As I stated before, the R&TTE directive is fully in force from the 8th of April 2000. The TTE/SES directive (98/13/EG) is withdrawn at the same moment, so there is NO overlap (Articl. 20).
In some specific cases (e.g. voice-telephony, Articl. 18.3) member states can request for a 30 months delay on a national basis, but I haven't seen something in that direction up to now. So let's stick to the basics of the R&TTE directive: - There is a transition regime which allows manufacturers to continue with the older approvals, set BEFORE the 8th of April 2000 (under TTE/SES procedures and marking OR under national regimes), but NOT longer than 1 year. After the 8th of April 2001 even these older products shall enter the EU market according to the new rules of the R&TTE directive. - However, when it relates to NEW products & market access (not second hand), the R&TTE is FULLY in force from the 8th of April 2000. So there is no choice. - When it concerns radio (transmitter apparatus), to be used with NON-harmonised frequencies (country-specific) , there should be a warning signal on the equipment, so that the USER is aware (The special sign, 0 with a diagonal line, see Annex VII, (5)). The user manual should describe clearly in which countries it is allowed to use. This warning signal shall be stated on the package as well. After the 8th of April 2001 ALL PRODUCTS entering the EU market must satisfy the R&TTE procedures AND marking. --------------------- How to deal with the R&TTE? The R&TTE directive put a high pressure now on the EN Standardisation bodies to generate new "Harmonised" Standards, based upon the "Essential" requirements. (CEN, CENELEC, ETSI). For most products this "Harmonised" Standards will come too late. To cope with the situation, it is allowed for telecom equipment to use the present CTR's - as far as the equipment falls under its scope, as a presumption of conformity to the essential R&TTE requirements. Generally speaking the new requirements are less stringent, so it is technically justified to use the older Standards. However, a warning should be given for safety matters. The R&TTE directive has a new approach towards safety. It includes also the requirements of directive 73/23/EEG, WITHOUT the supply restrictions, so battery operated equipment is included now (Artcl.3.1a). That means that ALL risks arising from the use shall be covered as well, e.g. acoustical shock, and EMF (!) etc. With regard to EMF we have seen the impact already with the mandate to the EU Standardisation bodies to define new requirements, first for GSM and other mobile equipment (before April 2000 !) So, after the 8th of April, manufacturers can better choose the Technical Construction File (TCF) approach as described under Annex IV, and ask an R&TTE Notified Body (see Annex IV and V) for an Opinion. (A written statement about your TCF). This gives no guarantee in liability issues, but in case that it goes wrong, you can show in a fair way your careful and prudent approach. Best regards, Theo Hildering, Senior Consultant, KTL-Arnhem, The Netherlands Web-site: www.ktl.com -----Original Message----- From: Leslie Bai [mailto:[email protected]] Sent: 10 December 1999 02:20 To: H.T. Hildering; [email protected]; [email protected]; [email protected] Subject: RE: Using RTTE directive before April 2000? There is a transition regime applies. Before April 8, 2000, we knew what we should do.... Between April 8, 2000 and April 7, 2001, the transition regime applies and manufacturers can place on the market and put into service equipment which Case 1. complies with Directive 99/5/EC Case 2. complies with Directive 98/13/EC (for equipment within its scope) Case 3. complies with national regulations (for radio equipment, which don't fall within teh scope of Directive 98/13/EC). In Case 1 and Case 2, equipment can freeely move according to the provisions of the Directives. In Case 3, Articles 28 and 30 apply. As of April 8, 2001, ONLY Directive 99/5/EC applies. Rgds, Leslie --- "H.T. Hildering" <[email protected]> wrote: > > The situation is simple, > > The European Commission has stated that the R&TTE > directive will come > effectively in force on the 8th of April 2000 for > all EU countries. > Therefore all member countries are obliged to > transpose it into their > national regulation before that date. > All member countries shall start to use the R&TTE > directive at the 8th of > April. > > Best regards > > Theo Hildering > > > > > > > > > -----Original Message----- > From: [email protected] > [mailto:[email protected]] On Behalf Of > [email protected] > Sent: 08 December 1999 22:13 > To: [email protected]; [email protected] > Subject: Using RTTE directive before April 2000? > > > Listmembers: > > I have a question that perhaps some of you can help > me with. I'm developing > a regulatory compliance plan for a new telecom > product that is scheduled to > begin shipping in the first quarter of 2000. The > exact date is not certain, > but it is likely to be before the April 8, 2000 date > that appears in the > RTTE > directive. > > If possible, I would like to avoid the whole > notified body route called out > by the current directive 98/13/EC, especially since > it would only be > required > for the brief period until April 2000. > > I seem to recall that a new directive can be used as > soon as *any* member > state has transposed it into national law. If so, > this suggests that the > RTTE directive could be used prior to April 2000 if > at least one member > state > has transposed it into national law. > > In the case of the UK, however, recent postings on > the emc-pstc listserver > indicate that the draft legislation for the UK calls > out an effective date > of > April 8, 2000. In other words, even if the UK > transposes the directive > prior > to April 2000, the national law itself will call out > an effective date of > April 8. I do not know what the other member states > are planning to do. > > So, am I stuck with using directive 98/13/EC and the > notified body route if > the product ships prior to April 8, 2000? > > > Joe Randolph > Telecom Design Consultant > Randolph Telecom, Inc. > > --------- > This message is coming from the emc-pstc discussion > list. > To cancel your subscription, send mail to > [email protected] > with the single line: "unsubscribe emc-pstc" > (without the > quotes). For help, send mail to [email protected], > [email protected], [email protected], or > [email protected] (the list > administrators). > > > > > --------- > This message is coming from the emc-pstc discussion > list. > To cancel your subscription, send mail to > [email protected] > with the single line: "unsubscribe emc-pstc" > (without the > quotes). For help, send mail to [email protected], > [email protected], [email protected], or > [email protected] (the list > administrators). > > > __________________________________________________ Do You Yahoo!? Thousands of Stores. Millions of Products. All in one place. Yahoo! Shopping: http://shopping.yahoo.com --------- This message is coming from the emc-pstc discussion list. To cancel your subscription, send mail to [email protected] with the single line: "unsubscribe emc-pstc" (without the quotes). For help, send mail to [email protected], [email protected], [email protected], or [email protected] (the list administrators).
