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.