Developments on the R&TTE Directive

You may think, by reading the title of this article, that you are about to learn some pearls of wisdom on developments with the Radio & Telecommunications Terminal Equipment (R&TTE) Directive. Sadly, the news is…there isn't much news!

By now, we were hoping to have received a steady stream of information to help us with the detailed workings of the R&TTE Directive. To date, very little has filtered through, therefore we shall have to work on what little data we have.

The facts are these:

  • The R&TTE Directive will come into force in April of next year, whether we are ready or not.
  • We are told that most types of equipment need only meet the Essential Requirements of the Directive which, at present, are limited to Safety and EMC.

Concern is being raised over the fact that there will be no Harmonized Standards published by the time the Directive comes into force. If we take as an example wired telecom terminal equipment and examine the ramifications of this fact:

PROBLEMS, PROBLEMS, PROBLEMS

The background to this present day concern is based on the fact that the Directive removes the need to comply with tomes of interface requirements and, instead, puts the onus on the network operators to release details of their interfaces, so that designers can design equipment to inter-work successfully with the PSTN.

In future, we will need to know full details of the telephony interface requirements to which terminal equipment must be designed in order to inter-operate with the European networks. For now, we are not as badly off as it seems because, at present, we have the Standards. However, we are told that the Standards, in the form of TBRs, are not going to be maintained by ETSI !

There will also be a need for manufacturers to come up with their own set of test specifications which will enable their designers to test their masterpieces to ensure optimum performance and hence minimal field returns. Add to this the continuing need for manufacturers to test their equipment against specified requirements at the final production stage, and the need to maintain standards is very apparent.

STANDARDS, STANDARDS, STANDARDS

As stated above, today we have the Standards, but if these are not to be maintained, then we are at the mercy of the network operators who can make specificational changes which will no longer be reflected in the Standards. If an effective way is not found to inform us all, then havoc will ensue.

Lack of standardization for telecom requirements under the R&TTE Directive will impact upon:

  • Quality
  • Recognition of quality product both within and outside the EU
  • Buyer confidence

It will also affect manufacturers’ liability and the liability of their EU representative who will be responsible for the documentation file that must be maintained to prove compliance with the new Directive. There is a question mark over what should be the content of the data held in this file and how much certified test data should be included.

Also in question is the sign off of the Declaration of Conformity, which has to list the standards with which the apparatus is compliant and point to where any certified test reports and data can be found.

QUALITY - PERCEIVED PITFALLS

There is general consternation amongst manufacturers that the new R&TTE Directive will open the floodgates for low quality product which would not have met compliance requirements under the old TTE Directive. CE marking does not signify certified quality when applied to products that are compliant with the new R&TTE Directive.

It is also perceived that market surveillance authorities will run into problems when attempting to trace manufactured product, especially if this product is OEM. Perhaps a self-regulating regime for quality, similar to that existing in the United States, needs to exist in Europe. If products were exposed to the threat of consumer watchdog checks for quality (such as those undertaken by organizations like J.D. Powers), it would be possible to elevate quality standards.

QUALITY OF SERVICE TEST PROGRAMME

A quality of service test programme could also elevate standards and protect the consumer. Such a programme would:

  • Test interworking capabilities with the PSTN or with associated PBX equipment.
  • Aid large customers who would be assured of quality.
  • Protect consumers.

If necessary, larger suppliers and retailers could align procurement requirements with Q of S test specifications.

CONCLUSION

In order to maintain Quality and Standards, manufacturers of R&TTE will need to:

  • Continue to test against existing standards (ENs, TBRs, etc.)
  • Lobby standards organizations to maintain PSTN interface requirements.
  • Develop internal design requirements based on:
  • Experience
  • Old/new standards
  • Published PTO (Carrier) specifications, if readily available.
  • Develop internal test specs based on:
  • Field test experience
  • Lab test results
  • Educate
  • Senior Management
  • Development staff
  • Customers

to recognize that compliance with Q of S or voluntary test programmes denotes superior Quality Product.

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.

For a summary of the R&TTE directive: http://www.patton-assoc.com/

A copy of The R&TTE directive may be downloaded at: http://www.patton-assoc.com/

History of Legislation. The legislation that has affected R&TTE emerged from different sciences and disciplines. The EC-wide Low Voltage Directive 73/23/EEC (1973) covered safety of all ITE. This Directive was eventually designated by all Member States to cover nationally approved TTE as well as EC-wide approved apparatus. Similarly, the EMC Directive 89/336/EEC replaced national legislation to cover all ITE and TTE. The TTE Directive 91/263/EEC (later to become 98/13/EC) currently covers approval of technically harmonized TTE.

 The full title of the R&TTE Directive is: Directive 1995/5/EC of the European Parliament and Council of 9th March 1999 on Radio Equipment and Telecommunications Terminal Equipment and the mutual recognition of their conformity.

Author biography – John Roche is Managing Director of Patton & Associates (UK) – the European office of Patton & Associates Inc. of Prescott Arizona. Patton & Associates provide Telecommunications Consulting, Design and Type Approval services for Europe, North America and The Pacific Rim.

John Roche can be reached at: roche@patton-assoc.com

Contact Patton & Associates: 

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Telephone: +01.520.771.2900