Taking the Headache out of the RTTE Approval

By Harry Shutt, Technical Director, HBT

Introduction

Understanding the formal procedures and technical implications of the RTTE Directive is important. It is a significant change from the present regime. But we must not lose our sense of balance. The underlying objective is to simplify the approval route whilst ensuring that products connected are safe and free from interference. Simplifying approval should be good for the designers, manufacturers and, ultimately, the end user customer since it should be speedier and less costly.

However, it is also in everyone's interest to ensure that products perform satisfactorily when connected to the network. Clearly, unreliability, high product returns and customer dissatisfaction must be avoided, not to mention potential litigation as a result of consumer protection laws regarding fitness for purpose.

Test houses need to offer manufacturers a painless way to meet the RTTE Directive by taking on board the procedural elements, and taking a proactive approach to solving problems, including design problems, and performing testing which will provide confidence in the supply chain that not only does the product meet the Directive but it is also fit for purpose - Functions that should work, do work and under various conditions.

Current approvals

The current approval requirements are based on harmonised standards but with the provision of approval against national standards for product types where harmonised standards do not exist. So, for example, a telephone or cordless telephone (CT0) would be approved using the following specifications:

EMC Directive 89/336/EEC
Low Voltage Directive (LVD) 73/23/EEC
CTR 38 - Speech performance of corded telephone
CTR 37 - Network connection approval of corded telephone
CTR 21 - Network connection approval of CT0
MPT 1384 - Radio for UK CT0 - Not a harmonised standard and would be country specific.

The emphasis on this approval route is that the manufacturer must have the product tested and passed by notified bodies and/or approved test houses before placing the product on to the market. This provides the manufacturer with the comfort and the confidence that the product has been tested and approved by competent bodies.

RTTE Essential Requirements

The purpose of the RTTE Directive is to remove regulatory barriers to the free movement of radio and TTE products within the EU. Products meeting the new RTTE Directive will have free access to all member states. The exception here is where the radio band for say a cordless telephone has not been adopted by other member states. To comply with the RTTE Directive the product must -

Comply with the essential requirements of the EMC Directive 89/336/EEC.
Comply with the Low Voltage Directive (LDV) 73/23/EEC (but with no voltage limit applying)
Be constructed (for Radio equipment) so that it uses the spectrum allocated to terrestrial/space radio communications and orbital resources effectively so as not to cause harmful interference.

In summary what do the changes mean?

The manufacturer no longer has to obtain mandatory third party type approval for the product and can rely on self-certification based on satisfying themselves that their product complies with the appropriate harmonised standard.
For the manufacturer it is no longer mandatory to use designated test houses.
The product has to meet simplified essential requirements - EMC and LVD Directives.
Includes radio equipment

Conformity assessment is based on:

Annex II - Internal production control - testing done either in-house or third party - manufacturers declaration of conformity, meaning that no testing is required by notified body and no factory approval required.
Annex III - For radio equipment - internal production control and, if no harmonised standard, the essential testing to be carried out with reference to a notified body.
Annex IV - Based on technical construction file presented to a notified body for review.
Annex V - Full quality assurance where the manufacturer operates an approved quality plan for design, manufacture and final product inspection and testing.

Policing

The extent of policing the current EMC Directive varies from country to country. In some countries inspection is limited and may be complaint driven while others carry out audit testing at accredited labs.

The policing powers are expected to be similar to those of the EMC Directive:-

Purchase of product on sale and subsequent testing.
Powers of entry to non-residential property.
Impounding of suspect equipment.
Inspecting product documentation.
Serving prohibition notices.

Conclusion

The burden now rests with the manufacturer of ensuring that their products comply with the Directive and meets the national requirements of other EU member states. If sold in Germany or France or Italy or .... can the manufacturer be confident, without testing, that the product will function correctly under certain network conditions? After all, the products still have to be fit for purpose and, remember, satisfy the customer.

There is a great concern that because the Directive does not contain mandatory telephone performance testing it could result in unscrupulous suppliers flooding the market with cheap products. These products may either not work under certain network conditions or have inferior speech quality or be generally unreliable. However, scrupulous distributors of quality product would naturally want to have their product meeting recognised standards to ensure it will work under all network conditions and in the EU member states. They would be at liberty to ask their suppliers to demonstrate the telephony aspects meet recognised standards. The current mandatory approval requirements of CTR 21, CTR 37 and CTR 38 could be used as a recognised way for the manufacturer/supplier to demonstrate to the distributors that the product is fit for purpose.

Some test houses such as SGS IEA in collaboration with HB Technologies (SGS-HBT) are now able to offer a service to the manufacturer/suppliers which will give them the comfort and confidence in applying the CE mark to their telephone products after the introduction of the RTTE Directive. The test house will test the product against the essential requirements of the RTTE plus the appropriate non-mandatory telephone requirements of CTR 21, 37, 38 (or even their own specifications) and then issue the manufacturer/supplier with a certificate to indicate compliance. To a great extent this can lift some of the concerns as the manufacturer/supplier has the comfort of knowing that the product placed on the market has been tested by a reputable test house and not only meets the essential requirements of the Directive but, demonstrably, meets recognised Pan-European performance and network connection requirements.

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