1. ACB Radio Equipment Directive Michael Derby ACB Europe9 April 2014

2. Introduction American Certification Body TCB, FCB, RCB, Notified Body Notified Body to the R&TTE Directive Michael Derby Regulatory Engineer, TCB, FCB, Notified Body Liaison: The TCB Council and the R&TTE CA

3. Change of Directives R&TTE Directive Applicable to Radio and Telecommunication Terminal Equipment 1999/5/EC Time for an update Radio Equipment Directive RE Directive Will replace the R&TTE Directive More than just alignment with the NLF

4. Agenda Agenda of presentation History of the RE Directive progress Proposed and expected text Emphasis on changes from R&TTE Directive Timeline

5. Radio Equipment Directive History of RE Directive progress Work began in 2007 (7 years!) Commission proposals sent to European Parliament in 2011/12 Comments were submitted Input from groups, including IMCO recently International Market and Consumer Protection Committee of the European Parliament

6. Radio Equipment Directive Compromise Text in January 2014 By the EU Council and EU Parliament Vote by European Parliament 13 March 2014 Document accepted by European Parliament Approval from EU Council of Ministers Hopefully all will be ok They agreed to the compromise text

7. Radio Equipment Directive Translation into all languages and text check Final text published Q3 at the earliest, I think Directive effective 20 days after publishing Manufacturer ‘could’ DoC to RE D then Formally at least one MS into National Law Transition period of 2 years Can use R&TTE D or RE D Until approximate Q3/Q4 of 2016

8. Radio Equipment Directive Main points of interest that are expected to be in the RE Directive Many of these taken from the IMCO text Some were already known Of course we cannot guarantee anything until the final RE Directive is published.....but, we are quite confident that the following items have been accepted

9. Radio Equipment Directive No more telecommunication terminal As the name change suggests, R&TTE has become RE Telecommunication Terminal equipment removed from the Directive Therefore EMCD and LVD will apply to telecom Examples are wired telephones, fax machines, etc. RE Directive only applies to wireless/radio

10. Radio Equipment Directive Scope of radio transmission Scope will include radio communication and also radio determination Definition of ‘determination’ used to clarify that equipment such as radar, RFID, movement detection, velocity measurement, etc. are in scope Equipment which is not for communication or determination is out of RE Directive scope For example, ISM, EN 55011, CISPR 11, etc. (Part 18!)

11. Radio Equipment Directive Scope of radio reception Receive only radio equipment is still in scope There had been talk of removing it Broadcast receivers are in scope They were specifically excluded from R&TTE D There may be a longer transition period for broadcast receivers These will therefore no longer be in the scope of EMCD and LVD LVD exclusion important for low voltage devices

12. Radio Equipment Directive Text of RE Directive scope Expected scope of the new Directive may be: Radio Equipment… …an electrical or electronic product, which intentionally emits and/or receives radio waves for the purpose of radio communication and/or radio determination, or an electrical or electronic product which must be completed with an accessory, such as antenna, so as to intentionally emit and/or receive radio waves for the purpose of radio communication and/or radio determination

13. Radio Equipment Directive Frequency Range of RE Directive The frequency range of the R&TTE Directive is 9 kHz to 3000 GHz The frequency range of the RE Directive will be “up to 3000 GHz”, with no lower limit There are communications below 9 kHz These are now in scope ETSI and ECO have some work to do

14. Radio Equipment Directive Radio Equipment assessed must be able to operate in at least one EU Country Without this, it cannot have a CE Mark In the past, people obtained Notified Body opinions and CE Marked their devices to the R&TTE Directive, for non-European markets This will not be permitted under the RE Directive unless the device can actually operate in at least one EU Country (or CE Marking country)

15. Radio Equipment Directive Safety for animals If you read carefully, safety within the R&TTE Directive did include animals But it wasn’t clear to those who didn’t understand it To clarify, the RE Directive will specify The protection of the health and safety of persons, of domesticated animals and the protection of property, including the objectives with respect to safety requirements set out in Directive 2006/95/EC, but with no voltage limit

16. Radio Equipment Directive Clearer exclusions for equipment Some radio equipment are covered by more specific Directives for their type of operation Exclusion from the RE Directive for such devices will be expressed more clearly

17. Radio Equipment Directive Evaluation Kits Specifically for professionals to use in R&D facilities are excluded from the scope Encourage innovation and development Support R&D in Europe Other Directives do exempt these devices Remove confusion and uncertainties about this type of device with regard to Directives

18. Radio Equipment Directive Encourage better contact information Member States (MS) will encourage Economic Operators (EO) to include website addresses in addition to postal addresses Better communication between MS, MSA, EO and consumers MSA is Market Surveillance Authority Economic Operator could be a manufacturer, supplier, importer, etc.

19. Radio Equipment Directive Encourage better contact information Equipment must show identifying numbers and contact details for responsible party(ies) Contact name and details for a person must be supplied with each device On the device, or documentation for small devices Importers must show similar information Stick contact details to equipment or packaging Supply chain to accept legal responsibility

20. Radio Equipment Directive Codify requirements for universal chargers Presently, common/universal chargers are optional under industry MOUs Requirement in the directive for common or universal chargers For example, mobile phones, tablets, cameras, music players, etc. Desire is to reduce impact to the environment and inconvenience to consumers

21. Radio Equipment Directive Electronic labelling European Commission and many MSAs have not been in favour of electronic labelling Proposed text should allow electronic labelling for certain, appropriate types of equipment For example, equipment with an integral screen Other information may also be permitted electronically, such as model and contact points Devices without initial charge could have a removable label for shipping

22. Radio Equipment Directive No more Country Notifications for Class 2 Class 2 devices for use in non-harmonised frequency bands presently require Notification to each member state The proposal is to drop this requirement

23. Radio Equipment Directive No more Alert Symbol for Class 2 Class 2 devices must show the Alert Symbol to alert the user of a restriction of use This symbol will no longer be used Face it; who other than us knew what it meant?

24. Radio Equipment Directive No more CE Mark in the user manual Presently, the CE Mark must appear in the user manual The proposal is to drop this requirement

25. Radio Equipment Directive Notified Body “Certificate” The name of the Notified Body opinion will change to “Type Examination Certificate” Not to be confused with “Type Approval Certificate”, used in certification Directives It is a DoC Directive and the Notified Body role is still a reviewing role; not certification No more Negative Opinion; only a Certificate, or no Certificate Need a way to track ‘no certificate’

26. Radio Equipment Directive Notified Body Report To accompany the Notified Body Type Examination Certificate, the Notified Body will be required to supply a report to explain and justify the issuing of the certificate

27. Radio Equipment Directive Notified Body number on the product Presently the NB number appears on the label of the product for any NB involvement Identification of Essential Test Suites (Annex III) Review and Opinion (Annex IV) (most common) Full quality assurance (Annex V) Under the RE Directive, the NB number will only be on the label when the full quality assurance route (Annex V) is used

28. Radio Equipment Directive Mandatory use of Notified Body (non-HS) Presently any deviation from harmonised standards requires review and opinion from a Notified Body This was never the intention with the R&TTE D RE Directive will clarify that only deviation from radio (Article 3.2) standards will mandate the review of a Notified Body Although any/full review is always an option

29. Radio Equipment Directive Translations not required DoC must be available in each language There was a proposal to translate the whole TCF into each language This proposal has not been accepted

30. Radio Equipment Directive Registration It’s not in, but it’s not completely out The RE Directive will include the possibility for the EU Commission to prescribe registration for specified products based on inadequate compliance Therefore, types of device which get onto the naughty list could prompt a registration system to be started and the hooks will be in place

31. Radio Equipment Directive Single DoC As expected from the NLF, all applicable Directives to be referenced on one DoC If necessary, it can be multiple pages In the case of multiple signatories, for example

32. Radio Equipment Directive Photograph on the DoC There was a proposal that all DoCs must contain a photo of the device Compromise is that if a photos is supplied, it must be in colour and of good quality

33. Radio Equipment Directive Manufacturer’s sample testing When appropriate, manufacturers will be required to perform their own sample testing, keep records of problems and inform others

34. Radio Equipment Directive Manufacturer providing information Manufacturers are obliged to cooperate with national authorities and provide any information requested by the authority

35. Radio Equipment Directive Good luck! Hopefully the final text will be out before the next TCB Council Workshop Anticipate detailed presentations at the workshop in October 2014

36. Questions? Contacts: michaeld@acbcert.com www.acbcert.com