The European Union's New R&TTE Directive, So What’s Going to Change?

From 8th April 2000, Radio and Telecommunications Terminal Equipment (R&TTE) manufacturers will be able to use the new R&TTE Directive to demonstrate product compliance with relevant protection criteria.

From the point of view of the designer, the manufacturer and the compliance engineer, the questions that must be answered are:

• How do we make our equipment compliant now?

• How will we make our equipment compliant in the future?

• How do we achieve the above and yet minimize duplication of effort?

We can best answer these questions by exploring the similarities and differences between the existing Telecommunications Terminal Equipment (TTE) Directive and the up and coming R&TTE Directive.

Comparison Of Old and New Directives

The current TTE Directive contains measures that require assessment and licensing of equipment by one or more of the EC Notified Bodies, which exist in every Member State.

TTE must be designed to meet certain standards that break down into (what are known as) Essential Requirements for Product Safety and EMC plus Common Technical Requirements (CTRs) for telecom if available. National Telecom Regulations (NTRs) can be applied if no European standard has been written.

Today, TTE must be tested by an accredited laboratory, which must produce a test report that has to be assessed by a Notified Body. A license is awarded by the Notified Body once it is also satisfied that adequate provision has been made to assure ongoing compliance with the TTE Directive. This is achieved by certifying the manufacturing facility or by on going field product checks.

The manufacturer is required to generate a Declaration of Conformity document prior to CE marking the equipment. The ideal is to achieve one-stop testing and licensing in order to allow CE marking and the placing on the market of TTE throughout Europe.

The R&TTE Directive is - what is known as - a "New Approach Directive", meaning that it follows a more streamlined model of conformity assurance based on a "self- assessment system", followed up by some form of market surveillance.

The Directive requires that R&TTE be designed to meet only Essential Requirements based on relevant protection criteria. Telecom specific requirements will be minimized to cover only protection of the network from harm. Where required (particularly for radio equipment), additional harmonized standards will be published in the EU Official Journal to cover certain classes of apparatus. These will provide manufacturers with a basis for presumption of conformity.

Requirements exist within the Directive for Notified Body assessment and marking for certain classes of equipment, such as Radio Equipment using non-harmonized frequency bands. There is also provision for manufacturers to voluntarily submit for R&TTE assessment. Here there is little change from the types of procedures published in the old TTE Directive.

Network operators will now have to publish their interface specifications to enable manufacturers to design R&TTE that will function properly on the various European networks. Manufacturers will be able to choose the criteria to which they design their apparatus and also where they go to conduct testing.

By implication, manufacturers will still have to test their apparatus thoroughly to ensure a base level of compliance and will want to satisfy themselves that their equipment meets a minimum set of operational criteria in order to work in all the European Member States. This may best be achieved by staying with the existing published standards, which would ensure compliant operation on all of the various networks within Europe.

The manufacturer is still required to produce a Declaration of Conformity (listing the test criteria/standards and other evidence of conformity) to be used as the basis for CE marking, but it will no longer be necessary for Notified Bodies to issue a license for most classes of apparatus.

Technical Documentation

One new feature of the Directive is the requirement to produce a Technical File, which must contain full engineering detail of the R&TTE as well as details of test results, methods and standards, as evidence that the product complies with relevant criteria.

Previously, it has been necessary to compile an Approval Submission Document for scrutiny by the Notified Body. Up Front Assessment of the new type of Technical File is no longer required, but the dossier must be available for inspection.

It is foreseen that many manufacturers will be confused as to what the correct contents of such a file should be and whether it will withstand scrutiny and audit by a surveillance authority.

Ongoing Compliance

Ongoing compliance will now be assured by market surveillance; this in itself is quite a departure from the old Directive and brings R&TTE conformity assessment in line with that of other types of ITE which currently fall under the LVD and EMC Directives.

Market Surveillance is not new in Europe. For some time, Authorities in various Member States have been checking that product continues to comply with the LVD, EMC and TTE Directives. In some States, surveillance is pro-active and in others it is complaint driven.

Last year in Sweden, the National Electrical Safety Board carried out checks on 6000 items of apparatus and conducted tests on 400 products. A staggering 33% of the ITE tested failed to comply with the requirements of the EMC Directive.

The UK has operated a complaint driven surveillance program for ITE. During 1998, approximately 1000 items were checked; nearly 4% failed to meet the criteria of either the TTE or the EMC Directives.

In Holland, the statistics for TTE show that 7% of products tested failed to comply with published requirements.

Germany has been the most pro-active in pursuing surveillance, inspecting 40,000 products and testing 2000 product types per annum. 28% of ITE and 16% of TTE products tested failed to meet the criteria of the EMC Directive.

R&TTE Directive - So What’s Going To Change?