

Larry K. Stillings
Compliance Worldwide, Inc.
357 Main Street
Sandown, NH 03873
(603) 887 3903 Fax 887-6445
www.complianceworldwide.com

Privileged/Confidential Information may be contained in this message.  If
you are not the addressee indicated in this message (or responsible for
delivery of the message to such person), you may not copy or deliver this
message to anyone. In such case, you should destroy this message and kindly
notify the sender by reply email.  Please advise immediately if you or your
employer do not consent to Internet email for messages of this kind.
Opinions, conclusions and other information in this message that do not
relate to the official business of my firm shall be understood as neither
given nor endorsed by it.

RE: R&TTE Directive Member States Notification

[Gerald Tammi]

The 2.4 Ghz frequency spectrum is NOT harmonized. France is one of the
countries that has a restricted band allocation

It may not be true per the a directive, however if you download the required
individual notification forms by country; you will see that there is an
entry required for the notified body name and number. The general form in
the EU catalog says "if applicable.  the individual country forms are
similar but customized to that country.  Many of the forms are in the
language of the country only, with no English version.


From: richwo...@tycoint.com [mailto:richwo...@tycoint.com]
Sent: Tuesday, July 01, 2003 2:32 PM
To: emc-p...@majordomo.ieee.org
Subject: RE: R&TTE Directive Member States Notification



Gerald, please explain why a Notified Body number is required? I thought
that a harmonized ETSI standard exists.

Richard Woods
Sensormatic Electronics
Tyco International



From: Gerald Tammi [mailto:gera...@zoom.com]
Sent: Tuesday, July 01, 2003 12:52 PM
To: 'Jan Heffken'; emc-p...@majordomo.ieee.org
Subject: RE: R&TTE Directive Member States Notification



I have gone through the process of a 802.11 WLAN.

France is not harmonized to the rest on the EU in the 2.4Ghz spread
spectrum.

Yes you will need a NOTIFIED BODY number to submit with the country
notifications

Yes you need to send notification to each country that you want to sell
into.

There is a 30 day waiting period for each country to reply before you can
sell into that market.  {they may respond sooner that the 30 days}  They may
reject especially if there is an external antenna.

If you are shipping out of the United States, and the product has an
embedded encryption engine; you need to file for an export license with the
US BXA.  Also you need to comply with control of export to the T7 terrorist
countries ban.

Gerald Tammi
Zoom Telephonics.
Boston, MA



From: Jan Heffken [mailto:jheff...@core.com]
Sent: Tuesday, July 01, 2003 10:04 AM
To: emc-p...@majordomo.ieee.org
Subject: R&TTE Directive Member States Notification



I am a little confused about paragraph 31 of the R&TTE Directive. I 
have copied it below. My understanding is that if our equipment (2.4GHz 
outdoor WLAN) operates in a non-harmonised frequency band, then we have 
to Notify Member States where it is not harmonised.

Where can I find answers to the following questions.

Is the 2,4GHz. spread spectum band harmonized through the EU?

Which Member States have not harmonized?

Do I have to go through a Notified Body to Notify?

Since paragraph 31 uses "should" and not "shall" do I have to do it all?

Paragraph 31 from the R&TTE Directive.
(31) Whereas manufacturers should notify Member States
of their intention to place radio equipment on the
market using frequency bands whose use is not
harmonised throughout the Community; whereas
Member States therefore need to put in place procedures
for such notification; whereas such procedures
should be proportionate and should not constitute a
conformity assessment procedure additional to those
provided for in Annexes IV or V; whereas it is desirable
that those notification procedures should be
harmonised and preferably implemented by electronic
means and one-stop-shopping;

Thanks in advance,

Jan Heffken
-- 
CoreComm Webmail. 
http://home.core.com



This message is from the IEEE EMC Society Product Safety
Technical Committee emc-pstc discussion list.

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 Jim Bacher: j.bac...@ieee.org

Archive is being moved, we will announce when it is back on-line.
All emc-pstc postings are archived and searchable on the web at:
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This message is from the IEEE EMC Society Product Safety
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This message is from the IEEE EMC Society Product Safety
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Visit our web site at:  http://www.ewh.ieee.org/so

RE: R&TTE Directive Member States Notification

[richwo...@tycoint.com]

Gerald, please explain why a Notified Body number is required? I thought
that a harmonized ETSI standard exists.

Richard Woods
Sensormatic Electronics
Tyco International



From: Gerald Tammi [mailto:gera...@zoom.com]
Sent: Tuesday, July 01, 2003 12:52 PM
To: 'Jan Heffken'; emc-p...@majordomo.ieee.org
Subject: RE: R&TTE Directive Member States Notification



I have gone through the process of a 802.11 WLAN.

France is not harmonized to the rest on the EU in the 2.4Ghz spread
spectrum.

Yes you will need a NOTIFIED BODY number to submit with the country
notifications

Yes you need to send notification to each country that you want to sell
into.

There is a 30 day waiting period for each country to reply before you can
sell into that market.  {they may respond sooner that the 30 days}  They may
reject especially if there is an external antenna.

If you are shipping out of the United States, and the product has an
embedded encryption engine; you need to file for an export license with the
US BXA.  Also you need to comply with control of export to the T7 terrorist
countries ban.

Gerald Tammi
Zoom Telephonics.
Boston, MA



From: Jan Heffken [mailto:jheff...@core.com]
Sent: Tuesday, July 01, 2003 10:04 AM
To: emc-p...@majordomo.ieee.org
Subject: R&TTE Directive Member States Notification



I am a little confused about paragraph 31 of the R&TTE Directive. I 
have copied it below. My understanding is that if our equipment (2.4GHz 
outdoor WLAN) operates in a non-harmonised frequency band, then we have 
to Notify Member States where it is not harmonised.

Where can I find answers to the following questions.

Is the 2,4GHz. spread spectum band harmonized through the EU?

Which Member States have not harmonized?

Do I have to go through a Notified Body to Notify?

Since paragraph 31 uses "should" and not "shall" do I have to do it all?

Paragraph 31 from the R&TTE Directive.
(31) Whereas manufacturers should notify Member States
of their intention to place radio equipment on the
market using frequency bands whose use is not
harmonised throughout the Community; whereas
Member States therefore need to put in place procedures
for such notification; whereas such procedures
should be proportionate and should not constitute a
conformity assessment procedure additional to those
provided for in Annexes IV or V; whereas it is desirable
that those notification procedures should be
harmonised and preferably implemented by electronic
means and one-stop-shopping;

Thanks in advance,

Jan Heffken
-- 
CoreComm Webmail. 
http://home.core.com



This message is from the IEEE EMC Society Product Safety
Technical Committee emc-pstc discussion list.

Visit our web site at:  http://www.ewh.ieee.org/soc/emcs/pstc/

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 Jim Bacher: j.bac...@ieee.org

Archive is being moved, we will announce when it is back on-line.
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http://www.ieeecommunities.org/emc-pstc

RE: R&TTE Directive Member States Notification

[Gerald Tammi]

I have gone through the process of a 802.11 WLAN.

France is not harmonized to the rest on the EU in the 2.4Ghz spread
spectrum.

Yes you will need a NOTIFIED BODY number to submit with the country
notifications

Yes you need to send notification to each country that you want to sell
into.

There is a 30 day waiting period for each country to reply before you can
sell into that market.  {they may respond sooner that the 30 days}  They may
reject especially if there is an external antenna.

If you are shipping out of the United States, and the product has an
embedded encryption engine; you need to file for an export license with the
US BXA.  Also you need to comply with control of export to the T7 terrorist
countries ban.

Gerald Tammi
Zoom Telephonics.
Boston, MA



From: Jan Heffken [mailto:jheff...@core.com]
Sent: Tuesday, July 01, 2003 10:04 AM
To: emc-p...@majordomo.ieee.org
Subject: R&TTE Directive Member States Notification



I am a little confused about paragraph 31 of the R&TTE Directive. I 
have copied it below. My understanding is that if our equipment (2.4GHz 
outdoor WLAN) operates in a non-harmonised frequency band, then we have 
to Notify Member States where it is not harmonised.

Where can I find answers to the following questions.

Is the 2,4GHz. spread spectum band harmonized through the EU?

Which Member States have not harmonized?

Do I have to go through a Notified Body to Notify?

Since paragraph 31 uses "should" and not "shall" do I have to do it all?

Paragraph 31 from the R&TTE Directive.
(31) Whereas manufacturers should notify Member States
of their intention to place radio equipment on the
market using frequency bands whose use is not
harmonised throughout the Community; whereas
Member States therefore need to put in place procedures
for such notification; whereas such procedures
should be proportionate and should not constitute a
conformity assessment procedure additional to those
provided for in Annexes IV or V; whereas it is desirable
that those notification procedures should be
harmonised and preferably implemented by electronic
means and one-stop-shopping;

Thanks in advance,

Jan Heffken
-- 
CoreComm Webmail. 
http://home.core.com



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Re: R&TTE Directive Member States Notification

[John Woodgate]

I read in !emc-pstc that Jan Heffken  wrote (in
<200307011403.h61e3n69098...@mail4.mx.voyager.net>) about 'R&TTE
Directive Member States Notification' on Tue, 1 Jul 2003:

>Since paragraph 31 uses "should" and not "shall" do I have to do it all?

The text you cite is in the 'whereases' part, which is not about
requirements; it's an archaic form of rationale, still preserved by the
legal eagles.

The 'shoulds' refer to what the Commission *hopes* (but does not
mandate) member states will do; they do not refer to what manufacturers
have to do.

You will find what manufacturers have to do later in the Directive. I
don't have access to a copy at present so I can't say exactly where you
will find the information you want.
-- 
Regards, John Woodgate, OOO - Own Opinions Only. http://www.jmwa.demon.co.uk 
Interested in professional sound reinforcement and distribution? Then go to 
http://www.isce.org.uk
PLEASE do NOT copy news posts to me by E-MAIL!


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RE: R&TTE Directive Member States Notification

[Bill Stumpf]

Jan,
 You do not have to go through a notified body or U.S. CAB to notify.
Each Member State has its own form that can be downloaded for this
purpose, and yes , you do have to notify if the frequency is not
harmonized in that Member State. Go to www.ero.dk for frequency
allocation information.

William M Stumpf
DLS Electronics
166 South Carter St.
Genoa City WI 53128
ph: 262-279-0210
fx: 262-279-3630
email: bstu...@dlsemc.com
EMC & R&TTE CAB  


From: Jan Heffken [mailto:jheff...@core.com]
Sent: Tuesday, July 01, 2003 9:04 AM
To: emc-p...@majordomo.ieee.org
Subject: R&TTE Directive Member States Notification



I am a little confused about paragraph 31 of the R&TTE Directive. I 
have copied it below. My understanding is that if our equipment (2.4GHz 
outdoor WLAN) operates in a non-harmonised frequency band, then we have 
to Notify Member States where it is not harmonised.

Where can I find answers to the following questions.

Is the 2,4GHz. spread spectum band harmonized through the EU?

Which Member States have not harmonized?

Do I have to go through a Notified Body to Notify?

Since paragraph 31 uses "should" and not "shall" do I have to do it all?

Paragraph 31 from the R&TTE Directive.
(31) Whereas manufacturers should notify Member States
of their intention to place radio equipment on the
market using frequency bands whose use is not
harmonised throughout the Community; whereas
Member States therefore need to put in place procedures
for such notification; whereas such procedures
should be proportionate and should not constitute a
conformity assessment procedure additional to those
provided for in Annexes IV or V; whereas it is desirable
that those notification procedures should be
harmonised and preferably implemented by electronic
means and one-stop-shopping;

Thanks in advance,

Jan Heffken
-- 
CoreComm Webmail. 
http://home.core.com



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RE: R&TTE Directive

[Bill Ellingford]

Hi Group, John etc.
The R&TTE has provision Network Access "essential requirements" (for wired
products) to be added if the commission find a need.  Currently, there are
no requirements except for those added to cover France Telecom.  Parts of
the French POTs network use old technology where certain transformers
(possibly A type relays) become saturated and thus will not pass any audio
if the line current drawn exceeds 60mA.
 
For an interim period, the commission have included the Line feeding tests
(60mA current limit) from TBR21 as an applicable, essential requirement for
France.  There is a withdrawal date for this requirement so it to will soon
vanish.
 
I agree with John, many sales chains are unhappy taking product with no
network access test results, we therefore choose to voluntarily apply the
TBR standards as a means of demonstrating compliance with the former,
applied essential requirements to show to any interested parties.  This
testing can of course be of further benefit, as many reports can be used in
other countries to support an overseas approval application.  This is
particulalry true of more modern technologies like ISDN BRI and PRI, ONP
etc.  A good example of this is TBR3 which is widely accepted as the Euro /
CEPT ISDN test standard.  Investigate the standards you apply as part of any
"One stop" multi-country approvals strategy.
 
I also agree that other, design standards may be applied.  The directive
calls for all PTOs to provide a list of interface specifications for the
ports available on their networks.  Many PTOs are quoting earlier national
specification for this purpose (I see some BS specs on the BT site) and many
refer to the NETs and TBRs from previous years.
 
Do not forget that Wireless interfaces do still have connection requirements
under the directive, where possible these are harmonised (ETSI) but due to
deviation in frequency allocations and terrain, many remain based on
National standards.
 
This is only a brief answer, obviously there is a lot more content in the
actual body of the directive.  This should be essential (but not bed time)
reading for this subject!
the 99/5/EC directive can be downloaded from our favourite EUROPA server.
 
Hope this helps.  Best regards
 
Bill Ellingford 
 
Approvals & Conformance manager
Motion Media Technology Ltd

-Original Message-
From: j...@aol.com [mailto:j...@aol.com]
Sent: 08 May 2002 17:06
To: jjuh...@fiberoptions.com
Cc: emc-p...@majordomo.ieee.org
Subject: Re: R&TTE Directive


In a message dated 5/8/2002, John Juhasz writes:




it appears that it is not required to test the interface itself to
'telecom specs' such as those in the CTR21. 





Hi John:

Your interpretation is correct.  For wireline POTS products/interfaces, the
only requirements that apply under the RTTE directive are safety and EMC.
There are no regulatory requirements whatsoever for the type of
specifications called out in CTR 21.  CTR 21 ceased to be a regulatory
requirement when the RTTE directive came into force on April 8, 2000.

That being said, many manufacturers are uncomfortable with having no
regulatory requirements for telecom.  One option is to continue voluntary
testing to CTR 21.  Another option is to obtain the individual "reference"
standards that the RTTE directive requires each operator of a public network
to publish.  Most of the major operators have posted these on their web
sites.  

A third option is to review CTR 21 and the relevant "reference"
specifications, then use engineering judgment to design and test your
interface.  This is the preferred approach if you are seeking minimum cost
and/or maximum compatibility with the various national networks.

The bottom line is that the telecom aspects of your product performance are
now a matter between you and your customer, rather than between you and the
regulators.


Joe Randolph
Telecom Design Consultant
Randolph Telecom, Inc.
781-721-2848
http://www.randolph-telecom.com 



*

Re: R&TTE Directive

[Theo Hildering]

Hi John,

You are right. The only requirements are for EMC and Safety (according to
the R&TTE directive).

I remember  there was only 1 (temporary) exception, important if the POTS
equipment will be used in France. (drawn current < 80 mA)
Probably this requirement is gone now, but be careful.

Success!

Theo Hildering


Hildering Telecom Consulting

The Netherlands



On 08-05-2002 16:46, "John Juhasz"  wrote:

> 
> Having been out of the telecom arena for a few years, I am seeking some
> clarification on
> the R&TTE Directive as it relates to a single-line, simple, analog POTS
> unit.
> With regard to specific testing of the telephone interface, the way I am
> reading the
> directive and associated guidance documents on Europa.EU
> http://europa.eu.int/comm/enterprise/rtte/gener.htm
> it appears that it is not required to test the interface itself to
> 'telecom specs' such as those in the CTR21.
> Testing to those specs is recommended only to ensure that the
> product works properly when connected to the PSTN and it doesn't
> harm the network.
> 
> Am I misunderstanding this?
> 
> GE Interlogix
> 
> John A. Juhasz
> Product Qualification &
> Compliance Engr.
> 
> Fiber Options Div.
> 80 Orville Dr. Suite 102, Bohemia, NY 11716
> 631-419-2324, Fax: 631-567-8322
> 
> 
> 
> 
> ---
> This message is from the IEEE EMC Society Product Safety
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Re: R&TTE Directive

[JRadomski]

John,

A few years ago, the European Commission has determined that there is no
need for technical requirements against which to assess wired
telecommunication products. Further work on the technical basis for
regulation (TBRs) has been suspended and many CTRs (CTR 21 included) have
been removed from the list of harmonized standards under the R&TTE
Directive. The only requirements deemed essential for wired
telecommunication apparatus are the safety and EMC requirements.

John Radomski
Clare Inc.





  John Juhasz   

   
  com>  cc: 

  Sent by:  Subject:  R&TTE Directive   

  owner-emc-pstc@majordo

  mo.ieee.org   





  05/08/02 10:46 AM 

  Please respond to John

  Juhasz










Having been out of the telecom arena for a few years, I am seeking some
clarification on
the R&TTE Directive as it relates to a single-line, simple, analog POTS
unit.
With regard to specific testing of the telephone interface, the way I am
reading the
directive and associated guidance documents on Europa.EU
 http://europa.eu.int/comm/enterprise/rtte/gener.htm
it appears that it is not required to test the interface itself to
'telecom specs' such as those in the CTR21.
Testing to those specs is recommended only to ensure that the
product works properly when connected to the PSTN and it doesn't
harm the network.

Am I misunderstanding this?

GE Interlogix

John A. Juhasz
Product Qualification &
Compliance Engr.

Fiber Options Div.
80 Orville Dr. Suite 102, Bohemia, NY 11716
631-419-2324, Fax: 631-567-8322




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Re: R&TTE Directive

[JPR3]

In a message dated 5/8/2002, John Juhasz writes:


> it appears that it is not required to test the interface itself to
> 'telecom specs' such as those in the CTR21. 
> 


Hi John:

Your interpretation is correct.  For wireline POTS products/interfaces, the 
only requirements that apply under the RTTE directive are safety and EMC.  
There are no regulatory requirements whatsoever for the type of 
specifications called out in CTR 21.  CTR 21 ceased to be a regulatory 
requirement when the RTTE directive came into force on April 8, 2000.

That being said, many manufacturers are uncomfortable with having no 
regulatory requirements for telecom.  One option is to continue voluntary 
testing to CTR 21.  Another option is to obtain the individual "reference" 
standards that the RTTE directive requires each operator of a public network 
to publish.  Most of the major operators have posted these on their web 
sites.  

A third option is to review CTR 21 and the relevant "reference" 
specifications, then use engineering judgment to design and test your 
interface.  This is the preferred approach if you are seeking minimum cost 
and/or maximum compatibility with the various national networks.

The bottom line is that the telecom aspects of your product performance are 
now a matter between you and your customer, rather than between you and the 
regulators.


Joe Randolph
Telecom Design Consultant
Randolph Telecom, Inc.
781-721-2848
http://www.randolph-telecom.com

RE: R&TTE directive list of harmonized stds.

[WOODS]

Allen, the 61000 series are "basic" standards and those type are not
published in the OJ; however, they are referenced in the harmonized
standards that are published.

Richard Woods

--
From:  Allan, James [SMTP:james_al...@milgo.com]
Sent:  Friday, March 02, 2001 9:44 AM
To:  'emc-pstc'
Subject:  R&TTE directive list of harmonized stds.


Group:  Help me here. I know I must be overlooking something.
The R&TTE Directive 1999/5/EEC refers me to the EMC Directive 89/336/EEC.
When I search the list of harmonized standards under 89/336/EEC I do not
find any reference to either
EN 61000-4-X or EN 60555-4-X
What am I missing and how does the EMC directive or any other  directive
relevant to R&TTE point me to EMC immunity?
The products in question are wire connected telecom terminals.

Jim Allan
Manager, Engineering Services
Milgo Solutions LLC
1619 N Harrison Parkway
Sunrise, FL, 33323
E-mail james_al...@milgo.com
Phone (954) 846-3720
Fax (954) 846-5693


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RE: R&TTE Directive Article 6.4 Notification Contact for Greece

[Andrea Bishop]

I received the following reply from the Greek Ministry when I asked the
question.


National authority responsible for spectrum management:
- Mr.  Nissim Benmayor  (head of the section)
(+30 1)  650 85 71
ymera...@hol.gr
(+30 1)  650 85 70   fax

***Mss.  Irini Athanasiou (+30 1)  650 85 54
yme...@hol.gr
(+30 1)  650 85 60   fax

regards

Andrea Bishop
Compliance Manager
BABT Product Service Ltd




-Original Message-
From: Kevin Harris [mailto:harr...@dscltd.com]
Sent: 16 January 2001 22:39
To: EMC-PSTC (E-mail)
Subject: R&TTE Directive Article 6.4 Notification Contact for Greece



Dear Colleagues,

Has anyone has any success finding a contact to give notice to under Art 6.4
for Greece?

Thanks 


Best Regards,


Kevin Harris
Manager, Approval Services
Digital Security Controls
3301 Langstaff Road
Concord, Ontario
CANADA
L4K 4L2

Tel: +1 905 760 3000 Ext. 2378
Fax +1 905 760 3020

Email: harr...@dscltd.com  

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RE: R&TTE Directive Notification Period

[Kevin Harris]

Hello All,
 
I see by the replies that I didn't state my problem clearly. I don't mean to
imply that the devices are variants of each other they are not. They are
separate devices each of which has been tested to the full extent required.
The proposition is purely this. Since I notified the PTTs before about
products with the same application and RF characteristics previously and I
had no objections from the PTTs and that furthermore the only way PTTs can
ban a device is to object on the basis of "network harm" then they cannot
ban my new products and I need not wait the four weeks.  
 
Comments anyone? 
 
Rest Regards
 
Kevin Harris
 

-Original Message-
From: CE-test - Ing. Gert Gremmen - ce-marking and more...
[mailto:cet...@cetest.nl]
Sent: Thursday, January 11, 2001 5:08 PM
To: Wismer, Sam; Kevin Harris; EMC-PSTC (E-mail)
Subject: RE: R&TTE Directive Notification Period


As always, people are pragmatic, and technical reasons, how valid they may
be, cannot prevail
over legal ones. Any compliance matter will (-in case of dispute-) finally
be judged by 
a legal specialist, not a technical-, and if in the end you manage to
convince a lawyer
that A equals B, he will ask you why calling it A anyway.
 
Furthermore , many technical properties of radio devices nowadays depend
heavily of software, such as the modulation scheme. If your previous uP
served
well to extremes of the test range, does the newer one ??
Your reasoning Richard, and Kevin would do well for submitting your device
to
a test house, as a motivation for no in-hour pre-compliance testing, but not
for safeguarding your boss or customers against legal charges. Sorry...
 
 
Regards,
 
Gert Gremmen, (Ing)
Ce-test, qualified testing
 
==
Web presence  http://www.cetest.nl <http://www.cetest.nl/> 
CE-shop http://www.cetest.nl/ce_shop.htm <http://www.cetest.nl/ce_shop.htm> 
/-/ Compliance testing is our core business /-/
==

-Original Message-
From: owner-emc-p...@ieee.org [mailto:owner-emc-p...@ieee.org]On Behalf Of
Wismer, Sam
Sent: Thursday, January 11, 2001 7:42 PM
To: Kevin Harris; EMC-PSTC (E-mail)
Subject: RE: R&TTE Directive Notification Period



Hi Kevin, 

Unless you give it the same model number etc., there will always be what
appears to someone who tries to check on it, an un-notified(is that a word?)
product on the market.  I suppose you could have notified a family of
products if you had visibility of them prior to the initial notification.  

It's a bit like adding a new antenna to a spread spectrum device here in the
US.  If the antenna is of the same type and equal or lesser gain than one
that has already been approved by the FCC, then you don't have to test it.
However, you do have to identify it.  This means you have to file a class 2
permissive change to add the antenna to the file and wait the 12 week cycle
time or so until it gets granted.

For your question though, if the label cannot identify it as something that
has been notified, then you should re-notify.  Just be glad you only have to
wait 4 weeks and not 12.

My 2 cents... 



~ 
Sam Wismer 
Lead Regulatory Engineer/ 
Radio Approvals Engineer 
LXE, Inc. 
(770) 447-4224 Ext. 3654 

Visit Our Website at: 
http://www.lxe.com <http://www.lxe.com>  



-Original Message- 
From: Kevin Harris [ mailto:harr...@dscltd.com <mailto:harr...@dscltd.com> ]

Sent: Thursday, January 11, 2001 10:35 AM 
To: EMC-PSTC (E-mail) 
Subject: R&TTE Directive Notification Period 



Hello Sages, 

I am trying to assess what could possibly happen under the following 
scenario for the notification period. Lets say I had some SRD devices that 
have gone through the notification period without comment. At some later 
point I decide to introduce further devices in the line. The radios are not 
identical schematically but all the RF characteristics are identical, 
including "percentage on" time. The new devices are all type tested, EMC and

safety tested in exactly the same manner as the devices previously notified 
and will be used in the same application. My proposal at that point would be

to not wait for 4 weeks to expire on notification but to market the devices 
immediately. My reasoning for this is that a country can only object to a 
device being marketed on "harm to the network" and then follow the procedure

in Article 9.5 for banning the device. Since they did not happen previously,

they cannot object now. I know that attitude might put some regulatory noses

out of joint but does anyone see a problem with the argument. 


Best Regards, 


Kevin Harris 
Manager, Approval Services 
Digital Security Controls 
3301 Langstaff Road 
Concord, Ontario 
CANADA 
L4K 4L2 

Tel: +1 905 760 3000 Ext. 2378 
Fax +1 905 760 3020 

Email: harr...@dscltd.com < mailto:harr...@dscltd.com
<mailto:harr...@ds

RE: R&TTE Directive Notification Period

[CE-test - Ing. Gert Gremmen - ce-marking and more...]

RE: R&TTE Directive Notification PeriodAs always, people are pragmatic, and
technical reasons, how valid they may be, cannot prevail
over legal ones. Any compliance matter will (-in case of dispute-) finally
be judged by
a legal specialist, not a technical-, and if in the end you manage to
convince a lawyer
that A equals B, he will ask you why calling it A anyway.

Furthermore , many technical properties of radio devices nowadays depend
heavily of software, such as the modulation scheme. If your previous uP
served
well to extremes of the test range, does the newer one ??
Your reasoning Richard, and Kevin would do well for submitting your device
to
a test house, as a motivation for no in-hour pre-compliance testing, but not
for safeguarding your boss or customers against legal charges. Sorry...


Regards,

Gert Gremmen, (Ing)
Ce-test, qualified testing

==
Web presence  http://www.cetest.nl
CE-shop http://www.cetest.nl/ce_shop.htm
/-/ Compliance testing is our core business /-/
==
  -Original Message-
  From: owner-emc-p...@ieee.org [mailto:owner-emc-p...@ieee.org]On Behalf Of
Wismer, Sam
  Sent: Thursday, January 11, 2001 7:42 PM
  To: Kevin Harris; EMC-PSTC (E-mail)
  Subject: RE: R&TTE Directive Notification Period


  Hi Kevin,

  Unless you give it the same model number etc., there will always be what
appears to someone who tries to check on it, an un-notified(is that a word?)
product on the market.  I suppose you could have notified a family of
products if you had visibility of them prior to the initial notification.

  It's a bit like adding a new antenna to a spread spectrum device here in
the US.  If the antenna is of the same type and equal or lesser gain than
one that has already been approved by the FCC, then you don't have to test
it.  However, you do have to identify it.  This means you have to file a
class 2 permissive change to add the antenna to the file and wait the 12
week cycle time or so until it gets granted.

  For your question though, if the label cannot identify it as something
that has been notified, then you should re-notify.  Just be glad you only
have to wait 4 weeks and not 12.

  My 2 cents...




  ~
  Sam Wismer
  Lead Regulatory Engineer/
  Radio Approvals Engineer
  LXE, Inc.
  (770) 447-4224 Ext. 3654

  Visit Our Website at:
  http://www.lxe.com




  -Original Message-
  From: Kevin Harris [mailto:harr...@dscltd.com]
  Sent: Thursday, January 11, 2001 10:35 AM
  To: EMC-PSTC (E-mail)
  Subject: R&TTE Directive Notification Period




  Hello Sages,

  I am trying to assess what could possibly happen under the following
  scenario for the notification period. Lets say I had some SRD devices that
  have gone through the notification period without comment. At some later
  point I decide to introduce further devices in the line. The radios are
not
  identical schematically but all the RF characteristics are identical,
  including "percentage on" time. The new devices are all type tested, EMC
and
  safety tested in exactly the same manner as the devices previously
notified
  and will be used in the same application. My proposal at that point would
be
  to not wait for 4 weeks to expire on notification but to market the
devices
  immediately. My reasoning for this is that a country can only object to a
  device being marketed on "harm to the network" and then follow the
procedure
  in Article 9.5 for banning the device. Since they did not happen
previously,
  they cannot object now. I know that attitude might put some regulatory
noses
  out of joint but does anyone see a problem with the argument.



  Best Regards,



  Kevin Harris
  Manager, Approval Services
  Digital Security Controls
  3301 Langstaff Road
  Concord, Ontario
  CANADA
  L4K 4L2

  Tel: +1 905 760 3000 Ext. 2378
  Fax +1 905 760 3020

  Email: harr...@dscltd.com <mailto:harr...@dscltd.com>

  ---
  This message is from the IEEE EMC Society Product Safety
  Technical Committee emc-pstc discussion list.

  To cancel your subscription, send mail to:
   majord...@ieee.org
  with the single line:
   unsubscribe emc-pstc

  For help, send mail to the list administrators:
   Jim Bacher:  jim_bac...@mail.monarch.com
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  For policy questions, send mail to:
   Richard Nute:   ri...@ieee.org

<>

RE: R&TTE Directive Notification Period

[Wismer, Sam]

Hi Kevin,

Unless you give it the same model number etc., there will always be what
appears to someone who tries to check on it, an un-notified(is that a word?)
product on the market.  I suppose you could have notified a family of
products if you had visibility of them prior to the initial notification.  

It's a bit like adding a new antenna to a spread spectrum device here in the
US.  If the antenna is of the same type and equal or lesser gain than one
that has already been approved by the FCC, then you don't have to test it.
However, you do have to identify it.  This means you have to file a class 2
permissive change to add the antenna to the file and wait the 12 week cycle
time or so until it gets granted.

For your question though, if the label cannot identify it as something that
has been notified, then you should re-notify.  Just be glad you only have to
wait 4 weeks and not 12.

My 2 cents...



~
Sam Wismer
Lead Regulatory Engineer/
Radio Approvals Engineer
LXE, Inc.
(770) 447-4224 Ext. 3654

Visit Our Website at:
http://www.lxe.com



-Original Message-
From: Kevin Harris [mailto:harr...@dscltd.com]
Sent: Thursday, January 11, 2001 10:35 AM
To: EMC-PSTC (E-mail)
Subject: R&TTE Directive Notification Period



Hello Sages,

I am trying to assess what could possibly happen under the following
scenario for the notification period. Lets say I had some SRD devices that
have gone through the notification period without comment. At some later
point I decide to introduce further devices in the line. The radios are not
identical schematically but all the RF characteristics are identical,
including "percentage on" time. The new devices are all type tested, EMC and
safety tested in exactly the same manner as the devices previously notified
and will be used in the same application. My proposal at that point would be
to not wait for 4 weeks to expire on notification but to market the devices
immediately. My reasoning for this is that a country can only object to a
device being marketed on "harm to the network" and then follow the procedure
in Article 9.5 for banning the device. Since they did not happen previously,
they cannot object now. I know that attitude might put some regulatory noses
out of joint but does anyone see a problem with the argument.


Best Regards,


Kevin Harris
Manager, Approval Services
Digital Security Controls
3301 Langstaff Road
Concord, Ontario
CANADA
L4K 4L2

Tel: +1 905 760 3000 Ext. 2378
Fax +1 905 760 3020

Email: harr...@dscltd.com  

---
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Technical Committee emc-pstc discussion list.

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 majord...@ieee.org
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 unsubscribe emc-pstc

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 Richard Nute:   ri...@ieee.org

RE: R&TTE Directive Notification Period

[WOODS]

I agree. We use the same  "regulatory ID" number on a product which include
variants not affecting the rf properties.  We see no reason to apply to the
Notified Body for an opinion of compliance nor to notify the PTTs when a new
variant is marketed where the rf properties have not changed. That new
variant will have the same ID number that was previously notified to the
PTTs, 

Richard Woods

--
From:  Kevin Harris [SMTP:harr...@dscltd.com]
Sent:  Thursday, January 11, 2001 10:35 AM
To:  EMC-PSTC (E-mail)
Subject:  R&TTE Directive Notification Period


Hello Sages,

I am trying to assess what could possibly happen under the following
scenario for the notification period. Lets say I had some SRD devices that
have gone through the notification period without comment. At some later
point I decide to introduce further devices in the line. The radios are not
identical schematically but all the RF characteristics are identical,
including "percentage on" time. The new devices are all type tested, EMC and
safety tested in exactly the same manner as the devices previously notified
and will be used in the same application. My proposal at that point would be
to not wait for 4 weeks to expire on notification but to market the devices
immediately. My reasoning for this is that a country can only object to a
device being marketed on "harm to the network" and then follow the procedure
in Article 9.5 for banning the device. Since they did not happen previously,
they cannot object now. I know that attitude might put some regulatory noses
out of joint but does anyone see a problem with the argument.


Best Regards,


Kevin Harris
Manager, Approval Services
Digital Security Controls
3301 Langstaff Road
Concord, Ontario
CANADA
L4K 4L2

Tel: +1 905 760 3000 Ext. 2378
Fax +1 905 760 3020

Email: harr...@dscltd.com  

---
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RE: R&TTE Directive DoC Requirements

[Andrea Bishop]

You can access most of the TCAM documents through the UK's DTI Technical
Advice and Policy Committee (TAPC) R&TTE website:

http://www.tapc.org.uk/RTTE/Index.html

Regards

Andrea Bishop
BABT Product Service


-Original Message-
From: Kevin Harris [mailto:harr...@dscltd.com]
Sent: 30 November 2000 23:36
To: EMC-PSTC (E-mail)
Subject: R&TTE Directive DoC Requirements



Hello Group,
OK I'm confused. Some of you who get Conformity update may remember that at
the beginning of the month there was an article on the R&TTE directive
having to do with DoC requirements. In part it .referred to a TCAM document
6 (30)0 in which a proposed compromise solution was suggested If you didn't
include a formal DoC with each product you could have a simple statement in
the manual in all 11 languages of the community and give a pointer to a web
site for the formal DoC.
However I just ran across some minutes from TCAM 6 which state 
NOTES ON TCAM 6, 25-26 September 2000
6.3 DoC in Manuals: Industry expressed concerns about the compromise
reached. It was not usual to put all 11 Community languages in all versions
of user manuals. Languages were "clustered" in meaningful groups to suit
commercial distribution arrangements. It was agreed that only relevant
languages need be included and that the obligation to supply declarations to
users should be revisited in the coming review of the Directive.
There seems to be a bit of a discrepancy here. Are either of these documents
to be taken at their word? If I invoked either of them do I run any risks of
not meeting the requirements of the directive? Any TCAM folks out there care
to comment?

By the way (since some of us are airing grievances or pet peeves these days)
Why is the TCAM site closed except to those who member states deem worthy.
Sharing the information with all surely can't hurt. As it stands it
certainly gives manufactures within the member states a huge jump on what's
happening. 


Best Regards,


Kevin Harris
Manager, Approval Services
Digital Security Controls
3301 Langstaff Road
Concord, Ontario
CANADA
L4K 4L2

Tel: +1 905 760 3000 Ext. 2378
Fax +1 905 760 3020

Email: harr...@dscltd.com  

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RE: R&TTE directive

[WOODS]

I don't recall reading anything in the directive that indicates the DoC must
be in multiple languages. If you know otherwise, please specify the section
number.

Richard Woods

--
From:  jim_bac...@mail.monarch.com
[SMTP:jim_bac...@mail.monarch.com]
Sent:  Tuesday, May 23, 2000 8:04 AM
To:  k...@i-data.com; emc-p...@majordomo.ieee.org
Subject:  Fwd:R&TTE directive


forwarded for Kim.

Reply Separator
Subject:R&TTE directive
Author: k...@i-data.com
Date:   5/23/00 12:12 PM

Dear all

According to the new R&TTE directive we will have to supply our
Declaration
of Conformity in  all EU languages.

Is R&TTE accepted as a reference in all languages or do I need to
translate
it ?

If I need to translate do anyone know an easy way to do this ?

Best regards,

Kim Boll Jensen
i-data international
Denmark

P.S. The danish translation is: Rådets direktiv om Radio og
Teleterminaludstyr 1999/5/EF



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Re: R&TTE Directive EMF Limits

[Ralph Cameron]

Richard:

The Canadian version of your FCC limts is called Safety Code 6 and has
recetnly been revised by  Health Canada. it doesn't permit computer
simulations but of course in the lab you can do anything.

Ralph Cameron
Consultant in EMC and Suppression of Consumer Electronic Euipment
(After sale)

- Original Message -
From: 
To: 
Sent: Wednesday, December 15, 1999 5:46 AM
Subject: R&TTE Directive EMF Limits


>
> The R&TTE Directive includes an essential requirement for "health and
> safety" which is interpreted by the Commission as human exposure to EMF.
I
> would like to hear from anyone that has equipment operating at less than
100
> kHz and plans on demonstrating compliance to the basic limits. This is
what
> my company plans to do using computer simulation.
>
> Richard Woods
>
> -
> This message is coming from the emc-pstc discussion list.
> To cancel your subscription, send mail to majord...@ieee.org
> 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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Re: VIRUS WARNING RE: R&TTE Directive - Transitional periods

[Martin Rowe (TMW)]

I was able to recover everything because I have Norton
Utilities. Norton protected the "deleted" files that the virus
attacked.

Thanks to Scott Lacey for pointing this out.

/\
| Martin Rowe  |   /  \
| Senior Technical Editor  |  /\  /\
| Test & Measurement World | /  \/  \/\  
| voice 617-558-4426   |/\  /\  /  \/
| fax 617-558-4470 |  \/  \/
| e-mail m.r...@ieee.org   |   \  /
| http://www.tmworld.com   |\/



--
> From: Scott Douglas 
> To: john.al...@rdel.co.uk; emc-p...@majordomo.ieee.org
> Subject: RE: VIRUS WARNING RE: R&TTE Directive - Transitional
periods 
> Date: Wednesday, December 01, 1999 09:46 AM
> 
> 
> I received three emails that looked like replies to message
trails on
> emc-pstc. Each had an attachment called "zipped_files.exe".
Inoculan
> detected the virus Worm.ExploreZip.Neolite in the attached
files. The emails
> and attached files were summarily deleted and my entire system
checked. No
> more viruses found. These three emails had subjects of recent
emc-pstc
> threads, but none of these came to me through the emc-pstc
server.
> 
> The message source address was "jcoll...@cienna.com"
> 
> Since I did try to open one of these attachments, and even
though Inoculan
> spotted it, and since I use Outlook, it may be that some of
you will get
> emails from me with the attachment. DO NOT OPEN ANY ATTACHMENT
WITH NAME OF
> "zipped_files.exe", Delete the message instead.
> 
> Scott
> s_doug...@ecrm.com
> ECRM Incorporated
> Tewksbury, MA  USA
> 
> 
> -Original Message-
> From: john.al...@rdel.co.uk [mailto:john.al...@rdel.co.uk]
> Sent: Wednesday, December 01, 1999 6:37 AM
> To: emc-p...@majordomo.ieee.org
> Subject: VIRUS WARNING RE: R&TTE Directive - Transitional
periods
> Importance: Low
> 
> 
> 
> Hi Folks
> 
> This is just to warn you that an automatic reply to my posting
last night
> on the above subject resulting in me - and possibly others -
being sent a
> new virus!
> 
> The message source address was 'david.cl...@spke.com'
> 
> Do not open any self-extracting ZIP messages attached to
emails from this
> address!!
> 
> Luckily it was caught by our corporate firewall, but I then
received the
> following message from the people administering the firewall.
Their
> message
> is given below for your information.
> 
> Regards
> 
> John Allen
> 
>
-
---
> ---
> 
> Hi, John.
> 
> The mail sent to you has been confirmed as a virus by Sophos. 
It's known
> as
> "explorezip-b"  By the looks of it, the infection results are
similar to
> many others - you run what looks like a self-unzipping file,
and the pc is
> infected, sending the virus to many others - via the local
address book,
> and
> in response to each received mail thereafter.
> 
> Steve
> 
> Steve Lewis
> IT Executive
> Racal Defence Electronics
> Crawley
> West Sussex
> UK
> 
> -
> This message is coming from the emc-pstc discussion list.
> To cancel your subscription, send mail to majord...@ieee.org
> 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).
> 
> 
> 
> 
> 
> -
> This message is coming from the emc-pstc discussion list.
> To cancel your subscription, send mail to majord...@ieee.org
> with the single line: "unsubscribe emc-pstc" (without the
> quotes).  For help, send mail to ed.pr...@cubic.com,
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-
This message is coming from the emc-pstc discussion list.
To cancel your subscription, send mail to majord...@ieee.org
with the single line: "unsubscribe emc-pstc" (without the
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roger.volgst...@compaq.com (the list administrators).

RE: R&TTE Directive - Transitional periods

[WOBrien]

Unfortunately, the program is not yet posted on the ITS webpage.  If you
would like more info, contact me via email or phone, please.

Bill O'Brien
ITS Boxboro, MA
978-635-8553
wobr...@itsqs.com

-Original Message-
From: Finlayson, Joe [mailto:jfinlay...@nbase-xyplex.com]
Sent: Wednesday, December 01, 1999 12:37 PM
To: 'wobr...@itsqs.com'; roger.vi...@wwgsolutions.com;
john.al...@rdel.co.uk
Cc: emc-p...@majordomo.ieee.org
Subject: RE: R&TTE Directive - Transitional periods


Bill,

I saw nothing on your web page.  I, and many others, may be
interested if the agenda was made available.

Thx,


Joe

*
Joe Finlayson   
Compliance Engineering Manager
NBase-Xyplex
295 Foster Street
Littleton, MA 01460
Tel:+1 (978) 952-5887
Fax:+1 (978) 952-5054
Email:  jfinlay...@nbase-xyplex.com



-Original Message-
From: wobr...@itsqs.com [mailto:wobr...@itsqs.com]
Sent: Wednesday, December 01, 1999 8:15 AM
To: roger.vi...@wwgsolutions.com; john.al...@rdel.co.uk
Cc: emc-p...@majordomo.ieee.org
Subject: RE: R&TTE Directive - Transitional periods



Based on the emails of the past couple of days, this seems like a genuine
public service - 

For anyone's interest - Intertek Testing Services and NMi (Netherlands
Measurement Institute) are holding a seminar on the new RTTE Directive in
Boxboro, MA on 12/14/99.  The program may clear up some confusion that
exists among practitioners.  If you would like more information, contact me
at the numbers below.

Bill O'Brien
ITS
Boxboro, MA
978-635-8553
wobr...@itsqs.com

-Original Message-
From: roger.vi...@wwgsolutions.com [mailto:roger.vi...@wwgsolutions.com]
Sent: Wednesday, December 01, 1999 6:36 AM
To: John Allen
Cc: emc-p...@majordomo.ieee.org
Subject: Re: R&TTE Directive - Transitional periods





John,
Thanks for the info and the pointer to TAPC which I also find a valuable
source
of such info.
Your summary adds detailed support to the information I was given at a BABT
seminar on Oct 5 (emc-pstc posting 15 Oct), but which was disputed in this
forum. Are the UK out on their own in disallowing new approvals to the old
regime during this transition period?

Roger




John Allen  on 30/11/99 18:27:24

Please respond to John Allen 

To:   "emc-p...@majordomo.ieee.org" 
cc:   "Graham Paddy(Director" , "Robinson
  Colin(Technical directcolin.robin...@rdel.co.uk"
  , "Smith Martin(PBD"
,
  "John Warren(QA" , "'BSI: White Ken'"
  , "Spicer Keith(QA" 
(bcc:
  Roger Viles/PLY/Global)

Subject:  R&TTE Directive - Transitional periods





Hi folks

I have just been sent a copy of the draft UK Statutory Instrument on the
above, together with a copy of the DTI consultative document - these appear
to clarify the previously much-debated subject of the proposed transition
periods and I thought various people might like to know.

These documents are available at the following website:  "www.tapc.org.uk"
in both  Word97 & pdf format.

The consultative document goes into some detail on the subject of
transition periods, and the critical statements are given in the following
sections:

"Summary of proposals
4 The existing UK and European type approval regimes for radio equipment
and telecommunications terminal equipment will end on 7 April 2000.

Manufacturers can place equipment on the market which conforms to the new
regime from 8 April 2000. Notwithstanding this, equipment approved before
this date may continue to be placed on the market until 7 April 2001.

Thereafter all individual items of equipment placed on the market must
conform to the requirements of the new regime."

AND

"Transitional provisions (draft regulation 8)
18 This regulation allows that, despite the ending of UK and European type
approvals regimes for radio equipment and telecommunications terminal
equipment on 7 April 2000, individual items of apparatus approved under
these regimes can continue to be placed on the market without change until
7 April 2001. Such apparatus first placed on the market by 7 April 2001 can
remain on the market until sold, and can subsequently be appropriately
installed and
used.

During the transitional period of 8 April 2000 to 7 April 2001, notified
bodies appointed under Directive 98/13/EC can continue to act in support of
approvals given before that period, for example by continuing arrangements
for production control, but cannot grant further approvals.

>From 8 April 2001, all items of apparatus placed on the market must meet
the requirements of regulation 5 "

The clear implication and statement of the comments in regulation 8 is thus
that NO further approvals to the old TTE Directive will be granted after 7
April 2000. Therefore previous comments about a 1 year transition period
appear to be only partially correct.

Maybe we should protest at this 

RE: R&TTE Directive - Transitional periods

[Finlayson, Joe]

Bill,

I saw nothing on your web page.  I, and many others, may be
interested if the agenda was made available.

Thx,


Joe

*
Joe Finlayson   
Compliance Engineering Manager
NBase-Xyplex
295 Foster Street
Littleton, MA 01460
Tel:+1 (978) 952-5887
Fax:+1 (978) 952-5054
Email:  jfinlay...@nbase-xyplex.com



-Original Message-
From: wobr...@itsqs.com [mailto:wobr...@itsqs.com]
Sent: Wednesday, December 01, 1999 8:15 AM
To: roger.vi...@wwgsolutions.com; john.al...@rdel.co.uk
Cc: emc-p...@majordomo.ieee.org
Subject: RE: R&TTE Directive - Transitional periods



Based on the emails of the past couple of days, this seems like a genuine
public service - 

For anyone's interest - Intertek Testing Services and NMi (Netherlands
Measurement Institute) are holding a seminar on the new RTTE Directive in
Boxboro, MA on 12/14/99.  The program may clear up some confusion that
exists among practitioners.  If you would like more information, contact me
at the numbers below.

Bill O'Brien
ITS
Boxboro, MA
978-635-8553
wobr...@itsqs.com

-Original Message-
From: roger.vi...@wwgsolutions.com [mailto:roger.vi...@wwgsolutions.com]
Sent: Wednesday, December 01, 1999 6:36 AM
To: John Allen
Cc: emc-p...@majordomo.ieee.org
Subject: Re: R&TTE Directive - Transitional periods





John,
Thanks for the info and the pointer to TAPC which I also find a valuable
source
of such info.
Your summary adds detailed support to the information I was given at a BABT
seminar on Oct 5 (emc-pstc posting 15 Oct), but which was disputed in this
forum. Are the UK out on their own in disallowing new approvals to the old
regime during this transition period?

Roger




John Allen  on 30/11/99 18:27:24

Please respond to John Allen 

To:   "emc-p...@majordomo.ieee.org" 
cc:   "Graham Paddy(Director" , "Robinson
  Colin(Technical directcolin.robin...@rdel.co.uk"
  , "Smith Martin(PBD"
,
  "John Warren(QA" , "'BSI: White Ken'"
  , "Spicer Keith(QA" 
(bcc:
  Roger Viles/PLY/Global)

Subject:  R&TTE Directive - Transitional periods





Hi folks

I have just been sent a copy of the draft UK Statutory Instrument on the
above, together with a copy of the DTI consultative document - these appear
to clarify the previously much-debated subject of the proposed transition
periods and I thought various people might like to know.

These documents are available at the following website:  "www.tapc.org.uk"
in both  Word97 & pdf format.

The consultative document goes into some detail on the subject of
transition periods, and the critical statements are given in the following
sections:

"Summary of proposals
4 The existing UK and European type approval regimes for radio equipment
and telecommunications terminal equipment will end on 7 April 2000.

Manufacturers can place equipment on the market which conforms to the new
regime from 8 April 2000. Notwithstanding this, equipment approved before
this date may continue to be placed on the market until 7 April 2001.

Thereafter all individual items of equipment placed on the market must
conform to the requirements of the new regime."

AND

"Transitional provisions (draft regulation 8)
18 This regulation allows that, despite the ending of UK and European type
approvals regimes for radio equipment and telecommunications terminal
equipment on 7 April 2000, individual items of apparatus approved under
these regimes can continue to be placed on the market without change until
7 April 2001. Such apparatus first placed on the market by 7 April 2001 can
remain on the market until sold, and can subsequently be appropriately
installed and
used.

During the transitional period of 8 April 2000 to 7 April 2001, notified
bodies appointed under Directive 98/13/EC can continue to act in support of
approvals given before that period, for example by continuing arrangements
for production control, but cannot grant further approvals.

>From 8 April 2001, all items of apparatus placed on the market must meet
the requirements of regulation 5 "

The clear implication and statement of the comments in regulation 8 is thus
that NO further approvals to the old TTE Directive will be granted after 7
April 2000. Therefore previous comments about a 1 year transition period
appear to be only partially correct.

Maybe we should protest at this very short notice period  - it is only just
over 4 months away?

What do people think - are the dis-advantages of the new regime out-weighed
by the advantages?

Regards

John Allen
Racal Defence Electronics Ltd
Bracknell
UK

-
This message is coming from the emc-pstc discussion list.
To cancel your subscription, send mail to majord...@ieee.org
with the single line: "unsubscribe emc-pstc" (without the
quotes).  For help, send mail to ed.pr...@cubic.com,
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RE: VIRUS WARNING RE: R&TTE Directive - Transitional periods

[Scott Douglas]

I received three emails that looked like replies to message trails on
emc-pstc. Each had an attachment called "zipped_files.exe". Inoculan
detected the virus Worm.ExploreZip.Neolite in the attached files. The emails
and attached files were summarily deleted and my entire system checked. No
more viruses found. These three emails had subjects of recent emc-pstc
threads, but none of these came to me through the emc-pstc server.

The message source address was "jcoll...@cienna.com"

Since I did try to open one of these attachments, and even though Inoculan
spotted it, and since I use Outlook, it may be that some of you will get
emails from me with the attachment. DO NOT OPEN ANY ATTACHMENT WITH NAME OF
"zipped_files.exe", Delete the message instead.

Scott
s_doug...@ecrm.com
ECRM Incorporated
Tewksbury, MA  USA


-Original Message-
From: john.al...@rdel.co.uk [mailto:john.al...@rdel.co.uk]
Sent: Wednesday, December 01, 1999 6:37 AM
To: emc-p...@majordomo.ieee.org
Subject: VIRUS WARNING RE: R&TTE Directive - Transitional periods
Importance: Low



Hi Folks

This is just to warn you that an automatic reply to my posting last night
on the above subject resulting in me - and possibly others - being sent a
new virus!

The message source address was 'david.cl...@spke.com'

Do not open any self-extracting ZIP messages attached to emails from this
address!!

Luckily it was caught by our corporate firewall, but I then received the
following message from the people administering the firewall. Their
message
is given below for your information.

Regards

John Allen


---

Hi, John.

The mail sent to you has been confirmed as a virus by Sophos.  It's known
as
"explorezip-b"  By the looks of it, the infection results are similar to
many others - you run what looks like a self-unzipping file, and the pc is
infected, sending the virus to many others - via the local address book,
and
in response to each received mail thereafter.

Steve

Steve Lewis
IT Executive
Racal Defence Electronics
Crawley
West Sussex
UK

-
This message is coming from the emc-pstc discussion list.
To cancel your subscription, send mail to majord...@ieee.org
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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To cancel your subscription, send mail to majord...@ieee.org
with the single line: "unsubscribe emc-pstc" (without the
quotes).  For help, send mail to ed.pr...@cubic.com,
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roger.volgst...@compaq.com (the list administrators).

Re: VIRUS WARNING RE: R&TTE Directive - Transitional periods

[Richard Lanzillotto]

The same thing happened to me.
 I was able to destroy using www.mcafee.com clinic.
They have the latest detection and removal
utility for this virus.  Regards
-Original Message-
From: John Allen 
To: emc-p...@majordomo.ieee.org 
List-Post: emc-pstc@listserv.ieee.org
Date: Wednesday, December 01, 1999 6:58 AM
Subject: VIRUS WARNING RE: R&TTE Directive - Transitional periods


>
>Hi Folks
>
>This is just to warn you that an automatic reply to my posting last night
>on the above subject resulting in me - and possibly others - being sent a
>new virus!
>
>The message source address was 'david.cl...@spke.com'
>
>Do not open any self-extracting ZIP messages attached to emails from this
>address!!
>
>Luckily it was caught by our corporate firewall, but I then received the
>following message from the people administering the firewall. Their message
>is given below for your information.
>
>Regards
>
>John Allen
>
>
>---
>
>Hi, John.
>
>The mail sent to you has been confirmed as a virus by Sophos.  It's known
>as
>"explorezip-b"  By the looks of it, the infection results are similar to
>many others - you run what looks like a self-unzipping file, and the pc is
>infected, sending the virus to many others - via the local address book,
>and
>in response to each received mail thereafter.
>
>Steve
>
>Steve Lewis
>IT Executive
>Racal Defence Electronics
>Crawley
>West Sussex
>UK
>
>-
>This message is coming from the emc-pstc discussion list.
>To cancel your subscription, send mail to majord...@ieee.org
>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).
>
>
>


-
This message is coming from the emc-pstc discussion list.
To cancel your subscription, send mail to majord...@ieee.org
with the single line: "unsubscribe emc-pstc" (without the
quotes).  For help, send mail to ed.pr...@cubic.com,
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roger.volgst...@compaq.com (the list administrators).

RE: R&TTE Directive - Transitional periods

[WOBrien]

Based on the emails of the past couple of days, this seems like a genuine
public service - 

For anyone's interest - Intertek Testing Services and NMi (Netherlands
Measurement Institute) are holding a seminar on the new RTTE Directive in
Boxboro, MA on 12/14/99.  The program may clear up some confusion that
exists among practitioners.  If you would like more information, contact me
at the numbers below.

Bill O'Brien
ITS
Boxboro, MA
978-635-8553
wobr...@itsqs.com

-Original Message-
From: roger.vi...@wwgsolutions.com [mailto:roger.vi...@wwgsolutions.com]
Sent: Wednesday, December 01, 1999 6:36 AM
To: John Allen
Cc: emc-p...@majordomo.ieee.org
Subject: Re: R&TTE Directive - Transitional periods





John,
Thanks for the info and the pointer to TAPC which I also find a valuable
source
of such info.
Your summary adds detailed support to the information I was given at a BABT
seminar on Oct 5 (emc-pstc posting 15 Oct), but which was disputed in this
forum. Are the UK out on their own in disallowing new approvals to the old
regime during this transition period?

Roger




John Allen  on 30/11/99 18:27:24

Please respond to John Allen 

To:   "emc-p...@majordomo.ieee.org" 
cc:   "Graham Paddy(Director" , "Robinson
  Colin(Technical directcolin.robin...@rdel.co.uk"
  , "Smith Martin(PBD"
,
  "John Warren(QA" , "'BSI: White Ken'"
  , "Spicer Keith(QA" 
(bcc:
  Roger Viles/PLY/Global)

Subject:  R&TTE Directive - Transitional periods





Hi folks

I have just been sent a copy of the draft UK Statutory Instrument on the
above, together with a copy of the DTI consultative document - these appear
to clarify the previously much-debated subject of the proposed transition
periods and I thought various people might like to know.

These documents are available at the following website:  "www.tapc.org.uk"
in both  Word97 & pdf format.

The consultative document goes into some detail on the subject of
transition periods, and the critical statements are given in the following
sections:

"Summary of proposals
4 The existing UK and European type approval regimes for radio equipment
and telecommunications terminal equipment will end on 7 April 2000.

Manufacturers can place equipment on the market which conforms to the new
regime from 8 April 2000. Notwithstanding this, equipment approved before
this date may continue to be placed on the market until 7 April 2001.

Thereafter all individual items of equipment placed on the market must
conform to the requirements of the new regime."

AND

"Transitional provisions (draft regulation 8)
18 This regulation allows that, despite the ending of UK and European type
approvals regimes for radio equipment and telecommunications terminal
equipment on 7 April 2000, individual items of apparatus approved under
these regimes can continue to be placed on the market without change until
7 April 2001. Such apparatus first placed on the market by 7 April 2001 can
remain on the market until sold, and can subsequently be appropriately
installed and
used.

During the transitional period of 8 April 2000 to 7 April 2001, notified
bodies appointed under Directive 98/13/EC can continue to act in support of
approvals given before that period, for example by continuing arrangements
for production control, but cannot grant further approvals.

>From 8 April 2001, all items of apparatus placed on the market must meet
the requirements of regulation 5 "

The clear implication and statement of the comments in regulation 8 is thus
that NO further approvals to the old TTE Directive will be granted after 7
April 2000. Therefore previous comments about a 1 year transition period
appear to be only partially correct.

Maybe we should protest at this very short notice period  - it is only just
over 4 months away?

What do people think - are the dis-advantages of the new regime out-weighed
by the advantages?

Regards

John Allen
Racal Defence Electronics Ltd
Bracknell
UK

-
This message is coming from the emc-pstc discussion list.
To cancel your subscription, send mail to majord...@ieee.org
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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To cancel your subscription, send mail to majord...@ieee.org
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-
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To cancel your subscription, send mail to majord...@ieee.org
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roger.volgst...@compaq.com (the list administrators).

VIRUS WARNING RE: R&TTE Directive - Transitional periods

[John Allen]

Hi Folks

This is just to warn you that an automatic reply to my posting last night 
on the above subject resulting in me - and possibly others - being sent a 
new virus!

The message source address was 'david.cl...@spke.com'

Do not open any self-extracting ZIP messages attached to emails from this 
address!!

Luckily it was caught by our corporate firewall, but I then received the 
following message from the people administering the firewall. Their message 
is given below for your information.

Regards

John Allen

  
---

Hi, John.

The mail sent to you has been confirmed as a virus by Sophos.  It's known 
as
"explorezip-b"  By the looks of it, the infection results are similar to
many others - you run what looks like a self-unzipping file, and the pc is
infected, sending the virus to many others - via the local address book, 
and
in response to each received mail thereafter.

Steve

Steve Lewis
IT Executive
Racal Defence Electronics
Crawley
West Sussex
UK

-
This message is coming from the emc-pstc discussion list.
To cancel your subscription, send mail to majord...@ieee.org
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).

Re: R&TTE Directive - Transitional periods

[roger . viles]

John,
Thanks for the info and the pointer to TAPC which I also find a valuable source
of such info.
Your summary adds detailed support to the information I was given at a BABT
seminar on Oct 5 (emc-pstc posting 15 Oct), but which was disputed in this
forum. Are the UK out on their own in disallowing new approvals to the old
regime during this transition period?

Roger




John Allen  on 30/11/99 18:27:24

Please respond to John Allen 

To:   "emc-p...@majordomo.ieee.org" 
cc:   "Graham Paddy(Director" , "Robinson
  Colin(Technical directcolin.robin...@rdel.co.uk"
  , "Smith Martin(PBD" ,
  "John Warren(QA" , "'BSI: White Ken'"
  , "Spicer Keith(QA"  (bcc:
  Roger Viles/PLY/Global)

Subject:  R&TTE Directive - Transitional periods





Hi folks

I have just been sent a copy of the draft UK Statutory Instrument on the
above, together with a copy of the DTI consultative document - these appear
to clarify the previously much-debated subject of the proposed transition
periods and I thought various people might like to know.

These documents are available at the following website:  "www.tapc.org.uk"
in both  Word97 & pdf format.

The consultative document goes into some detail on the subject of
transition periods, and the critical statements are given in the following
sections:

"Summary of proposals
4 The existing UK and European type approval regimes for radio equipment
and telecommunications terminal equipment will end on 7 April 2000.

Manufacturers can place equipment on the market which conforms to the new
regime from 8 April 2000. Notwithstanding this, equipment approved before
this date may continue to be placed on the market until 7 April 2001.

Thereafter all individual items of equipment placed on the market must
conform to the requirements of the new regime."

AND

"Transitional provisions (draft regulation 8)
18 This regulation allows that, despite the ending of UK and European type
approvals regimes for radio equipment and telecommunications terminal
equipment on 7 April 2000, individual items of apparatus approved under
these regimes can continue to be placed on the market without change until
7 April 2001. Such apparatus first placed on the market by 7 April 2001 can
remain on the market until sold, and can subsequently be appropriately
installed and
used.

During the transitional period of 8 April 2000 to 7 April 2001, notified
bodies appointed under Directive 98/13/EC can continue to act in support of
approvals given before that period, for example by continuing arrangements
for production control, but cannot grant further approvals.

>From 8 April 2001, all items of apparatus placed on the market must meet
the requirements of regulation 5 "

The clear implication and statement of the comments in regulation 8 is thus
that NO further approvals to the old TTE Directive will be granted after 7
April 2000. Therefore previous comments about a 1 year transition period
appear to be only partially correct.

Maybe we should protest at this very short notice period  - it is only just
over 4 months away?

What do people think - are the dis-advantages of the new regime out-weighed
by the advantages?

Regards

John Allen
Racal Defence Electronics Ltd
Bracknell
UK

-
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To cancel your subscription, send mail to majord...@ieee.org
with the single line: "unsubscribe emc-pstc" (without the
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roger.volgst...@compaq.com (the list administrators).

Fw: Re: R&TTE Directive

[ed . price]

Posted for Colin:





  From: colin_mcgeec...@hp-unitedkingdom-om4.om.hp.com
  Subject: Re: R&TTE Directive
  Date: Wed, 7 Apr 1999 09:24:26 +0100 
  To: wo...@sensormatic.com
  Cc: emc-p...@majordomo.ieee.org, t...@world.std.com


>  I have not read the R&TTE directive but I would suggest that any 
>  DoC only requires to be in ONE of the official EU languages.
>  
>  You can recognise the standard numbers anyway, if your not fluent 
>  in the language which the DoC is written in. eg IEC 60950 in 
>  English is IEC 60950 in German and French.
>  
>  Cheers,
>  
>  Colin.
> 
> 
> __ Reply Separator 
> _
> Subject: R&TTE Directive
> Author:  Non-HP-WOODS (wo...@sensormatic.com) at HP-UnitedKingdom,mimegw6
> Date:04/06/99 8:44 PM
> 
> 
> I have several open issues with Article 6.3 of the new R&TTE directive that 
> I would like to discuss with the community.
>  
> The article indicates that manufacturers must provide "information for the 
> user on the intended use of the apparatus." 
>  
> *   Question: How in depth does this information need to be?
>  
> The article indicates that a copy of the declaration of conformity
> must be provided to the user.
>  
> *   Comment: Assuming that the equipment is sold in all member states, 
> it appears that a copy of the original signed declaration be included along 
> with translations in all of the official languages of the EU.
>  
> The article also says for radio equipment, ". . .such information shall be 
> sufficient to identify on the packaging and the instruction for use of the 
> apparatus the Member States. . .where the equipment is intended to be 
> used"
>  
> *   Comment: This requirement appears to be written for devices that are 
> sold to consumers. For example, a German native could shop for a remote 
> control device in the UK and be assured that the product would be legal in 
> Germany. However, as written, this article also requires the same 
> information to be placed on the packaging of a 50 MW FM transmitter, which 
> does not seem to be appropriate to this writer.
>  
> *   Question: Assuming that a radio device may be used everywhere within 
> the EU or perhaps not, how would that be noted on the packaging without 
> resorting to multiple languages?
> 
> 

---End of Original Message-

--
Ed Price
ed.pr...@cubic.com
Electromagnetic Compatibility Lab
Cubic Defense Systems
San Diego, CA.  USA
619-505-2780
List-Post: emc-pstc@listserv.ieee.org
Date: 04/07/1999
Time: 08:11:02
Military & Avionics EMC Services Our Specialty
Also Environmental / Metrology / Reliability
--



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roger.volgst...@compaq.com (the list administrators).

Re: R&TTE Directive

[COLIN_MCGEECHAN]

 I have not read the R&TTE directive but I would suggest that any 
 DoC only requires to be in ONE of the official EU languages.
 
 You can recognise the standard numbers anyway, if your not fluent 
 in the language which the DoC is written in. eg IEC 60950 in 
 English is IEC 60950 in German and French.
 
 Cheers,
 
 Colin.


__ Reply Separator _
Subject: R&TTE Directive
Author:  Non-HP-WOODS (wo...@sensormatic.com) at HP-UnitedKingdom,mimegw6
List-Post: emc-pstc@listserv.ieee.org
Date:04/06/99 8:44 PM


I have several open issues with Article 6.3 of the new R&TTE directive that 
I would like to discuss with the community.
 
The article indicates that manufacturers must provide "information for the 
user on the intended use of the apparatus." 
 
*   Question: How in depth does this information need to be?
 
The article indicates that a copy of the declaration of conformity
must be provided to the user.
 
*   Comment: Assuming that the equipment is sold in all member states, 
it appears that a copy of the original signed declaration be included along 
with translations in all of the official languages of the EU.
 
The article also says for radio equipment, ". . .such information shall be 
sufficient to identify on the packaging and the instruction for use of the 
apparatus the Member States. . .where the equipment is intended to be 
used"
 
*   Comment: This requirement appears to be written for devices that are 
sold to consumers. For example, a German native could shop for a remote 
control device in the UK and be assured that the product would be legal in 
Germany. However, as written, this article also requires the same 
information to be placed on the packaging of a 50 MW FM transmitter, which 
does not seem to be appropriate to this writer.
 
*   Question: Assuming that a radio device may be used everywhere within 
the EU or perhaps not, how would that be noted on the packaging without 
resorting to multiple languages?

RE: R&TTE Directive

[Crabb, John]

I received the following yesterday from one of my "sources" :

---
Message from ETSI

The much heralded R&TTE Directive was adopted on the 9th March and is
known as 99/5/EC. It is still to be published in the OJEC (approximately 4
to 6 weeks at the most). It comes fully into force on 10th March 2000 if the
dates are constant.

  Claire d'Esclercs
 ETSI Standards Making Support Department

--
Regards,
John Crabb, Development Excellence (Product Safety) , 
NCR  Financial Solutions Group Ltd.,  Kingsway West, Dundee, Scotland. DD2
3XX
E-Mail :john.cr...@scotland.ncr.com
Tel: +44 (0)1382-592289  (direct ). Fax +44 (0)1382-622243.   VoicePlus
6-341-2289.


> -Original Message-
> From: WOODS, RICHARD [SMTP:wo...@sensormatic.com]
> Sent: 12 March 1999 15:40
> To:   'emc-pstc'
> Subject:  R&TTE Directive
> 
> My source believes that the Radio and Telecommunications Terminal
> Equipment
> Directive will be published in the OJ in April and will take effect after
> one year. What do you hear?
> 

-
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To cancel your subscription, send mail to majord...@ieee.org
with the single line: "unsubscribe emc-pstc" (without the
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