Wireless compliance considerations
22 September 2015
Neil Dyson discusses the compliance issues surrounding the addition of wireless technology to OEM machines.
As more and more machinery manufacturers add wireless modules into their products, there is an assumption from many that, because the module is compliant as an independent unit, no further action on is required. However, this may not be the case and it could have wide reaching consequences for the end users of these machines.
In the European Union (EU) it is mandatory that radio equipment meets the ‘essential requirements’ of the Radio and Telecommunications Terminal Equipment Directive 1999/5/EC (R&TTE).
In order to reduce costs and time to market for new equipment, many machinery manufacturers are now relying on the use of wireless modules which already meet some or all of the R&TTE essential requirements. However, it is important to understand that once these modules are integrated into another product, it changes the regulatory requirements as the entire host machine then falls within the scope of the R&TTE Directive.
The R&TTE Compliance Association has already issued guidance on the use of wireless modules. In a nutshell, this states that when an R&TTE compliant module is integrated into a final host product, only limited radio testing is required. The host product must still always meet the other essential requirements of the Directive - namely the safety and EMC aspects.
However, integrating a wireless module is not always as straightforward as it may seem, and is new territory for many machinery manufacturers embedding these modules into their equipment for the first time.
The most common method of demonstrating compliance with the R&TTE essential requirements is by using ‘Harmonised Standards’. These are written and published under an EU mandate, and provide a ‘presumption of conformity’ (or compliance), provided they are applied in full.
Harmonised Standards are always evolving, which means they have what is effectively an expiry date as they become superseded by more up-to-date standards, which may well have different requirements. Machinery manufacturers may therefore need to perform a gap analysis between the two sets of standards in order to bring their products up to speed with the latest requirements.
Global rules vary
The USA and Canada have formal approval processes in place, so the routes to compliance are reasonably clear compared to Europe. When all Federal Communications Commission (FCC) requirements are met, and the device is certified, the FCC grant will state that the device has modular approval. Provided the conditions of the grant are adhered to, there should be no further testing or certification required for the intentional radiator part of the host machine, but a label should be displayed stating that an approved wireless module is contained within the host.
The Industry Canada rules for modules are broadly similar to those of the FCC and are laid down in RSS-GEN Section 3.
For European compliance, machinery manufacturers should ensure that the wireless module is fully compliant with the latest Harmonised Standards and is integrated in accordance with the manufacturer’s supplied instructions. While the module manufacturer should be aware of the integration rules, as a minimum the final/host machinery manufacturer should check the module’s Declaration of Conformity to ensure that it lists Harmonised Standards which are in date.
The host machinery manufacturer should also have access to the wireless module manufacturer’s technical file in case they are asked to prove compliance by a country’s market surveillance authority.
Products containing wireless transmitters also need to comply with separate national radio regulations no matter where in the world they are used. This means that a product containing a wireless transmitter must not be shipped to a non-EU country without checking the regulations.
In any country, the market surveillance authorities can come down hard on manufacturers that supply non-compliant equipment to the market and ignorance of the rules is no excuse. Machinery end-users also therefore need to have an understanding of the requirements to which the manufacturer of their machine must adhere, in order to ensure that the equipment they purchase complies and is safe to use.
Neil Dyson is business line manager at TÜV SÜD Product Service.
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