As electronics product designers we know that the compliance process in electronics product development can appear intricate and precarious, if rules or regulations are misinterpreted.
Now, our community has the European Union’s new Radio Equipment Directive 2014/53/EU (RED) to grapple with.
The RED came into force on 13th June 2016, replacing the Radio and Telecommunications Terminal Equipment Directive (R&TTE Directive 1995/5/EC).
With a significant bearing on how manufacturers gain a CE Mark, due to changes between the two frameworks, it’s crucial to fully understand these regulatory differences to avoid time and cost overruns.
Here’s an overview of the Radio Equipment Directive – its scope, impact on product design, and what you should do next.
Regulatory necessity for new Radio Equipment Directive
Traditionally, almost all devices dependent on the radio frequency spectrum to function mainly consisted of AV equipment, PCs, and telecommunications technology.
Since 2000, regulatory compliance and conformity has come under the Radio and Telecommunications Terminal Equipment Directive (the R&TTE Directive, 1999/5/EC).
Now, the Internet of Things has ushered in an age of ultra-connectivity with millions of items connected and communicating daily; smart cars, meters, jewellery, fitness devices – even smart paper… the list seems endless.
The relentless proliferation of IoT is also widely believed to have been a contributory factor to the R&TTE Directive revisions.
RED – its aims
The driving forces behind this new regulation were improving market surveillance and raising the number of products meeting compliance requirements. The RED ensures all radio devices (or ‘apparatus’) within its remit are compatible for use in the EU.
This is done through a regulatory mandate of standard technical requirements for telecommunications apparatus; allowing approved equipment to be sold without restriction between countries in the European Economic Area (EEA).
The R&TTE Directive was replaced by the RED on 13 June 2016 with a one-year grace period – during which both the old and new Directives may be used for product compliance. The R&TTE will be repealed on the 13 June this year when only the RED will apply.
The Radio Equipment Directive – what are the main changes?
RED – Main changes include:
• No provision for Telecom Terminal Equipment (TTE); this now comes under the EMC (EMCD) or Low Voltage Directives (LVD)
• No lower limit to the radio frequency spectrum. Under the RTT&E Directive, the range covered was between 9 kHz and 3000 GHz.
• LVD safety obligations: no voltage limits for radio equipment
• No alert sign (Class 2 labelling)
• Provision for universal chargers to address wastage
• Closer regulation of the activities of Notified Bodies
• The manufacturer must inform the Notified Body of all modifications to the product that may affect compliance
• Further clarification on market surveillance guidelines
RED – scope includes:
• All Radio Receivers (Broadcast TV and radio equipment included)
• Equipment capable of being connected to a public telecommunications network even if that is not its intended purpose
Examples of equipment included within the scope of the RED:–
• Cordless and mobile phones
• Terminal adapters
Legacy products must also meet the latest RED harmonised standards. The (Electromagnetic Compatibility Directive) EMC, safety and Radio R&TTE harmonised standards will eventually be harmonised under RED.
RED – scope excludes:
• Amateur radio kits
• Marine equipment
• Airborne components and products (which fall under Article 3 of regulation EC216/2008)
• Equipment for military, police and state-security
There are currently very few RED harmonised Radio standards and the R&TTE list has disappeared.
RED and the EMC Directive
We asked Anne Barr at The Compliance Map – a developer of supply chain and environmental compliance software solutions, to explain how RED affects the EMC Directive: ”the EMC requires equipment to be designed and manufactured to ensure that any electromagnetic disturbance generated does not impact the operation of radio and telecommunications equipment and that it is not impacted by such disturbance. It specifically excludes equipment covered by the Radio Equipment Directive (RED).
Therefore, the changes introduced by RED had two direct impacts on EMC:
1. Telecom Terminal Equipment previously covered by the Radio and Telecommunication Terminal Equipment Directive (R&TTE) and not included in RED now falls within the EMC.
2. Sound and TV receive-only equipment and radio equipment operating below 9 kHz previously excluded from the R&TTE are no longer by covered by the EMC.
However, Article 3 of RED requires radio equipment to have an adequate level of electromagnetic compatibility as set out in EMC, recognising that the essential requirements of the EMC were sufficient to cover equipment covered by RED. This effectively merges the requirements of EMC into RED.”
If you want to know more about ByteSnap’s EMC testing services, please contact us.
Who’s affected by the Radio Equipment Directive?
• All 27 EU member states
• 3 EEA (European Economic Area) Countries
Impact on Product Designers
For new products the impact on product designers is minimal, as most products that fall under RED would also have fallen under R&TTE, so the testing will be required anyway.
The main current problem is overcrowding and high charges at test houses, due to the re-testing being undertaken on existing products as well as new ones. In addition, the lack of clarity due to the RED not having been passed into law yet in the UK is adding to delays for product designers.
What action needs to be taken now?
Anne Barr shares the key next steps for electronics companies:
“First – determine whether products you design, manufacture, import or distribute are in scope of the new directive given the changes that have taken place.
“If you are affected by the directive, then a compliance project plan should be designed and implemented to meet the regulatory deadline of 13 June.
“Roles and responsibilities for the compliance project plan should be assigned, and budget allocated for the following:
• ensuring that the legislative requirements are understood and that changes e.g. with respect to product registration are tracked
• reviewing and updating existing conformity assessment procedures. The use of harmonised standards should be considered as it allows self-declaration of conformity. ETSI is currently in the process of developing these for different product types and OEMs should monitor progress
• revising product labelling, technical documentation and declaration of conformity as appropriate
• amending risk management procedures e.g. sample testing, complaints monitoring and product recall as needed
• communicating requirements both internally and externally.“
RED Post-Brexit…What Happens Now?
Despite talk of a return to BSI (British Standards Institute) conformance, it’s too early to speculate about a potential 2-tier compliance system for UK-manufactured devices.
Britain is in the early stages of leaving the European Union, a process which will take an estimated two years. So, as far as EU legislation – including the Radio Equipment Directive – is concerned, it’s business as usual.
To find out more on European harmonised radio spectrum usage, try the EFIS tool – the European Communications Office’s Frequency Information System.
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