---------- Original message from Ted Warren ----------

> Marc Decre wrote:
> > 
> > Hello,
> > 
> > Can somebody advise on the following:
> > 
> > TBR21 only descibes DTMF dialling.
> > 
> > 1. If you support pulse dialling in a product, is it necessary to go for
> > national approvals ? 2. What is the coverage for DTMF dialling in Europe
> > , specially for France, Spain , Portugal, Belgium and Germany.
> > 
> > Marc Decre
> 
> 
> Hi, Marc
> 
> In answer to the first part of your question, National requirements DO
> apply to equipment with pulse dialling facilities, but which would
> otherwise be within the scope of CTR21.  However, some countries (for
> example the UK) add no additional requirements for the pulse dialling
> facility, so my understanding is that the approval route in the UK is the
> same as for such equipment without pulse dialling facilities.  
> 
> It would be interesting to know whether you then get a pan - Europoean
> approval that you can not use in some countries, or a national approval to
> exclusively pan-European standards.  Comments from others would be
> welcome.
> 
> I do not have sufficient information to answer the second part of the
> question, except that DTMF is very widespread on direct exchange lines. 
> In the UK the availability is supposed to be 100%, but it may still be
> necessary to individulaay request that the service is enabled in a few
> cases.
> 

Marc, Ted

Your pan-European CTR21 approval will be valid in all member states for the 
functions of your product covered by CTR21.

Additional features OUTSIDE the scope of CTR21 (like pulse dialling) may 
require a separate approval from country to country but these member states 
cannot impose national requirements which conflict with those of CTR21, 
they can only add requirements which fall outside CTR21. You effectively end 
up with a pan-European CTR21 approval with additional national "delta" 
approvals in the countries which require them.

Many member states will allow you to get around the additional requirements 
if you declare that, for example, pulse dialling or caller ID is not supported 
in 
that country and include suitable user instructions to ensure the feature is 
not used.

The laws in other member states however require you to go one step further 
so that you are forced to either disable the feature altogether or get it 
tested 
and approved. They will not just accept a declaration and user instructions.

CTR21 puts manufacturers in a better position than they were in three 
months ago but it only goes part of the way depending on the features of 
your product. However, given the choice of (a) CTR21 + deltas or (b) national 
standards only, most manufacturers welcome the benefits which CTR21 
brings, even if these benefits are limited.

Regards

------------------------------

Ben Wrigley
Senior Approvals Specialist

KTL
Saxon Way
Priory Park West
Hull
HU13 9PB
UK

Phone:  +44 (0)1482 801801
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Email:  mailto:[email protected]

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