Machinery Update September \ October 2017

120 MACHINERY UPDATE SEPTEMBER/OCTOBER 2017 www.machineryupdate.co.uk
Regulations
New radio equipment
rules are tricky to meet
Paul Laidler Taylor
BuSinESS ManaGER diRECTOR fOR MaChinERy fOR MaChinERy SafETy SafTEy aT Tüv aT Süd Tüv PROduCT Süd PROduCT SERviCE SERviCE
The entire machinery supply chain, including manufacturers, importers and integrators of radio
equipment, now have to comply with the EU’s new Radio Equipment Directive. Here’s some help.
Even before we reach the
golden goal of Industry
4.0, machines are
increasingly incorporating
radio-based components
which rely on the radio
spectrum to operate.
These include systems for the
wireless connection of safety
devices, such as E-stops;
or in the operation of metal
detectors.
Now, the entire machinery
supply chain (manufacturers,
importers and integrators
of radio equipment) has
the European Union’s
new Radio Equipment
Directive 2014/53/EU (RED)
to deal with. As of June 13,
2017, the RED completely
replaced the old Radio and
Telecommunications Terminal
Equipment Directive (R&TTE).
Changes between the two
frameworks have a significant
bearing on how manufacturers
gain CE Marking. It is therefore
crucial to fully understand
these regulatory differences
in order to avoid time and cost
overruns.
CLEAR RESPONSIBILITY
The RED’s new requirements
are intended to clearly spell
out the responsibilities and
obligations for every economic
operator involved in the
supply chain (manufacturer,
importer, distributor,
authorised representative).
The Directive is applicable to
all electrical and electronic
devices that intentionally emit
and receive radio waves at
frequencies below 3000 GHz.
This is also the first time that
equipment operating below
9 kHz requires radio testing as
the RED scope is for products
operating below 3000 GHz,
whereas the R&TTE scope
started at 9 kHz.
For the first time, for instance,
broadcast radio and TV
receivers fall within its scope.
The following definition
explains what products are
subject to the RED:
“Radio equipment – an
electrical or electronic
product which intentionally
emits and/or receives radio
waves for the purpose of
radio communication and/
or radiodetermination, or an
electrical or electronic product
which must be completed
with an accessory (such as an
antenna) so as to intentionally
emit and/or receive radio
waves for the purpose of
radio communication and/or
radiodetermination.”
The introduction of the
RED means if machinery
manufacturers want to carry
on selling within the EU and
European Free Trade
Association countries, they
must test and if required
re-certify to the Radio
Equipment Directive, otherwise
they can no longer be placed
on the market. Consequently,
many manufacturers are
finding achieving compliance
to be a significant challenge
as they have never before been
required to undertake any of
the RF testing.
To enable full traceability,
every economic operator
within the supply chain must
identify who has supplied
them and to whom they have
supplied radio equipment.
The product must also be
accompanied by instructions,
and manufacturer’s contact
details, in a language which
can be easily understood
within the Member State in
which it is being sold.
One key change, which is
causing confusion among
Changes between the two legal
frameworks have a significant
bearing on gaining CE Marking
manufacturers, is that the
conformity assessment
process now requires them
to undertake a risk analysis
and assessment. Many
manufacturers are struggling
to fully understand these
changes, as there is no
explicit description of the
risk assessment process
within the RED – it is instead
referenced in the EU’s New
Legislative Framework.
While manufacturers have
experienced approvals
managers, they are not familiar
with a risk assessment
approach and may not have
the skill set to deal with this
new requirement.
Under the RED, importers
also have new responsibilities
as, when appropriate,
they must now carry out
sample testing, investigate
and maintain a register of
complaints and product
recalls, as well as keep
distributors informed of
this monitoring process.
For up to ten years after the
equipment has been placed
on the market, surveillance
authorities have a right
to request a copy of the
Declaration of Conformity,
and it is the importer’s
responsibility to ensure that
this is available.
RE-BRANDED UNITS
The RED has also changed
who is responsible for
re-branded equipment within
the supply chain. Importers
and distributors take on the
responsibilities, which were
once those of the original
manufacturer, where radio
equipment is re-badged and
supplied under their own
name or trade mark.
The RED’s wide ranging
changes are requiring some
significant adaptations to how
radio-enabled machinery is
manufactured and supplied.
It is therefore vital that
the entire supply chain
understands and complies
with their specific obligations.
The key benefit of modular
certification is the major cost
and time savings it contributes
to the operation of adaptive
self-configuring Industry 4.0
production systems.
i For more information contact
W www.tuv-sud.co.uk
TÜV SÜD Product Service
is the PPMA’s technical and
legislative partner