"Packets" - Regulatory Updates for the
R&TTECA – Notified Body group for the R&TTE Directive
(Report from semi-annual meeting in Prague, Czech Republic)
own Michael Derby, well- ensconced in
Winchester, England and well- connected to the European
Regulatory Scene provides this PACKETS' update on matters of
Michael performs reviews of RF
devices for compliance with FCC, Industry Canada and CE
Marking requirements. He provides training and will be
coming to Boston in September to participate in the
Washington Laboratories Academy Training Program, September
22 and 23.
You can also meet Michael and hear him presenting about the
R&TTE Directive at this year’s EMC UK Exhibition, 12th and
13th of October.
For more details or clarifications, please
contact Michael Derby.
A new version of REC 70-03 has
been released. This is a critical document that lays out the
frequency band and power limits for short range devices
(SRDs) to be placed on the European Market. It can be found
at the ACB web site.
Read REC 7003 to view and/or download.
The New R&TTE Directive:
Wherefore Art Thou?
The New R&TTED was hoped for 2010
but now looks like 2011 (late 2011). The new Directive will
most likely have a new directive number and no longer be
1999/5/EC, so manufacturers' DoCs will need to
change. It will still follow the 'DoC' approach but
it will implement the New Legislative Framework
(NLF) and terminology will change.
Several working groups have been
established at the European Commission with various
assignments. This is a summary of the WG's tasks and
progress. Read about EU workgroups
We discussed a possible loophole in assessments of radio
transmitters. An installation (such as a building) is
required to meet the EMC Directive using good engineering
practice and it is required to not cause interference.
However, the building or installation does not need to be
specifically CE Marked under the EMC Directive. Radio
apparatus are specifically addressed in the R&TTE Directive. Read about installation loopholes
CISPR 32 and CISPR 35:
(Multimedia Equipment, Emissions) and CISPR 35 (Multimedia
Equipment, Immunity) standards are in progress. CISPR 32 is
due out soon. There is less progress with CISPR 35 but it
will be with us.
An amendment is expected,
to clarify average emissions measurements above 1 GHz. Also,
clarifications on the requirement Read about CISPR 22
Proposed Requirements for
Renewable Energy Sources
The committee is considering the
requirements for equipment that 'gather' power and convert
it to AC and supply it back to the mains, such as solar
panels and wind turbines.
ErP and ErP Directives:
The EuP and ErP Directives were
suggested as business opportunities for test labs who would
like to expand their scopes.
Not many labs are involved in
these requirements but Read about ErP directives
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Special Updates from The Espresso Engineering
team at the 2010 EMC Symposium
It's almost like being there, except for the sun and
sand. Join Coco Bean and the rest of the crew in Sunny Fort
ATCB & Washington Labs team to present Radio
Approvals Workshop. September 22-23. Boston, MA
Join ATCB experts Dennis Ward and Michael Derby for a
comprehensive overview of methods and requirements for FCC,
IC and EU Radio Regulations. This seminar will cover the
testing, evaluation and certification requirements for
commercial equipment with demands for EMC compliance.
Specific focus on radio regulations compliance for products
bound for global markets.
Visit Washington Laboratories
Confused about China? Befuddled over Brazil? Hungry for Hong Kong?
Our International Approvals team is ready to assist! With a
team that spans 24 time zones, we can get that critical
approval you need to ship your device. With offices in North
America, China, Taiwan and the UK, we can get the access you
The Value of Independent Testing
American Council of Independent Labs (ACIL) has just
completed its first-in-a-series view of the Role of
Watch it on Espresso Engineering
our business, standards are everything.
If it weren’t for standards, chaos would ensue. Hence, it
is of prime importance that we observe certain cornerstones
of societal well-being. Standards should be referenced often
and certain minimums upheld, as detailed
Read about Martini Standard.
Although this standard is
over 40 years old, timeless principles still apply - one being
that British brands hold sway in our Global Village.
The New R&TTE Directive: Wherefore Art Thou?
The New R&TTED was hoped for 2010 but now looks like 2011 (late
2011). The new Directive will most likely have a new directive
number and no longer be 1999/5/EC, so manufacturers’ DoCs
will need to change. It will still follow the ‘DoC’
approach but it will implement the New Legislative Framework
(NLF) and terminology will change.
Several working groups have been established at the European
Commission with various assignments. This is a summary of the WG’s
tasks and progress.
All Directives must align with the New Legislative
Framework (January 2010). As the R&TTE Directive is being
re-written, it is important to ensure the new version complies with
the NLF requirements. (Examples include: Cross border
communication with regard to market surveillance and accreditation
of assessment bodies, referring to the examination and documentation
process as a “Type Examination Certificate” instead of a “Notified
Body Opinion”, correct application of the CE Mark and Notified Body
number, etc. No more annexes, modules instead)
The NLF will have a fairly wide-ranging effect as older
requirements are tweaked to comply with the NLF.
A problem exists with tracing the person who signs the
Declaration of Conformity (DoC). Several suggestions have been made,
including a registration system for manufacturers selling into
Europe. This working group is looking to find a solution to the
issue. Many manufacturers are strongly opposed to the registration
system and it has been a source of great debate over the last year.
Although the final answer is not yet known, it does seem that the
European Commission is beginning to feel it would not be the best
Working to find a way to improve the ‘Class 1’ and ‘Class 2’
system in Europe, often referred to as harmonised or non-harmonised
Looking at ways to help new and innovative equipment onto the
market. This is the main purpose of the Notified Body but there
are problems with the process because often it is felt that Notified
Bodies do not always have all the information relating to spectrum
use in each country.
If a device transmits a CW signal to charge a battery and there
is no communication, then it is excluded from the scope of the R&TTE
Directive. However, if it has some ‘handshaking’ with the device
being charged (to know what it is charging), then it is a radio
communications device and the R&TTE Directive applies.
In theory this may sound like no big deal. After all, it must
still demonstrate good EMC, safety and interference performance (no
different than if it followed the EMC and Safety Directives).
However, under the R&TTE Directive, it would need to consider
spectrum allocation and use of frequency bands. A manufacturer
would need to do country notifications for non-harmonised use of
bands, etc. , so the administrative overheads increase.
A suggestion has been made to exclude wireless chargers from the
R&TTE Directive and a list of ‘exclusion parameters’ were proposed
(for example, communication distance less than 10cm, low power,
etc.). However, many times have we seen exclusions written for one
piece of equipment and then been surprised at how technology
evolves. Think about how many times you have been in a meeting that
starts with the words: “When we wrote the document, we had no idea
that the technology would move in this direction”.
If we make the exclusion list too general, there could be
confusion. Could RFID then be excluded from the R&TTE Directive? How
about wireless chargers that can still charge at 11cm distance? Most
people agree that a solution is needed but any exclusion would need
to be clear, if it is to happen.
The debate rages on and a solution is not yet in sight!
The next meeting of the R&TTECA is planned for Portugal, in
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ECANB – Notified Body group for the EMC
We discussed a possible loophole in assessments of radio
transmitters. An installation (such as a building) is required to
meet the EMC Directive using good engineering practice and it is
required to not cause interference. However, the building or
installation does not need to be specifically CE Marked under the
EMC Directive. Radio apparatus are specifically addressed in the
R&TTE Directive. However, a radio transmitter which is integral to
the workings of an installation may be avoiding assessment. It may
not be assessed by the R&TTE Directive because it is not a radio
apparatus. It will need to meet the ‘good engineering’ requirements
of the EMC Directive but there are no spectrum allocation or band
assessment requirements in the EMC Directive. This loophole was
never intended and a solution is being considered.
The Digital Dividend
Perhaps the second biggest issue being discussed at EMC meetings
these days. Televisions are receiving digital signals and the
analogue TV bands are being auctioned off at good prices. It looks
like the 700/800 MHz bands will be used by LTE telecommunication
devices, which is great, however, the domestic TV receivers are
still open at those frequencies and have undergone no specific
testing to deal with immunity to LTE signals. The very real concern
is that soon we will have a network in Europe which interferes with
everyone’s television set (and it’s nearly time for the new season
of X-Factor!) There is a lack of definitive proof but most are
convinced that a problem is looming.
It could take years to create some tests and issue a harmonised
standard for television receivers to demonstrate immunity to
telecommunication signals at adjacent channels or within the
receiver operating band.
In the mean time, television manufacturers are encouraged to
investigate ways to deal with this potential interference. A
Notified Body should be cautious about issuing an opinion for a
television if the manufacturer or lab has not done ‘something’ to
show some immunity.
Power Line Communications (PLC)
Perhaps the biggest issue being discussed at EMC meetings these
days. PLC, Power Line Communication, Power Line Telecommunications
or Communication over power lines. Call it what you like, though
make sure you whisper. It comes under the EMC Directive and looks
likely to cause interference, especially to amateur radio users. The
concern is that the needs of the many will outweigh the needs of the
few. That may sound ok to some of you, except that the few have been
around for a lot longer than the many and, well, it’s not very fair
Military Equipment & the CE Marking
I attended a presentation about a clamping down on equipment being
‘exempt from the requirements’ because they are considered military
equipment. (In fact, they are not specifically ‘excluded’, they are
just not specifically ‘included’) It seems that many people use the
military excuse to avoid the CE Marking requirements. There’s an old
saying regarding regulatory compliance: “Just paint it green and you
don’t have to do anything”
It seems many things were getting by without a CE Mark in this way.
This is not to say that no testing or evaluation was being
performed, just not the CE Marking requirements.
A tightening up of the requirements was discussed. In particular,
the group discussed the classification of devices as ‘munitions of
war’. If an electric hand dryer is intended to be used in Army
barracks, is that really classified as munitions of war? This topic
is provided as guidance only at this time.
My favourite quote on the subject came from the Netherlands, with
words to this effect: ‘If you drop a nuclear bomb on Amsterdam, I
don’t expect it to have a CE Mark. However, if you put a tank on a
military truck and drive it down my freeways in peacetime, I do
expect it to meet our automotive requirements.’
Ultimately, military devices are tested, often rigorously, to
military standards. Manufacturers of military equipment may worry
about additional requirements on top of what they already do.
However, the addition of a few regulatory compliance tests may be a
drop in the ocean compared with the scope of their existing test
requirements. Also, they may be able to take their existing
assessment and use a technical documentation route to demonstrate
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Other Issues – Arising from other groups and meetings in Europe
NLF and Market Surveillance
The NLF has been implemented since January 2010. Each European
member state is to do market surveillance. Some countries have
picked a technology to focus on (for example: cellphones, domestic
electrical entertainment systems, etc.) but other member states may
focus on administrative issues such as correct CE Marking and
Products are often incorrectly labelled with a CE Mark which does
not meet the requirements of the Directives. This may be addressed
by some of the market surveillance work. It is important to remember
that an incorrect CE Mark is an infringement of the requirements of
the Directive. Consider the attached demonstration and you will
easily find incorrect CE Marks on devices:
EMCTLA (EMC Test Lab Association)
Michael attended a recent meeting of the EMC Test Lab Association
and jotted down a few Notes and Comments.
A NEW EMC DIRECTIVE in the Pipeline
The EMC Directive will need to be amended to align with the New
Legislative Framework (NLF). It is intended to keep the same
essential requirements and even to keep the same Directive number, 2004/108/EC.. For this reason, a manufacturer’s DoC
should not need to be amended to reference a new Directive number.
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CISPR 32 and CISPR 35:
CISPR 32 (Multimedia Equipment, Emissions) and CISPR 35 (Multimedia
Equipment, Immunity) standards are in progress. CISPR 32 is due out
soon. There is less progress with CISPR 35 but it will be with us in
An amendment is expected, to clarify average emissions measurements
above 1 GHz. Also, clarifications on the requirement for one
measurement only, for AC Emissions measurements on a cabinet with
one AC Mains input.
amendment is expected, to re-write and clarify the telecoms section.
The 2009 version is published with an amendment to include the
following main points: Group 1 and Group 2 equipment defined, where
Group 1 are ISM devices using RF for their operation or function,
whilst Group 2 devices generate RF only for their internal
functions. A Class C limit has been introduced for
higher power apparatus (most would have their own dedicated
Measurement Uncertainty A controversial change to
CISPR 11 will require a full assessment of measurement uncertainty.
If a lab’s measurement uncertainty is greater than the target value
in CISPR Pub 16-4-2, then the lab will have to ADD the uncertainty
value to a measured result! This means that a “pass” may become a
“fail” if the measurement uncertainty is greater than dictated by
for microwave ovens are moved from CISRP 11 to CISPR 14.
Regarding the tests of microwave ovens, the type or quality of the
pan holding the water can affect the results by amounts up to 20 dB
pr EN 50498: Automotive Accessories
A new standard for EMC testing, which applies to accessories for
vehicles is being drafted. This will complement the Automotive
Directive and can be used for ‘e Marking’ or ‘CE
Marking’ as appropriate, an after-market device for the automotive
Compliance With What?
There was a discussion regarding compliance statements in test
reports. There is a common text in CISPR standards that “non
compliance shall not be based on one unit only”, meaning that
you cannot state a device does not comply with the standard just
because one of them fails a test. You should test at least 3 to
ascertain compliance with a standard. The same applies to complying
with the standard.
Clearly, people do not test 3 devices, so test labs ‘should’ just
state that a device complies with the limits, not that it complies
with the standard. Fine points, for sure, but personally I think
manufacturers will want to see a statement that they comply with the
standard, not just with the limits.
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BE GREEN AND ENJOY EMC, TOO
Proposed Requirements for Renewable Energy Sources
Consideration is being given to the requirements for equipment that
‘gather’ power and convert it to AC and supply it back to the mains,
such as solar panels and wind turbines.
ErP and ErP Directives: Opportunities?
The ErP Directive (formerly EuP Directive) was suggested as business
opportunities for test labs who would like to expand their scopes.
Not many labs are involved in these requirements but they are CE
EuP is the original version, for Energy Using Products. ErP is the
replacement for Energy Related Products. (Good examples of the
difference could be ‘double glazing windows’ or ‘efficient shower
heads’. These do not use power but they are related to energy use,
so they would be included in ErP but not EuP).
The focus of these Directives is to reduce the use of power during
the life of a product. Most manufacturers apply standards to
demonstrate compliance, though there are very few published
standards and this will be a difficult Directive to monitor and
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