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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