US-EU Mutual Recognition Agreement Workshop Report

June 2, 1999

With significant changes taking place in the area of telecommunications conformity assessment, there have been several meetings this spring to discuss the related issues. A series of meetings were held in Washington, DC on April 27-28, 1999 in conjunction with the workshop required by the US-EU Mutual Recognition Agreement.

Competent Body Proposal

The United States EMC and Telecom Sector will be making a proposal to the US-EU MRA joint committee to accelerate the transition period for EMC Conformity Assessment Bodies. The joint sectoral committee for Telecom and EMC, at its meeting on April 26, 1999, agreed to prepare a proposal to submit to the joint committee, which is responsible for carrying out the terms of the U.S.-EU mutual recognition agreement. The proposal is limited to accelerating the transition period for CABs operating under the sectoral annex for electromagnetic compatibility from 24 months to the time when the EMC CAB is accredited by the appropriate designating authority and recognized by the other party.

There are a number of U.S. labs currently evaluating equipment for compliance under the terms of the EMC Directive. This typically occurs under a contractual arrangement between the U.S. Lab and an EU Competent, which is ultimately responsible for signing the Technical Construction File under Article 10.2 of the EMC Directive.

Conversely, there are a number of EU labs currently performing measurements on equipment subject to Parts 15 and 18 of the FCC Rules. Until this portion of the MRA goes into effect, EU labs must submit the data for approval to the FCC or a US accredited lab under the FCC Declaration of Conformity procedure. (The FCC DoC procedure requires the manufacturer to declare compliance of a product based on a test report prepared by a laboratory accredited by A2LA, NVLAP or accrediting organization operating under the terms of an MRA.)

Since there appears to be competent CABs in the territories of both parties, the need for a transition period to build confidence is not required.

 

European Enforcement Activities

The R&TTE directive makes significant use of supplier declaration of conformity. Two critical elements to make this system work are product liability and enforcement by the member states. Dipl. -Ing. Gerd Jeromin, Head of the EMC Section of the Regulatory Authority for Telecommunications and Posts, Mainz reported on the enforcement activities currently taking place in Germany. Current enforcement is to the existing directives. In 1997 and 1998 the RegTP performed visual inspections on 40,000 equipment per year and conducted technical measurements on 1920 types of equipment per year.

 

Measurement Quantities per year

Equipment for industrial use

EN 50 081-2

100 units

Medical and scientific apparatus

EN 55 011

300 units

Domestic radio and TV receivers

EN 55 013

1000 units

Domestic appliances and household electronic equipment

EN 55 014

4300 units

Lights and fluorescent lamps

EN 55 015

400 units

IT equipment

EN 55 022

700 units

Telecommunications terminal equipment

EN 55 022

1200 units

Radio and TV network components

EN 50 083-2

1000 units

Radio transmitters

national standards

600 units

Results of Products tested in 1998

Products

Tested

Nonconform

Rate

Domestic Appliances

2218

238

11%

Electric tools

1322

326

25%

Lights, fluor. Lamps

601

212

35%

IT-Equipment

651

134

21%

Dom. Radio & TV Receivers

957

417

44%

TTE

631

67

11%

Mobile Radio Equipment

462

164

35%

Industrial Equipment

86

10

12%

Medical Devices

25

5

20%

Scientific Equipment

71

3

4%

TV Cable Network C.

131

13

10%

Components

0

0

0%

Total

7155

1589

22%

 

FCC TCB Program

The Federal Communications Commission program to create Telecommunication Certification Bodies (TCBs) is on track. An open forum was held on April 28, 1999 at the US Department of Commerce in Washington, DC to provide the public the opportunity to discuss the program. The industry working group which has been preparing comments on the TCB criteria completed their work and submitted their comments to the FCC on April 29, 1999. It is expected that the FCC will release the designation criteria shortly. The next step is to get the program started by conducting training for the accreditation assessors. The FCC along with industry are in the planning stages for this training. All indications are that the program will be up and running the first of next year.