Pieter Interesting points but I still disagree. See my responses below:
---------- Original message from Pieter Robben ---------- > Since there seems to be some confusion about my statements regarding > the issue of a European approval for the PSTN access part of a DECT > fixed part based on CTR21 I feel that it is best to present a "case study" > regarding the original question of Mark Lawson as an attempt to clarify > some issues. > > Case: > > A manufacturer contacts a Notified Body with the following question: I want > to sell a DECT fixed part in Europe. What requirements are there, apart from > EMC and LVD requirements, in order to enable me to sell it ? > > Question 1: Which directive would be applicable ? > > Answer: The TTE and SES directive 98/13/EEC is applicable to this type of > equipment. No disagreement here. > Question 2: What CTR's and or standards must be used in order to prove > compliance with the requirements of the directive 98/13/EEC ? > > Answer: When looking at the list of CTR's/TBR's related to the TTE and SES > directive one would choose TBR6, TBR10 and TBR22 since these specifically > address DECT. Agreed, except as I stated in my previous email CTR21 would also apply (see below). > Question 3: Do these standards also fully cover the requirements regarding > the connection to a PSTN in European countries ? > > Answer: No, there may be national requirements in each country of the EC > which are applicable to a DECT fixed part as stated in the TBR10 standard > (Where the DECT FP is connected to a PSTN, and there are any national > peculiarities in the requirements for voice telephony, these shall be > acommodated within the FP). Answer: YES. National requirements for voice telephony have now been replaced by CTR38. (see my response to question 5) > Question 4: Is it possible to issue a valid European approval, including the > approval for the connection to a PSTN in European countries, which would > enable me to sell the DECT fixed part throughout Europe without applying for > approval at the national authorities in those countries ? > > Answer: No, because of the reason mentioned in the answer on question 3 > (there may be specific national requirements for the connection to the PSTN). Answer: YES. (again see my response to question 5) > Question 5: Which requirement regarding the connection to a PSTN of a DECT > fixed part is applicable in, for instance, the Netherlands ? > > Answer: The requirement is T11-13 which specifically addresses DECT > equipment. These are national requirements based on TBR21 with additional > tests defined. The part you have to comply with is Part D, Voice facility > requirements, section 3.5 (Cordless telephones, Digital Enhanced Cordless > Telephone DECT). An approval, valid for the Netherlands, can be issued when > there is proven compliance with the T11-13, TBR6, TBR10, TBR22, EMC directive > and LVD directive. Here's where your argument falls down. The introduction to Part D of T11-13 states: "This part of the NL-Technical requirements contains the voice facility requirements for voice telephony such as handset telephones, hands free telephones, cordless telephones, etc., which are intended to be connected directly to the PSTN ....." It continues: "..... In the mean time ETSI has started work on the voice facility standard for pan-European Regulation for analogue handset TE." [i.e. CTR38] "As soon as this regulation is set into force, this will apply for handset telephones and will become the basis for the voice facility requirements for the other types of voice telephony TE." Since CTR38 has been in force since last October, the above reference from T11-13 implies that CTR38 now takes precedence. And as explained in my previous email, TBR38 excludes (amongst other things) handsets which employ a radio link. Since they are excluded from TBR38 then these types of TE are NOT capable of supporting the voice telephony justified case and so are NOT excluded from TBR21. Remember that these products still support the DECT telephony justified case between the handset and the PCM digital interface, but TE which supports the DECT telephony justified case is not excluded from the scope of TBR21. > Question 6: Is this procedure the same in other countries of the EC ? > > Answer: Yes. The issue of an approval for a DECT fixed part is based on > proven compliance with the TBR6, TBR10, TBR22, EMC directive, LVD directive > and the applicable national regulation for DECT regarding the connection to a > PSTN. You have to apply for approval at each national authority in each > country of the EC. Since CTR38 applies in all Member States, manufacturers can currently choose to use this in preference to national PSTN voice regulations. From October this year ONLY CTR38 will be available since national regulations must be withdrawn by then. Therefore CTR21 can be used in all Member States for PSTN access for DECT (and all other products which are completely excluded from the scope of TBR38). > The main issue about the remark Mark Lawson made regarding the German > Notified body is that he was under the impression that the approval for the > DECT FP was valid as a European approval since CTR21 was used. Unfortuneatly, > for DECT there is no such thing as a European approval (for now), for the > moment there is still a national approval required. I can't comment on Mark's particular case since I haven't seen his certificates but I'm fairly confident he has a European approval based on CTR21 since Germany still uses BAPT 223 ZV 5 (+ ZV 24) for national approval of voice products such as telephones. Many Notified Bodies currently subscribe to this way of thinking (including your competitors in The Netherlands) and are issuing perfectly legal European approvals for DECT products based on compliance with CTR6, 10, 21 and 22. > Pieter Robben > Manager, location Niekerk of NMi Certin B.V. > NB/CB for EMC, TTE, Radio and Low Voltage Dir. It's worth pointing out that there may be additional national requirements in some Member States if facilities like pulse dialling (which is outside the scope of CTR21) are intended for use in that particular country, however this would be in addition to the scenario described above. Finally Pieter, as Volkhard pointed out in his email, since the DECT FP and PP can be approved separately, there is no guarantee that the FP will be used with a voice PP at all since it may always be used with a GAP compliant data adaptor PP. Do you impose voice requirements on such a product? Regards ------------------------------ Ben Wrigley Senior Approvals Specialist KTL Saxon Way Priory Park West Hull HU13 9PB UK Phone: +44 (0)1482 801801 Fax: +44 (0)1482 801806 Mobile: +44 (0)802 280914 Web: http://www.ktl.com Email: mailto:[email protected]
