I am curious to know how other companies that have radio equipment plan to
demonstrate compliance with the "health and safety" (code words for EMF)
requirements of the R&TTE.
Richard Woods
----------
From: Cynthia Pleach [SMTP:[email protected]]
Sent: Thursday, December 09, 1999 1:32 PM
To: 'Corinne SALINGRE'; [email protected]
Cc: [email protected]
Subject: RE: Using RTTE directive before April 2000?
The R&TTE does not reduce the amount of work needed, just eliminates
the need for a notified body to check the work, You still need to
conduct
tests to the same standards and you still need to have some type
of control over the maintenance of approval.
-----Original Message-----
From: Corinne SALINGRE [mailto:[email protected]]
Sent: Thursday, December 09, 1999 11:59 AM
To: [email protected]
Cc: [email protected]
Subject: Re: Using RTTE directive before April 2000?
Of course you are true.
I was saying that you have all the transition time (8 april 2000-7
april 2001) to change from TTE-SES into R&TTE. Normally it gives you time to
do the job !
And in most cases the R&TTE reduces the work to be done in the
formal approval process.
(but I guess we will have to do the work, but in a voluntary
compliance process, according to what our customers requires.)
[email protected] wrote:
Folks, you are forgetting that any product that is first placed on
the
market prior to April 8 can continue to be sold for an additional
year at
which time it must comply with the R&TTE procedures.
Richard Woods
----------
From: Corinne SALINGRE
[SMTP:[email protected]]
Sent: Thursday, December 09, 1999 5:13 AM
To: [email protected]
Cc: [email protected]
Subject: Re: Using RTTE directive before April 2000?
In the case of the R&TTE, the application date will be 8
april 2000
for all members states (not before, not after).
Some countries will have legislative problems to achieve the
transposition at that precise moment. However the Directive will be
applicable even in that cases (that can lead to nice questions on
how could
you break a law that has not yet been transposed in that country, or
how can
the market surveillance authority be designated in the absence of
the law
!).
In France also, the transposition into national law is said
to be
ready for 8 april.
In my opinion, if your product is to be introduce in very
early
2000, you will have better to use the TTE-SES directive approval
scheme and
plan to change it into R&TTE before 7 april 2001 .
And even if the R&TTE excludes some technical aspects (as
not being
essential requirements), my customers and the operators will still
require
these testings (preferrably done by external tests houses).
I feel that the only difference is the person whom these
tests are
essential for ! (notified body now and my customer after 8 april !)
[email protected] wrote:
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.
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