TÜV SÜD Webinar: The European Radio Equipment Directive 2014/53/EU Questions & Answers

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Frederick Patrick
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TÜV SÜD Webinar: The European Radio Equipment Directive 2014/53/EU Questions & Answers Questions From which date exactly will this Directive be in power?

1 TÜV SÜD Webinar: The European Radio Equipment Directive 2014/53/EU Questions & Answers Questions From which date exactly will this Directive be in power? Answers Member States must publish and apply the Radio equipment Directive in national law by 12 June Member States must apply the Directive requirements from 13 June Will existing products already assessed under the R&TTE Directive need to be re-certified under the RED when it comes into force? Is a list of harmonised frequency bands readily available? Are GPS receivers included in the minimum performance level tests? Do passive transponders fall into the scope of the RED? So, items of radio equipment placed on the European market after 13 June 2016 must comply with the new Directive. However, radio equipment compliant with the current R&TTE Directive before 13 June 2016 may continue to be placed on the market until 13 June Radio equipment compliant with the current R&TTE Directive before 13 June 2016 may continue to be placed on the market until 13 June From 13 June 2017, such equipment would need to be compliant with the Radio Equipment Directive (RED). However, this does not necessarily mean retesting. An assessment would need to be made whether previous technical documentation provided compliance with the essential requirements of the RED, and the supporting documentation ( e.g. User Manuals, DoC, Labelling) provided compliance with the appropriate requirements of the RED The European Communications Office (ECO) provides a tool to investigate the harmonised radio spectrum use in Europe called ECO Frequency Information System (EFIS) (see The national radio spectrum authorities are required to enter and maintain their national spectrum allocation data in EFIS. Please see ECC Decision 01(03). GPS receivers are within the scope of both the current R&TTE Directive and the forthcoming Radio Equipment Directive and, as such, one of the appropriate conformity assessment procedures must be carried out to verify compliance with the essential requirements. I assume you mean devices similar to those used for RFID; readers (including terminals, interrogators) and transponders (including tags, contactless cards and similar devices) all fall within the definition of "radio equipment and must be assessed against the essential requirements of the Radio Equipment Directive.

2 Are products containing an approved GPS module within the scope of the RED? Does the requirement for common chargers apply only to mobile phones? Would a professional TV broadcast receiver that connects to a third party satellite dish fall under the RED? Will a guideline for RED usage or separate EU/EN document be released by ETSI or other organisation? Is there any special guidance about prototypes, evaluation samples or toolkits for integrators/oem? For a low power radio transmitting device that meets the harmonised standards, what is the procedure? Do we have to consult a notified body or can we still self-declare? When a radio module is integrated into a host product, the host product becomes radio equipment and the person integrating the module becomes the manufacturer of the final product and is responsible for demonstrating compliance of the product with the essential requirements of the RED (a similar situation to the R&TTE Directive for GPS modules). Article 3.3(a) says radio equipment interworks with accessories, in particular with common chargers. However, Recital 12 says mobile phones that are made available on the market should be compatible with a common charger and Article 47 requires the Commission to review the RED operation to ensure that portable radio equipment interworks with accessories, in particular with common chargers. So the main target for this requirement appears to be mobile phones. A professional TV broadcast receiver would fall within the definition of radio equipment in its own right and be subject to the RED. A satellite system would also fall within the definition of radio equipment and be subject to the RED. There is a revised European Commission Blue Guide now available which follows very much the same structure and presentation as the previous "Blue Book", but includes new chapters, such as the responsibility of economic operators or accreditation, for example, or completely revised chapters such as that on market surveillance. At present we are not aware of any planned Guide to the RED from either an interest group or from the UK Government. Custom-built evaluation kits destined for professionals to be used solely at research and development facilities for such purposes are outside of the scope of the RED. Please see Annex I of the RED. For radio equipment for which the manufacturer has applied appropriate OJ listed RED harmonised standards in full to demonstrate compliance with the essential requirements, the conformity assessment procedures of Annex II, Annex III or Annex IV can be applied, at the choice of the manufacturer. If you have applied appropriate OJ listed RED harmonised standards in full to demonstrate compliance with the essential requirements, then you can use the conformity assessment procedure of Annex II (Internal Production Control) without involving a Notified Body.

3 Is there a central database of member states requirements for demonstration of precertification products? Will it be possible to test to Annex 3 of RED prior to 2016 so that there will not be a need to re-test or re-certify after 13/06/2017? If harmonised standards have been used for prior certification, can the manufacturer meet the new RED assessment requirements without resorting to testing by a 3rd party? Do all of these requirements apply to very short-range radio equipment that does not require licensing or registration? For example, communication with a GPS device in a vehicle. Does the notified body now have an obligation to report the outcome of the assessment to a database (fail/no fail)? Do RFID tags and receivers fall under the RED? What Directive would control for the DoC and compliance standards - RED, EMC or LVD? We are not aware of any plans for such a database. Since the main essential requirements have not changed, testing to harmonised standards listed against the R&TTE should be able to be used to support RED compliance. However, a new RED harmonised standards list may change some requirements. With respect to Certification it is expected that NBs will be able to assess equipment against the RED once they are listed with the commission under the RED. However the date when the Certificate becomes valid may be fixed to 13/6/2016 Yes, the earlier testing may be used provided the product remains unchanged, to support compliance. However, a new RED harmonised standards list may change some requirements. Where a client obtained a Notified Body Opinion under the R&TTE this may not be used as such under the RED. Yes. Where a Notified body refuses, restricts, suspends, or withdraws a Type Examination certificate we are required to advise our Notifying Authority ( Government Department). Where appropriate other Notified Bodies under the RED may also be advised. RFID readers (including terminals, interrogators) and transponders (including tags, contactless cards and similar devices) all fall within the definition of "radio equipment and must be assessed against the essential requirements of the Radio Equipment Directive. No Directive controls the DoC. A DoC would be required for all applicable Directives. In recent Directives there is a requirement for a Single Doc for all applicable Directives, which may be multipart addressing

4 individual directives. Older Directives still permit a separate DoC. For equipment within the scope of the RED, the appropriate harmonised standards listed under the RED in the Official Journal provide a presumption of conformity with the essential requirements of the RED. If equipment is tested at the customer s site in the design phase and is not available for sale, does it require compliance with the RED? Equipment within the scope of the RED is outside the scope of the EMC and LVD Directives so a product should not have DoCs to the EMC and LVD Directives if it falls within the RED. There are 2 separate issues making available on the market and putting into service. If the equipment is considered to be made available on the market, then all of the requirements of the RED apply, including CE marking. Products which are free issue or long-term Loan are considered to be Placed on the Market even if not formally sold. At the moment we have a product containing a GSM data modem and under the current legislation we have included the suppliers test data as part of our TCF. Will we be required to register and test our device regardless of the testing of the supplier of the selfcontained device or will this still be sufficient for conformity? Do you think low frequency (magnetic field) metal detectors and similar equipment would be in scope? How would RED be applied to GLONASS equipment (GLONASS similar to GPS)? The equipment must comply with the essential requirements of the RED when put into service. Equipment which incorporates radio modules is radio equipment and falls within the scope of the RED. The requirement to compile technical documentation, carry out an assessment against the essential requirements, and issue a DoC is very similar to the current R&TTE Directive. Registration will be dependent on whether the European Commission determines that a particular type of radio equipment requires registration. If the equipment falls within the definition of radio equipment and is not excluded by Article 1, then it is within the scope of the RED. The key factors are Radiocommunication and Radiodetermination. GLONASS receiver equipment is within the scope of the RED (and is also within the scope of the current R&TTE Directive). If the manufacturer has applied appropriate OJ listed RED harmonised standards in full to demonstrate compliance with the essential requirements, the RED conformity assessment

5 procedures of Annex II, Annex III or Annex IV can be applied, at the choice of the manufacturer. Am I correct that now line telephones are out of RED? If yes, how will DECT phones be assessed? Is after-market sales ESA still in the RED s scope (it is a radio device)? If we use test software during type approval to harmonised standards (because the test software is more controllable), can we still then sell our product with the customer software? For our 2.4GHz WLAN radios we have a statement on the packaging Suitable for the following markets Is this statement still applicable? The exception is GLONASS/GPS/Galileo equipment, which comes under the Marine Equipment Directive. For such equipment the RED does not apply but the Harmonised Standards and Compliance routes from the MED apply. Yes, wireline telephones are outside of the scope of the RED. However, DECT phones fall within the definition of radio equipment and are within the scope of THE RED. If the equipment falls within the definition of radio equipment and is not excluded by Article 1, then it is within the scope of the RED. The combination of radio equipment and software made available on the market must comply with the essential requirements of the RED. The technical documentation should provide evidence of this. The European Commission may also invoke under Article 3.3: radio equipment supports certain features in order to ensure that software can only be loaded into the radio equipment where the compliance of the combination of the radio equipment and software has been demonstrated 2.4 GHz WLAN devices previously required the Alert Symbol as a Class 2 device due to restricted use in France for wideband data devices up to 100 mw allowing indoor use only (and restriction details on the packaging). From 1st July 2012, the restriction was removed. We manufacture consumer DAB/FM radios. Will these now fall under the RED scope? If so, would there be any additional tests or do the current EMC and LVD Directives apply? Wideband Data Transmission Systems operating in the MHz frequency band are Class 1 (sub-class 22) equipment. As a result, there are no restrictions on the use of such 2.4GHz WLAN devices. DAB/FM radios fall within the definition of radio equipment and are within the scope of the RED. The tests required under the RED are dependent on what standards are invoked by the Official Journal listing of RED harmonised standards. DAB/FM radios must comply with the RED from 13 June If you have any further queries relating to the Radio Equipment Directive, you can contact this webinar s presenter, Les Rowland at Les.Rowland@tuv-sud.co.uk.

RADIO EQUIPMENT DIRECTIVE

RADIO EQUIPMENT DIRECTIVE Standardisation to support significant changes since RTTED Presented by Michael Sharpe for 53 shades of RE D workshop Radio Equipment Directive (RED) 2014/53/EU: OJ L153 22 May