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. 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. 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). 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). 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. 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. 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. Pieter Robben Manager, location Niekerk of NMi Certin B.V. NB/CB for EMC, TTE, Radio and Low Voltage Dir. Tel: +31-594-505005 / 1-860-873-1454 (USA) Email: [email protected] / [email protected] (USA)
