---------- Original message from Victor L. Boersma ---------- > > Treggers > > > > CTR 21 passed the European Council vote on 20 July, and was notified > > on 21 June to all National Member States. > > > > This means that CTR21 Pan-European approvals can now be issued. > > > > I know that BABT have already said that they will now issue approvals to > > CTR21 and convert existing TBR21 (fully compliant) national approvals on > > request.. > > > > regards > > > > Andrea Bishop > > Andrea, > > I am not quite sure how it works, but it seems to me that I remember that > any decision by the European Commission needs to be transposed into > national regulation in the member states, or something to that effect, > before it takes effect. Seems to me that the member states will need a > couple of days (weeks ... months ....) to do that and that the effective > date even from a Council perspective cannot be the date when ACTS or some > body of that ilk agreed to the CTR. It may well be that some > organizations are willing to let you use their Notified Body number and > the CE marking as soon as they have satisfied themselves that indeed your > gadget meets all the applicable requirements. However, a member state > that has not yet transposed that new agreement into national regulation, > may not want to accept that before they have to. Question is, by what > date do the member states have to implement CTR21 ??? > > By the way, something went screwy with your dates as you have the member > states notified before the Council made its determination. > > Ciao, > > Vic Boersma
Vic, Andrea A few things to clarify first: [1] CTR21 does not actually exist yet. The European Council have adopted TBR21 which means that is is now effectively a harmonized standard. It will not be a CTR until the relevant European Commission decision is published in the OJ. Member states will have to implement a CTR within 12 months (usually) of the decision (which usually happens several weeks before OJ publication). OJ publication is expected around September time. [2] Many members states cannot (legally) grant CE approvals using TBR21 until the CTR21 OJ publication takes place. This is to do with how the terminal equipment Directive is implemented into the national law of the member state. In some member states (like the UK for example) the law specifically refers to CTRs being used as the basis for approval. The laws of other member states (such as The Netherlands) do not refer to CTR's but to Harmonized Standards, and whilst a CTR is a harmonized standard, a harmonized standard is not necessarily a CTR as is the case with TBR21 at the moment. Andrea's announcement surprises me since I have heard from at least two manufacturer's in the last week with national UK TBR21 approval who claim to have approached BABT (in at least one case BABT Product Service) and were told that BABT could not grant CE approval until the CTR21 Commission Decision appeared in the OJ, I guess because of the UK law. Regardless of all of this, Vic's comments do provide a cautionary word of warning. There may be member states who make things difficult for manufacturers during periods of transition and beyond. Furthermore there may be other implications (like pulse dialling or caller ID) which do not fall within the scope of TBR21 but do fall within the scope of other national standards meaning that in some cases CTR21 CE approval and various national approvals may be required. Regards ------------------------------ Ben Wrigley Senior Approvals Specialist KTL Saxon Way Priory Park West Hull HU13 9PB UK Phone: +44 (0)1482 801801 Fax: +44 (0)1482 801806 Mobile: +44 (0)802 280914 Web: http://www.ktl.co.uk Email: mailto:[email protected]
