There’s still uncertainty around some aspects of an imminent new Directive affecting all suppliers of radio equipment sold in the EU.
As the world goes wireless, radio equipment covers an ever growing variety of products, from television receivers to garage door openers and residential monitoring systems. The big news for industry is that as of 13 June 2016, compliance with the new European Union Radio Equipment Directive will be mandatory for devices sold in the EU.While the Directive - RED for short - introduces clearer obligations for manufacturers, importers, distributors and authorised representatives, achieving compliance is proving to be a significant challenge, as both the requirements and the number of products that are covered have changed.
It applies to all electrical and electronic devices that intentionally emit and receive radio waves at frequencies below 3,000GHz. For the first time, this includes broadcast radio and TV receivers. However, it does exclude radio equipment exclusively used for public security, defence and State security, as well as some marine and airborne equipment, and radio equipment used by amateurs. The good news for many engineers is that custom-built evaluation kits for use at R&D facilities are also excluded.
But while those selling equipment within Europe are expected to be up to date, it seems that the European Union itself is not entirely up to speed. Because the RED is replacing the old Radio and Telecommunications Terminal Equipment Directive, additional harmonised standards are required and existing ones must be amended. However, the European Telecommunications Standards Institute, ETSI, has said that it’s not possible to complete all of them by the June deadline. Likewise, some standards produced by CEN/CENELEC still require amendment.
This causes an issue for manufacturers who are up to date with the changes, and might think that they are one step ahead. If their product relates to a standard that is not yet harmonised with the RED, it’s mandatory for them to apply to a Notified Body for a Type Examination Certificate or Full Quality Assurance Approval. That’s a few more hoops to jump through, although equipment that was previously compliant with the R&TTE Directive may continue to be placed on the market until 13 June 2017.
With all these changes and degree of uncertainty, what are the key updates to be aware of?
First, to enable full traceability, everyone in the supply chain must be able to identify who has supplied them and to whom they have supplied radio equipment. There are also two new options for the Declaration of Conformity that must accompany every product sold: a full version covering all applicable Directives and a simplified one with the link for a website where the full Declaration can be found.
For the first time, manufacturers are expected to anticipate how the end-user might misuse equipment. Consequently, they have to carry out a safety assessment that allows for this, not just the intended use of the product. Likewise, new responsibilities for importers mean that they must carry out sample testing of equipment on the market, as well as investigate and maintain a register of complaints and product recalls - keeping distributors informed of such monitoring. Importers are also required to keep a copy of the DoC, which authorities have a right to request up to 10 years after equipment is first marketed.
Among new rules regarding rebranded radio equipment, importers and distributors who supply equipment under their own name now take on the responsibilities as if they were the original manufacturer.
The RED also takes into account the different languages spoken across Europe, and every product must be accompanied by instructions in a language required by the Member State in which it is being sold. Essential Requirements now also support the European Commission’s push for portable devices to be compatible with a single charger.
The ticking clock on the road to compliance has stopped as we approach the 13 June deadline, and the RED’s wide ranging changes mean some significant adaptations to how radio equipment is manufactured and supplied. It is therefore vital that the supply chain understands its specific obligations so that equipment can continue to be sold legally on the European market. It is clear that, for many, uncertainty caused by lagging deadlines is creating confusion.
Jean-Louis Evans is managing director at testing, certification, inspection and training provider TÜV SUD Product Service (www.tuv-sud.com)