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Be wary of wireless modules warns TÜV SÜD

TÜV SÜD is seeing a significant growth in the number of non-compliant products entering its laboratories due the rising trend for wireless modules to be added into an expanding variety of products, such as televisions, washing machines, fridges, telematics devices and factory machinery.

Products that were not traditionally subject to the Radio and Tele-communications Terminal Equipment Directive (R&TTE) must now meet its requirements. Manufacturers are failing to realise this and are in danger of falling foul of the various market surveillance authorities, as ignorance of the rules is no excuse.

A presumption is often made that when an R&TTE compliant module is integrated into a final host product, no further radio testing is necessary. However, this is not the case if the module is not integrated in accordance with the module manufacturer's instructions, and it is also required to meet additional essential requirements of the R&TTE Directive, such as safety and EMC aspects.

The R&TTE Directive will be superseded by the Radio Equipment Directive (RED) in June 2016. The essential requirements of the RED are largely identical to those of the R&TTE Directive, so the situation regarding wireless modules will remain unchanged.

Jean-Louis Evans, Managing Director of TÜV SÜD Product Service, says: "The integration of wireless modules is going beyond the more traditional market, such as laptops and mobile phones, and they are now being included in everything from domestic fridges to industrial machinery. The problem is that while these wireless modules are being sold to manufacturers as being compliant, once they are integrated into another product that changes the rules."

He continues: "Manufacturers are assuming that because the wireless module is compliant, that they do not have to do any more tests to declare against different standards - this is wrong. 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."

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. However, Harmonised Standards are always evolving, and manufacturers must keep abreast of them if they are to continue placing products on the EU market.

In the USA and Canada, the use of wireless modules is also commonplace, but these countries have formal approval processes in place, so the routes to compliance are reasonably clear compared to Europe. However, the Federal Communications Commission (FCC) rules can be difficult to understand. So, for those wishing to export products to North America, it may be prudent to seek guidance from an authorised test laboratory or from an FCC-designated Telecommunications Certification Body.
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