R&TTE DIRECTIVE A Realistic Approach for Radio Equipment

Since then things have greatly improved, ETSI have seriously got their act together, with many specifications having now been published, although quite a lot are still awaiting citation in OJEC (Official Journal of the European Communities). In general for transmitting equipment, the original radio type approval specification has been re-issued with a - 1 reference (e.g. ETSI EN 300 220-1), with a -2 or -3 document giving the 'essential test suites' that must be applied (e.g. ETSI EN 300 220-3). This means that the number of tests required has been reduced, and those tests can be made either in-house, or by a third party. The test facility used does not need UKAS approval, although traceability to national standards, and the use of a suitable quality standard (e.g. BS EN ISO 9001), are desirable to show 'due diligence'.

Once relevant standards are referenced in OJ, then a 'Self Declaration', can be made. In the last few months a great many of the standards have been published, and citation of a large block of these, is expected some time in December 2000.

One of the principal reasons for the introduction of the directive, is to encourage innovation, thus allowing a shorter time between design and market. This degree of de-regulation, has not been accepted in all quarters. An attempt to keep things much as they were in the old 'type approval' testing days, was the introduction of the 'Radiomark'. This has not been looked on favourably by all those within the European Commission. A number of manufacturers and notably the LPRA (Low Power Radio Association) have signed up to it. It does however, they say, offer a voluntary third party certification service, enabling manufacturers to supply products of assured radio performance quality. It is expected that compliance to the directive, will be self regulating, in much the same way as the EMC directive, with the licensing authority (Radio Communications Agency in the UK) having the powers of enforcement.

The next important date of the 8th April 2001 is approaching fast. By this date products MUST be compliant. This equally applies to all older equipment that was originally type approved as well as new. All old 'type approvals' must be converted to an R&TTE declaration to allow equipment to continue to be sold. The Notified bodies are generally applying a conversion either free of charge or at a fixed rate.

It should be noted that the R&TTE directive encompasses the protection requirements of both the EMC and LVD (low voltage directive) with the LVD applying to all equipment, not just that apparatus above 50V. To show EMC compliance, it is appropriate to test to published standards. A whole new range of EMC standards are numbered ETSI EN 301 489-*. With the final part number referring to a specific group of products (e.g. ETSI EN 301 489-9 being Wireless Microphones). These have all recently been published, but are again awaiting citation in OJ during December. In the mean time however existing published standard can be used (e.g. EN 300 683).

EMC Standards for Radio Equipment under the R&TTE Directive ETSI EN 301 489
Ref.	Title	Publication Date
1	Common technical requirements	August 2000
2	Paging equipment	August 2000
3	Short Range Devices	August 2000
4	Fixed radio links	August 2000
5	Private Mobile Radio	August 2000
6	DECT	September 2000
7	GSM Mobile	September 2000
8	GSM Base	September 2000
9	Wireless Microphones	September 2000
10	CT2	September 2000
11	VHF FM Broadcast transmitters	Dates TBA
12	Satellite Earth stations	September 2000
13	CB Radio	September 2000
15	Amateur Radio	September 2000
16	Analogue Cellular Radio	September 2000
17	WLAN & HIPERLAN	September 2000
18	TETRA	September 2000
19	Receive only Satellite Earth Stations	Dates TBA
20	S-PCN	Dates TBA
22	VHF Aeronautical Radio	Dates TBA

One slight anomaly is commercial amateur radio equipment. In this case, there has previously been, no type approval tests required. There has however been a requirement to meet the EMC directive and to CE mark the product. This has generally been accomplished by the self declaration route to ETS 300 684 1997, following referencing in OJ in January 1999.

ETS 300 684 was an unusual EMC standard, in that it crossed the barrier into radio tests that were generally only included in type approval specifications, though with much looser limits. This has now been replaced, by one standard covering radio tests, and one covering EMC. These are: ETSI EN 301 783-1 for radio tests, with ETSI EN 301 783-2 stating which parts of 783-1 must be applied under article 3.2 of the R&TTE Directive. ETSI EN 301 489-15 for amateur EMC, referencing ETSI EN 301 489-1. Fortunately the radiated and conducted emission limits in ETSI EN 301 782-1 are essentially the same as EN 300 684. Therefore where complete test results to EN 300 684 exist, it may be only a paper-work exercise to comply with R&TTE Directive.

Radio equipment comes under class 2 of the directive, which means that countries can apply restrictions on the placing on the market of these products. Therefore it will be necessary to inform the licensing authority (RA in the UK), that the equipment is being placed on the market, at least four weeks in advance.

In theory, if the equipment operates on frequency bands harmonised across Europe, the equipment need only be marked with the CE mark, and a copy of the 'Declaration of Conformity' supplied. At present there doesn't appear to be any completely harmonised bands. Therefore it is necessary to use the alert mark, 'CE!' and put the limitations of use in the handbook.

As well as keeping a copy of the DOC, the manufacturer must keep a technical file, to include a description, design and manufacturing drawings with explanation, a list of standards applied, the results and test reports. Also a manufacturer 'must take all means necessary in order that the manufacturing process ensures compliance of the manufactured products with the technical documentation'. Again following a suitable quality system would be appropriate.

It is useful to keep the essential requirements of the directive in mind. These are:-

1. Protection of the health and safety of the public (including the operator)
2. The protection requirement with respect to EMC
3. Effective use of the radio spectrum, to avoid harmful interference.

To keep up to date with the latest standards situation visit the ETSI web site http://www.etsi.org.

Roger Ray is Technical Director of RN Electronics Ltd, a Wireless Design & EMC Test Facility. Email: roger@rfdesign.co.uk URL: www.rnelectronics.com

EMC Journal Home

---

© Nutwood UK Ltd 2001	Eddystone Court - De Lank Lane St Breward - BODMIN - PL30 4NQ Tel: +44 (0)1208 851530 - Fax: +44 (0)1208 850871 nutwooduk@nutwood.eu.com