Could the flood of cheaper electrical imports be endangering our airwaves?
16 October 2008
The RTTE Directive has generally been ‘a good thing’, but Jean-Louis Evans believes that it has its problems - and hopes the review that is currently in progress could resolve these.
Since its introduction in April 2000, the Radio and Telecommunications Terminal Equipment Directive (RTTE) has been the required method for manufacturers to show compliance of any radio and telecoms equipment that is sold across Europe. The Directive was introduced to remove any trading barriers in Europe, with the intention of continuing to ensure that products met minimum requirements related to health and safety, EMC and the radio spectrum.
As a total harmonisation Directive, the introduction of the RTTE meant that no member states could add on their own national approval requirements. This was intended to encourage the free movement of equipment by removing the old market access controls that countries had previously demanded for products being imported.
Before the RTTE was introduced in April 2000, every radio-enabled device had to be passed either by a National Type Approval Body or a European Notified Body. This of course means that the new Directive liberalised the regulations surrounding the old approvals regimes for Radio and Telecommunications Terminal Equipment. It also meant that for the first time, manufacturers could simply sign a declaration of conformity and apply CE marking themselves, making the manufacture and sale of products less time-consuming, as well as reducing costs and the time to market for products. In essence, RTTE moved the process of compliance from one of regulation to a more surveillance-led approach.
Increase in equipment failure
However, a market surveillance report conducted in 2003 in 19 European Conference of Postal and Telecommunications Administrations (CEPT) countries showed that 76 per cent of equipment that relies on the radio spectrum failed to comply with the RTTE. Five years on from that report, approximately 90 per cent of the manufacturing of such products has moved from Europe to China and other Asian countries.
As cheaper low-end products start to flood the market, so the risk that they will interfere with the radio spectrum and therefore essential services such as emergency services, military and air traffic control are increased. The chances are that if a similar market surveillance report were conducted today that the percentage of products to fail would have increased significantly.
Fortunately, the EU is currently reviewing how the safety of products that rely on the shared radio spectrum can be improved. For the production of more high tech equipment compliance is much higher as this sector has an established set of protocols. However, it is the area of mass-produced electrical goods for the general consumer market that is causing concern with products that are not compliant increasingly seeping into the supply chain.
This isn’t just speculation on TÜV Product Service’s part. Another CEPT market surveillance campaign conducted in 2005 showed that 88 per cent of the terminal equipment checked failed to comply with the Directive’s technical requirements. The main problems were with low tech, low cost products that showed non-compliance - just the type of equipment that consumers are demanding more of from the High Street.
While the RTTE has been a real boon to the electronics manufacturing sector it has created a loophole for the less scrupulous manufacturers. They may be running the risk of not testing at all as their focus is on reducing cost and time to market to a minimum as their priority route to profit.
Confusion proliferates
As the increase in consumer demand for electrical goods has exploded over the last ten years, so much of that additional manufacturing capacity has moved outside Europe. Due to language issues, these manufacturers could be misunderstanding the Directive requirements - giving products the CE badge that would otherwise fail tests.
The CEPT market surveillance campaign backs this up as it showed that many of the products that did not pass compliance also had no self declaration of conformity assessment. The majority of these products were produced in China and brought into the EU without the importer being aware of relevant legislation.
However, not all the problems are entirely down to the new economies emerging outside the Europe. The CEPT report also discovered widespread confusion about the new Directive’s administrative provisions as there are more of them than in any other related directives. So, the EU’s review will have to include making the Directive easier to understand, even for those manufacturers in Europe that have established protocols which they have followed for decades.
Prepare for the avalanche
The implications for the electronics manufacturing and test sector in the UK and Europe is that if left unchecked, this situation will snowball. While there are final product implications, this will also impact modules used in the assembly of electrical equipment. Components that businesses use to construct a final product, which because they carry CE marking, the assumption is that they are compliant with the RTTE.
Looking further up the supply chain, Wireless LAN equipment used in the office or home could interfere with military radio communication. This is especially of concern in some countries in Continental Europe where the military frequency is comparable to the transmission frequency of such products. For example, as the German military operates on a frequency similar to that of a wireless LAN, special arrangements were required for increased market surveillance to protect military radars from interference.
Manufacturers could also find themselves producing, and retailers selling, products that actually interfere with each other – your new wireless LAN in the office could render your wireless mouse or other Bluetooth products useless. The utopian idea behind the RTTE was that while self-certification made market growth possible, it would be market forces through user dissatisfaction that would identify non-compliant products. But, someone could be happily using their home wireless LAN totally oblivious to the interference that it is having with their neighbour’s television.
The good news is that the policy makers in the EU are reviewing the situation now – with a progress report expected later this year, following a public consultation last year. But, proposed changes aren’t expected until late 2009.
With cheap imports from outside Europe on the rise, and demand for wireless equipment increasing rapidly, this review is unlikely to be fast enough to address the pace of wireless product proliferation and its effect on the integrity of the radio spectrum – potentially turning our dream of a wirelessly connected world into a nightmare.
Jean-Louis Evans, Managing Director at TÜV Product Service, a product testing and certification organisation, and at its sister company, British Approvals Board of Telecommunications (BABT), the radio and telecommunications certification body.
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