The
European Union's New R&TTE Directive 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: 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 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 presently 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 satisfied that the test results are compliant with the technical
regulations and adequate provision has been made to assure ongoing compliance with the TTE
Directive. This is achieved by certifying the manufacturing facility or by ongoing 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 1 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.2
These will provide manufacturers with a basis for presumption
of conformity. Requirements exist within the Directive for Notified Body
assessment and marking3 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.4 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,5 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 Sweden6, 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? From the
manufacturer’s point of view, it will still be necessary to: Design to criteria, if not to
standards. Produce and store a test report
and other essential product data to prove compliance. Declare Compliance and CE Mark
the equipment. Today, we have to do all of this under the TTE Directive,
but we also have to send the Technical File to the Notified Body for assessment. They will
only issue a license if the applicant submits to an up-front factory assessment or signs a
contract for product surveillance. In future there will be no assessment or licensing,
only surveillance by dedicated authorities. Manufacturers will still want to measure
themselves against a set of criteria, but these will be seen to have shifted from
regulatory standard to advisory technical specification. Such relaxation can remove from
the designer, the manufacturer and his compliance engineer a standard reference point by
which his quality can be judged. If the designer wishes, he can still use the previously
published standards as a datum point. It is foreseen that many manufacturers will want to avoid
the penalties of non-compliance7 by
‘playing safe’ and continue to test at a recognized laboratory thereby enabling
them to file evidence of compliance that will withstand external scrutiny. This will minimize duplication of effort, as it will
necessitate adherence to existing procedures but without the need to send in the Approval
Submission Documents (and filing fees) to a Notified Body unless their Equipment Class
demands it. Conclusion In most cases the change to the new
Directive brings with it a removal of up-front regulatory assessment and relaxes the need
to conform to published standards, but places responsibility upon the manufacturer to
demonstrate ongoing compliance. Therefore the big differences are in the reduced number
and type of requirements that must be met and the fact that less assessment and product
licensing will be undertaken by a fewer number of Notified Bodies. Market surveillance
will mean that the manufacturer must continually be seen to be compliant. 1 see Article 3 of the Directive <back> 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. Other Directives that affect us today and have contributed
to the new R&TTE Directive include the General Product Safety Directive 92/59/EEC, the
Satellite Earth Station (SES) Directive 93/97/EC (later combined with TTE to form
Directive 98/13/EC) and the Conformity Assessment Procedures and CE Marking Rules -
93/465/EEC and 93/68/EEC. 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. A copy of The R&TTE
directive may be downloaded at: http://www.patton-assoc.com/ 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 |