UK Legal requirements for equipment

Hi All,
First of all sorry for bringing this topic back, but I think you are all smart people and mayne can help me :slight_smile:

I am new to everything what I am doing now. I want to build wireless checkpoints for the Airsoft/Paintball games.

Idea is to program arduino with lora 868mhz and then add leds with buttons, so checkpoints would be placed randomly in the PRIVATE site then player need to press his teams button and RF impulse would be sent to the scoarboard in the base, for this porpose I will use lora 868mhz module.

So far I have contacted Rfsolutions and ordered 3 lora modules (lambda9 868mhz) they assured me as it is legal to use in the UK and this module is license free, then Iā€™ve called to ofcom and send them an email as well, and they said as well that Iā€™m good to go.
Question.
Can someone please tell where are my limits programming this unit with the arduino? Where should I pay more attention programming it is it just that I canā€™t exceed 25mw and everything else is fine? Iā€™m not really a tech or radio guy so please if you could reply in simple English :smile:

Thank you and have a nice day :slight_smile:

1 Like

It seems like youā€™re not using it in an experimental way, and due to the range it will also be publicly available in a certain way . Did ofcom also explain why exactly using these would be ok? Did they perhaps refer to some criteria they used to decide about your request?

Please see my email sent to them below:

Hi,

Iā€™m an Airsoft enthusiast (military reenactment) and just started to use ARDUINO programming for my project.

I am new to programming and radio frequencies. I know that there are some frequencies that is licence exempt.

I want to build a scoreboard and a wireless checkpoints. Idea is that the player would come next to the checkpoint and would press his teams coloured button,then RF signal would travel from the checkpoint to the scoreboard and VICE VERCA.

All these units would be only used in the private territories mainly woodland, my goal is to get from 200m up to 1000m range in the woods.

I have 3 different modules in mind.

2.4GHz module with max of 100mw from China

GSM module Quad band from China

868mhz LoRa module 100mw from UK rfsolutions.co.uk
CE + FCC

Could you please tell me which module I am legal to use without any licence in the UK, everything would be on the ground and with just short RF impulses.

Thank You!

If the devices meet the requirement, then there is no need for a license.

However, what is not yet clear is whether when the new Radio Equipment Directive came into force, December 26th 2017, all such radio equipment now needs to meet the requirements for CE marking and testing, even if its for your own use.

If Iā€™m bying lora module from rfsolutions.co.uk which is UK company with all of the CE and RohS marks and data sheets I think I should be alright. And prices are not that bad comparing to the China market.

My understanding would be that its the final device, as working, where CE applies.

And thats what they have sent to me back:

Hello Mickey,

The three methods you have mentioned are all ok as long as the first and third one meet the requirements of interface Requirement 2030, which can be found on our website www.ofcom.org.uk if the powers are as you have stated then they probably do.

As for the GSM unit it will not work unless you have a SIM in it then you are covered by that licenced MNO.

Thats what you would expect them to say as far as the UK regulatory side of 2030 is concerned.

Meeting the EU Radio Equipment Directive, is a seperate and additional requirement.

Dear All,
Ofcom has published its annual works plan and it is open for consultation - https://www.ofcom.org.uk/consultations-and-statements/category-1/proposed-annual-plan-2018-19

You may wish to respond to their plan if you would like them to put some effort into stating their position with regard to LoRaWAN / TTN. The current plan doesnā€™t mention IoT once.

Regards, Mark

It does seem focused on the BBC and broadband. Have Digital Catapult published a response?

Surely not?

We build automation control panels from 100 separate CE certified parts. We do not require re-certification of the panel as a whole.

Good question @Davet998 - ill ask them. Iā€™d be surprised if they have, they donā€™t like to step on toes.

I had a long discussion with Ofcom about this.

The Radio Equipment Directive (RED) guide is very misleading, perhaps deliberately so.

The RED guide does state that for personal use there is an exemption from following the CE marking processes for radio equipment that ā€˜is placed on the marketā€™.

What the RED guide significantly omits to mention is that there is still a requirement to follow CE marking processes for ā€˜putting (equipment) into serviceā€™.

Why personal users get an exemption for ā€˜placing equipment on the marketā€™ when they still have to follow the process to place the item into service, does not make sense.

The comment from Ofcom was;

ā€œIf a person is putting into service radio equipment (built for personal use) then they must ensure that it meets the essential requirements of the RE Regulations (effective and efficient use of the radio spectrum). It must be for the individual to conduct or commission such testing as may be needed to ensure conformity.ā€

Even if you use an assembled radio module that is CE then by the time you add the micro controller, power supply, antenna and your own code the assembled device itself needs to be CE, which I would suggest is impractical for personal users.

Although 868Mhz is not an Amateur/Ham radio band, I am wondering if it is relevant to the Things network?

My Full Amateur radio licence allows me to self teach and experiment with radio communications . It just occurred to me that those without a licence, might not be allowed to ā€˜researchā€™ under UK law?

Or is the fact that 868Mhz is an ISM (Industrial, Scientific, Medical) frequency, and not an Amateur radio frequency, mean that we all should not be producing radio equipment, without a licence?

The company I run has to have a specific radio communications licence from the government (OFCOM), to be able to commercially ā€˜work onā€™ (including repair) commercial radio communications equipment.

Yes OFCOM seemed a bit unsure, when I asked them about maximum antenna height for 868Mhz use.

In OFCOM licenced Business radio there is a 20 Metre height limit for base antennas on buildings in UK, but 868MHZ seems out of their remit.

I donā€™t see how the UK Amateur radio license can be relevant. Ignoring the frequency issues the UK license only allows you to send messages to other licensed amateurs.

Bear in mind, It isnā€™t just the UK that has radio hams with licenses - Most countries have them!

I look at it as a good thing that we do not come under the brief of a radio ham license.
If we did, then it would be the end of Lorawan.

Apart from the Gentlemanā€™s agreement about bandplans and ERP power, there are strict restrictions on encryption and broadcasting (as you have pointed out) - basically, its not allowed and if you break the rules as they are set at the momment, you lose your radio ham license

It continues to be an unknown - in some way, we are best to leave ofcom out of it. We are not infringing any of their current rules as far as I know!
We are harming no-one anyway and I donā€™t see any law that actively prohibits us from doing this and no-one has so far been prosecuted. The worst that could happen is that we are told to stop operating the equipment!

The biggest worry is if recent law privacy changes are seen to apply to Lorawan (which is outside the radio ham license anyway), and this is deemed sufficient for a criminal prosecution outside of Ofcom - but I think it is rather far fetched worry atm

1 Like

Bear in mind, It isnā€™t just the UK that has radio hams with licenses - Most countries have them!

Sure I know that, but then the thread is about ā€˜UK legal requirementsā€™ so what the Americans or Dutch can do with their license is of no consequence.

Ofcom do not in themselves make the rules.

The UK has adopted the EU Radio Equipment Directive, so to breach that is illegal in the UK, no matter what Ofcom may think or say.

@mark-stanley have you seen this. 6th update of the EU Short Range Device decision (EC 2017 - 1483)

https://www.linkedin.com/pulse/6th-update-eu-short-range-device-decision-ec-2017-1483-hersent/?trackingId=JjhgFkuGaUnpyt3BgR6meQ%3D%3D

Looks good for LoRaWAN but not sure how Offcom works with EU on this now and post Brexit?