Electrical and electronic equipment destined for marketing in the member countries of the European Union must comply with the Radio and Tele- communications Terminal Equipment (R&TTE) Directive, 1999/5/EEC.
The R&TTE Directive, whose authority commenced on April 8, 2000, signified a new approach to the legal aspects of marketing radio and telecommunication equipment in Europe. Because of its importance to any company that intends to sell short-range devices within the European community, we review below in some detail the major provisions of the Directive that particularly affect this category of equipment.
The aim of the Directive is stated in Article 1 as the establishment of
“a regulatory framework for the placing on the market, free movement and putting into service in the Community of radio equipment and tele- communications terminal equipment.” All technical specifications and characteristics of equipment falling under the scope of the Directive revolve around the following “essential requirements” and “addition,”
quoted below from Article 3.
1. The following essential requirements are applicable to all apparatus:
(a) the protection of the health and the safety of the user and any other person, including the objectives with respect to safety requirements contained in Directive 73/23/EEC, but with no voltage limit applying;
(b) the protection requirements with respect to electromagnetic compatibility contained in Directive 89/336/EEC.
2. In addition, radio equipment shall be so constructed that it effectively uses the spectrum allocated to terrestrial/space radio communication and orbital re- sources so as to avoid harmful interference.
The EMC Directive referred to in 1(b) itself specifies two essential requirements:
a) The device cannot interfere with radio or telecommunications equipment operation;
b) the device itself must be immune from electromagnetic disturbance due to sources such as RF transmitters and other equipment.
The requirements of the Directive are considered to be met if the equipment complies with harmonized R&TTE standards, when they exist, published periodically in the Official Journal of the European Union. As opposed to the approval regime that was in force previously, manufactur- ers do not apply to the communication authorities of the individual EU countries for authorization but they themselves bear full responsibility for meeting the requirements of the Directive.
The manufacturer, under the R&TTE Directive, is required to provide the user of his product with information about its use, and also a declara- tion of conformity with the essential requirements of the Directive. The product packaging and instructions must bear the CE mark, the number of the notified body that was consulted to get guidance on test requirements and meeting the essential requirements, and, if there are operating restric- tions because of use of nonharmonized frequency bands, an “alert sign”
consisting of an exclamation point contained within a circle. It shall also be identified by a serial number, or type or batch number, and the name of the manufacturer or the person responsible for placing the product on the market. When the alert sign is used, the manufacturer is responsible for notifying the states in the EU where operation of his product is restricted.
The manufacturer has a choice of several routes for demonstrating compliance with the requirements of the Directive. In the case of radio equipment, the procedures are specified in Annexes III, IV, and V, outlined below. When the manufacturer applies the harmonized standards that are appropriate to his product, he may choose any of the procedures in those Annexes. However, if he does not apply harmonized standards or applies them only in part, he can choose between following the procedures of Annexes IV or V.
Annex III
The manufacturer prepares technical documentation covering design, manufacture and operation of the product and including the following details:
■ A general description of the product, conceptual design and manu- facturing drawings and schemes of components, sub-assemblies, circuits, etc.,
■ Descriptions and explanations necessary for the understanding of said drawings and schemes and the operation of the product,
■ A list of the standards referred to in Article 5 (harmonized stan- dards), applied in full or in part, and descriptions and explanations of the solutions adopted to meet the essential requirements of the Directive where such standards referred to in Article 5 have not been applied or do not exist,
■ Results of design calculations made, examinations carried out, etc.,
■ Test reports.
The manufacturer performs the test suites specified by the relevant harmonized standards. If the test suites are not given in the standards, then he chooses a notified body to identify the test suites for him. Notified bodies are designated by national authorities responsible for telecommunication matters to perform certain tasks under the procedures of the Directive when the manufacturer does not apply harmonized standards in full. The manufacturer, or the person responsible for putting the goods on the market, declares that the tests were carried out and that the product com- plies with the essential requirements. Marking on the product includes the CE Mark and the number of the notified body, if consulted.
Annex IV
This procedure is similar to that of Annex III, but in addition, the manufacturer prepares a technical construction file (TCF) consisting of the documentation detailed under Annex III above along with a declaration of conformity to specific radio test suites. The TCF is presented to a notified body who gives an opinion on whether the requirements of the Directive are met. When placing the product on the market, the manufacturer in- cludes the number of the notified body after the CE mark on the device and packaging, as prescribed.
Annex V
The manufacturer operates an approved quality system for design, manufacture and final product inspection and testing which is subject to surveillance by a notified body. The notified body must assess whether the quality control system ensures conformity of the products with the requirements of the Directive in light of relevant documentation and test results supplied by the manufacturer. When placing his product on the market, the manufacturer includes the number of the notified body after the CE mark on the device and packaging, as prescribed.
It should be stressed that the R&TTE Directive regulates the putting of telecommunication, including wireless, devices on the market and allows their distribution generally throughout all European countries belonging to CEPT. However, operating characteristics, including frequency bands, maximum power output and duty cycle, for example, as well as licensing requirements, are still determined by the authorities of the individual countries. Thus, the manufacturer affixes the “alert sign” on his product when those characteristics are not fully harmonized and is responsible for indicating to the user where the device may be used. The ERO web site, listed in the “References and Bibliography” section should be referred to for up-to-date information on the degree of harmonization of transmission characteristics in the European countries.
As an example of the application of the R&TTE Directive, we’ll describe the relevant harmonized documents which are the basis of testing compliance in the case of unlicensed short-range devices. The harmonized document for the radio transmission characteristics is EN 300 220-3. This is part 3 of the specification, EN 300 220-1, described previously, desig-
nated as “Harmonized EN covering essential requirements under article 3.2 of the R&TTE Directive.” It includes technical requirements and lists the essential test suites to be used for compliance with the directive while referring to the detailed document EN 300 220-1.
Documents EN 301 489-1 and EN 301 489-3 are used to confirm compliance with the electromagnetic compatibility requirements of the Directive. These requirements involve both the potential for interfering with other equipment through radiation, and the susceptibility to being interfered with by other equipment or phenomena, or immunity to inter- ference. The radiation part of the requirement generally covers non- intentional radiation, from digital control circuits for example, whereas intentional radiation and its spurious by-products are covered by the transmission characteristic specifications mentioned in the paragraph above. Phenomena which effect the interference immunity of the equip- ment being tested are
■ Electromagnetic fields in the range 80 to 1000 MHz
■ Electrostatic discharge
■ Fast transients on signal, control and power ports
■ RF common mode interference—.15 to 80 MHz
■ Transients and surges on DC power input ports
■ AC power line variations and anomalies
EN 301 489-3 sets out exclusion bands for receivers, based on the device’s intended function, to prevent susceptibility to interference on an intended received frequency, or image frequency, for example, from disqualifying the product. For transmitters, radiation on the operating frequency and sidebands is excluded from the interfering possibilities of the device.
The essential requirements regarding health and safety, referenced in article 3 paragraph 1(a) of the Directive, are satisfied by meeting the requirements in the CENELEC (European committee for electrotechnical standardization) document EN 60950, “Safety of information technology equipment.” The nature of testing involved depends on whether the prod- uct has an internal or external power supply unit.
A designer of short-range radio equipment that is to be marketed in the European Union is well advised to take into account the EMC and safety requirements of the R&TTE Directive early in the development stages of the product.