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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