Last week, MET Labs attended the FCC Telecommunication Certification Body (TCB) Council TCB Workshop in Baltimore.  Here was the agenda.  

One of the workshop’s more interesting presentations was on the R&TTE Directive.  Following is a summary of the key points.

The Radio and Telecommunication Terminal Equipment Directive applies in Europe and the European Economic Area.

There is no certification for the R&TTE Directive 1999/5/EC.  Meeting the requirements is the responsibility of the manufacturer or whoever puts the device on the market.

  • Products must have CE mark to show compliance
  • Declaration of Conformity (DoC) must be created for each device
  • Technical Construction File (TCF) is necessary to demonstrate compliance

The CE mark must be visible on the label, user manual, and packaging, and must include the Notified Body and Alert Symbol, if applicable.

The DoC must be available in each language, and must be traceable to a signatory.

The TCF must be kept for at least 10 years after the final version of each device has been made.

R&TTE Directive does not give test limits.  It instructs the manufacturer that the device must comply with certain performance requirements:

  • Article 3.1a – Health (RF exposure; boundary calculations; acoustic safety; typical operation)
  • Article 3.1a – Safety (EN 60950 for IT equipment; EN 60065 for Audio/Video equipment)
  • Article 3.1b – EMC Performance (EN 301 489 series for radio; EN 55022 & EN 55024 for TTE)
  • Article 3.2 – Radio Spectrum (output power; frequency tolerance; spurious emissions; receiver performance tests; tests at extreme voltage/temperature)

R&TTE Directive divides products into two classes:

  • Class 1 – No restrictions on putting the device into service
  • Class 2 – Restrictions exist for use of the device, and Country Notifications may be necessary

Ideally, all devices fall within an existing harmonized (harmonised) test standard.  If you test to a harmonized standard and pass, there is a presumption of conformity to the essential technical requirements.

Harmonized standards are listed by the European Commission in its Official Journal (OJ).   

When a standard is superseded, the device should meet the new version of the standard to stay compliant.  There is an overlap period.

A Notified Body opinion is required if harmonized standards are not fully applied in these situations:

  • Device has new technology with no applicable standards yet
  • New standards are not yet harmonized
  • Family of products, where the standard has not been applied to some models
  • Test procedures or processes of the harmonized standard were not followed

If the technology is new and no harmonized standards exist, the manufacturer works with a Notified Body – like MET Laboratories – to determine a test plan, or parts of another standard to use.  Alternatively, use a new version of a standard which has not yet become harmonized.

For most Radio and Telecommunication Terminal devices, the R&TTE Directive alone is sufficient – the EMC and Safety (Low Voltage) Directives do not apply.

R&TTE Directive was written in 1999.  The new version of the directive is being written now, with these goals in mind:

  • Improve traceability to DoC signatory
  • Improve compliance rates
  • Improve process for dealing with non-compliant products
  • Maintain equipment quality
  • Maintain trade

The next TCB event is a FCC/TCB Conference Call on December 13.  The call is restricted to TCB personnel, but Associate Members can receive the call minutes.

Find out more about compliance with the R&TTE Directive.

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