Let's try putting it all together in an example. Let's take EN 300 330,
Inductive Short Range Devices (SRDs). ETSI has approved the standard - a
100% vote I hear - which specifies the limits in the 9-135 kHz band, for
example. Since each EU Member State approved the standard, does that not
imply that the 9-135 kHz band has been harmonized for inductive SRDs? Or, is
it necessary for the same Member States to implement CEPT/ERC Recommendation
70-03? Or, is it necessary for a CEPT/ERC Decision to be issued - one that
specifically references EN 300330? Actually, all of this can be summed up
into one question - How can I confirm that a particular frequency band has
been harmonized?
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From: Bill Ellingford [SMTP:[email protected]]
Sent: Wednesday, July 07, 1999 6:28 AM
To: 'Chris Raymont'
Cc: '[email protected]'
Subject: Harmonised Frequencies, R&TTE Dir. #2
This is a re-transmission, my first send seems to have been
corrcupted and combined with an earlier message.
Hi Chris & Treg world
There is a lot of debate at present on harmonised frequency bands
for Radio products under the R&TTE D. The basic argument is that, for
reasons of differing terrain, evolution of national systems etc, there are
many products required to perofrm the same function in different countries
using different frequencies and sometimes, different modulation schemes.
That is a fact.
If we look at the wider picture, there are many new technologies for
which CEPT (and in some cases ITU-R) have set-aside specific bands to be
used by all member states.
There are also moves to free up bands occupied by old technology
(i.e. moving police and public services away from the lower VHF bands and
ceasing VHF TV transmissions etc.). Where this occurrs, CEPT tries to
formulate a new, pan-European use for these redundant bands and attempts to
define harmonised usage.
Under the R&TTE Directive, a simple CE mark will allow you to place
an item onto the market in any country where there is harmonised spectrum
usage. For products in countries where different bands / frequencies are
allocated, your marking must (via an indicating code) show which countries
it may be used in. You are not prevented from moving these goods around
Europe but the user will be breaking the law if they attempt to use
equipment so marked in a nation where the usage is invalid.
So, one must check with the ERO (and maybe CEPT) on which
frequencies and schemes are harmonised and for products outside of this, the
National radio authorities will be required to produce their spectrum
allocation tables from which one will try to best engineer the product to
meet as many target markets as possible and seek an ID code for the CE
marking in each valid nation.
In cases of doubt (for radio products) an approval body will still
exist but the role will be one of advising on compliance rather than
actually certifying product. One will be able to approach these bodies for
a guidance decission on use of appropriate standards etc. for a
multi-country case.
Please consider that this reply is very brief in terms of the degree
of information to be conveyed by the directive, this response is aimed at
definitions relating to harmonised spectrum usage only. There are many
other considerations to be applied under the directive.
I hope that this provides people with some basic understanding, the
radio part of the directive is far more complex than te TTE part.
Best regards: Bill Ellingford
Motion Media Technology Ltd
