In a message dated 5/28/01, Robert Pausch writes: > the statement that the 60mA current limiting is no longer required for > Europe is untrue in this general > form. Correct is: > France has executed the right to apply article 18(3) of the RTTE directive > for the period of 30 months. > For this period the current limiting function shall be provided with TE to > be placed on the French market. > Please review the commission decision 2000/373/EC. (I can forward on > request). >
Hi Robert: I described the problem with France in my original posting. My comments were based on the content of the same 2000/373/EC document that you reference, so I guess we have a difference of opinion about what this decision requires manufacturers to do. By my reading of Article 1 of 2000/373/EC, the EC has simply specified that TE without current limiting must be provided with a declaration that the TE is not to be used on phone lines that require current limiting. There is no requirement that TE without current limiting can not be sold in France. I think that if you review the wording of the decision it will become apparent that this is what the Commission has done. It appears to be a political solution where the Commission wanted to appease France without weakening the implementation of RTTE Directive. In addition to the decision 2000/373/EC, I have a copy of a TCAM letter dated February 20, 2000, where more of the background discussion that led to the decision is described. In this discussion, representatives of the Commission pointed out that the current limiter problem only affected 22% of France's lines, so requiring current limiters on all TE sold in France would unduly penalize the users of the other 78% of the lines. In fact, they argued that because 78% of the lines in France did not require current limiting, the Commission lacked the authority to impose a blanket requirement that all TE sold in France must have current limiting. In the end, they opted to impose a requirement that manufacturers of TE without current limiting must declare that the TE is not intended for connection to PSTN lines that require current limiting. This leaves open the option for a manufacturer of non current limited TE to make this declaration and still legally sell the TE in France. I'm not sure how practical it would be to use this option, since users may have no easy way to determine whether their line requires current limiting or not. I would not recommend this option for manufacturers of consumer products, but it might be a viable approach for manufacturers of more specialized commercial equipment. In particular, there are some cases where an existing commercial product is otherwise compliant with the RTTE, so that no redesign would be necessary if the current limiter is not required. For this type of situation, the availability of the declaration option may mean the difference between selling a few units in France and selling none at all. The manufacturer's final decision will depend on a number of factors, including the cost impact of providing the limiter, the type of product involved, the volume of product to be sold in France, and the timing of the product sales. It is worth noting that the claimed percentage of affected lines was 22% in January 2000, and that even if France Telecom had been granted the delay they sought, they felt that these lines would be eliminated by October 2002 (conveniently equal to the maximum delay allowed under the RTTE). My guess is that since France Telecom did not get the delay they wanted, they may be accelerating the phase out of the affected lines. This suggests that the percentage of affected lines is probably much less than 22% today, and is probably declining every month. In summary, I believe that Commission Decision 2000/373/EC does not forbid the sale of non current limited TE in France. Rather, it simply requires that such TE be provided with a declaration that the TE is not intended for use on lines that require current limiting. There are probably only a few situations where a manufacturer would choose to exercise this option, but the option is there. Fortunately, after October 2002, there will be no need to consider the current limiter issue at all. Joe Randolph Telecom Design Consultant Randolph Telecom, Inc. 781-721-2848 http://www.randolph-telecom.com
