Joe, Perhaps Peter (who works for a test lab and not a manufacturer) could infer that, because the interface on the product he is evaluating was designed to be an SELV Circuit, it is not intended to connect to a network that extends beyond a building and further that the R&TTED does not apply. But that would presume that his customer knew what he was doing. Peter may find out that his customer does intend to supply the product as an item of CPE. In this case he could then deduce that the equipment is unlikely to be suitable for that purpose (certainly not universally so). That is why it is wrong to start off looking to see what standards and aspects of a standard are complied with and then decide which regulations apply. Rather, in my opinion, Peter should start by asking his customer what market the equipment he is evaluating is intended to be supplied into. He can then see which standards and attributes of those standards are complied with. Based on these two items of information he will then be in a position to advise his client as to whether the product is likely to be suitable for the intended market. Always remembering of course that complying with a Harmonised Standard is only one way of demonstrating compliance with with any directive (albeit the most common way). As usual, my own opinions. Regards, Richard Hughes
-----Original Message----- From: Joe Finlayson [mailto:[email protected]] Sent: 02 October 2002 13:30 To: 'Paul Didcott' Cc: Hughes, Richard [HAL02:GF00:EXCH]; 'EMC PSTC'; 'NEBS Newsgroup'; 'TREG Newsgroup' Subject: RE: RTTE or LVD for Equipment with E1 SELV interface Agreed. So, in Peter's case, he stated that his product is SELV and therefore is not designed or intended to connect to the PSTN. From that statement, I would venture to say that his product is Network Equipment (not CPE) and therefore does not fall within the scope of the R&TTE Directive. Thx, Joe -----Original Message----- From: Paul Didcott [mailto:[email protected]] Sent: Wednesday, October 02, 2002 3:59 AM To: 'Joe Finlayson' Cc: 'Richard Hughes'; 'EMC PSTC'; 'NEBS Newsgroup'; 'TREG Newsgroup' Subject: RE: RTTE or LVD for Equipment with E1 SELV interface Guys, >>As this product does not connect to the PSTN and is destined for the Central Office only, I would say the R&TTE Directive does not apply as the scope does not include Network Equipment. Correct. >>It will be seen from the above that the R&TTED is not limited to PSTN since it is quite possible that a network operator could provide a business with an E1 interface, for instance. Correct. The R&TTED applies to terminal equipment which connects to any public service of the network operator, whether that be a leased line service or PSTN service. >>"Public" telecommunications network is included in the scope of the R&TTE Directive Incorrect. The R&TTE scope statement, "intended to be connected directly or indirectly by any means whatsoever to interfaces of public telecommunications networks", only relates to TE, not network equipment. The term 'indirect' simply means via another piese of equipment, e.g. such as a telephone connected to a PBX which connects to the public telecom network. Hence equipment connected behind PBX falls within the scope of the R&TTED, for example. As has been mentioned, the LVD and EMC Directives & CE marking still applies to equipment destined for use only 'within' the public network, for EU/EFTA Member countries. Hence, E1 equipment desined for connection to a public telecom network service, must be CE marked for compliance with the R&TTED. However, the applicable standards will be exactly the same for EMC and Safety compliance under the R&TTED as would apply under the EMC Directive and LVD. Hope this helps, B-regards, Paul G Didcott Snr Approvals Consultant Tel: +44 (0)1482 801801 Mailto:[email protected] <mailto:[email protected]> KTL is now fully recognised by the DSL Forum as an Independent Testing Laboratory (ITL). Laboratory Accreditation Services Ltd t/a KTL. Registered No. 4407692. Registered Office: KTL, Saxon Way, Priory Park West, Hull, HU13 9PB, UK. www.ktl.com <http://www.ktl.com> " -----Original Message----- From: Joe Finlayson [mailto:[email protected]] Sent: 01 October 2002 23:15 To: 'Richard Hughes'; 'EMC PSTC'; 'NEBS Newsgroup'; 'TREG Newsgroup' Subject: RE: RTTE or LVD for Equipment with E1 SELV interface Richard, Good point - the "directly or indirectly" part grabbed my attention but that seems too broad a description which could encompass quite a wide range of equipment. However, the point of discussion here is whether a product classified as SELV by IEC 60950, Type 2 by GR-1089, etc. and does not connect (interface) to the "Public" telecommunications network is included in the scope of the R&TTE Directive. This type of product resides in the network and does not connect to outside plant conductors - terminates to another piece of equipment with the proper isolation to outside plant conductors. My interpretation is that if there is no provision for physical connection to the PSTN, the R&TTE does not apply. Any takers??? I'll copy the TREG and NEBS gurus on this one as well. Thx, Joe -----Original Message----- From: Richard Hughes [mailto:[email protected]] Sent: Tuesday, October 01, 2002 5:57 PM To: 'Joe Finlayson'; "EMC-PSTC (E-mail)" < Subject: RE: RTTE or LVD for Equipment with E1 SELV interface Joe, The R&TTED applies to the following types of equipment: 1) Radio equipment 2) Terminal equipment. The Directive also contains the following definitions: 'telecommunications terminal equipment' means a product enabling communication or a relevant component thereof which is intended to be connected directly or indirectly by any means whatsoever to interfaces of public telecommunications networks (that is to say, telecommunications networks used wholly or partly for the provision of publicly available telecommunications services). 'interface' means (i) a network termination point, which is a physical connection point at which a user is provided with access to public telecommunications network, and/or (ii) an air interface specifying the radio path between radio equipment and their technical specifications It will be seen from the above that the R&TTED is not limited to PSTN since it is quite possible that a network operator could provide a business with an E1 interface, for instance. Peter, It is for the manufacturer to decide to which market, e.g. terminal equipment or central office equipment only, they whish to sell their product into. EN 60950 has nothing to do with it since this standard can be used to evaluate either type of product - and other non-telecom ICT products as well of course. Simplistically, if the product does not have an input or output voltage in the range 50-1000Vac, 75-1500Vdc then the LVD does not apply {ref. Article 1 of LVD}. Clearly, if the LVD does apply then certain editions of EN 60950 do provide a presumption of conformity with the safety objectives of the LVD. If the LVD does not apply then that should not be taken as an excuse to not comply with EN 60950, but that's another debate entirely. If the R&TTED applies then the EMC is not applied as such, because the EMC requirements are then covered by the R&TTED. However, this is largely an administrative technicality because Article 3(1)(b) points to the EMC Directive for its essential requirements, just as Article 3(1)(a) points to the LVD for safety (minus any upper or lower voltage limit). Well, that's enough personal opinions expressed on this matter for me... Richard Hughes -----Original Message----- From: Joe Finlayson [ mailto:[email protected] <mailto:[email protected]> ] Sent: 01 October 2002 17:52 To: "EMC-PSTC (E-mail)" < Subject: RE: RTTE or LVD for Equipment with E1 SELV interface Peter, As this product does not connect to the PSTN and is destined for the Central Office only, I would say the R&TTE Directive does not apply as the scope does not include Network Equipment. Thx, Joe -----Original Message----- From: Peter Merguerian [ mailto:[email protected] <mailto:[email protected]> ] Sent: Tuesday, October 01, 2002 9:33 AM To: "EMC-PSTC (E-mail)" < Subject: RTTE or LVD for Equipment with E1 SELV interface Dear All, For an equipment where the E1 has been assessed for SELV under EN 60 950 (ie for intrabuilding use and not subject to overvoltages), does the equipment fall under the RTTE Directive or can the manufacturer declare compliance to the LVD and EMC Directives. If under the RTTE Directive, what telecom standard applies to the E1 intrabuilding interface? This e-mail message may contain privileged or confidential information. If you are not the intended recipient, you may not disclose, use, disseminate, distribute, copy or rely upon this message or attachment in any way. If you received this e-mail message in error, please return by forwarding the message and its attachments to the sender. PETER S. MERGUERIAN Technical Director I.T.L. 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