Will the EU withdraw radio equipment from the market because of the change of legislation from R&TTED to RE-D?
The EU does not withdraw products from the market. The Member States are in charge of market surveillance.
What are harmonised standards for? The application of harmonised standards is voluntary. They are used to demonstrate that products, services, or processes comply with relevant requirements of the EU legislation. However, manufacturers can use any technical specification to demonstrate that the radio equipment complies with all necessary requirements, upon their own responsibility. The essential performance requirements and use of radio spectrum laid down in Articles 3.2 and 3.3 must, however, be certified by a Notified Body, if alternative specifications are applied. The list of notified bodies can be found on the Commission website (NANDO). The manufacturer can give assurance that the equipment meets the safety and health and electromagnetic compatibility requirements laid down in Article 3.1 by showing conformance to harmonised standards, but there is always the option to use alternative technical specifications. In such a case, the manufacturer assumes the risk if a product subsequently presents a risk to anybody.
Iâm not sure that Iâd agree with your assessment on this. That comment doesnât demand any user to undergo full, insurance backed testing just to be able to power on a device. Just that:
(Emphasis added)
If youâre using a CE marked module, and are using the LoRaWAN stack that is included with it, the main risks of non-conformity would be from the antenna and signal path from the module (and you could copy the manufacturerâs reference design for something thatâs already been tested), choice of the antenna, and any high frequency signal paths that youâve added to your device.
From this point, itâs effectively an engineering risk assessment. Depending on your level of experience, no practical testing may be required, or you may need to perform basic testing that the device doesnât emit unexpected RF signals. Or, if youâre producing hundreds or thousands of devices, to go through professional pre-compliance or insured compliance testing.
Iâm not sure that Iâd agree with your assessment on this. That comment doesnât demand any user to undergo full, insurance backed testing just to be able to power on a device.
I was reiterating what Ofcom said and that is their so called opinion only. Do remember that Ofcom do not write the rules or make the law here.
The controlling document appears to be not the RED guide but the Blue guide which says;
.2.1. PRODUCT COVERAGE
Union harmonisation legislation applies to products which are intended to be placed (or put into service (31)) on the market (32).
Note the âor put into serviceâ
I did ask Ofcom to clarify whether the âor put into serviceâ applies to radio equipment, but they chose not to. I suggested to them that the RED guide quoted on the Ofcom website is misleading at best, and that they change their advice, they declined to do so.
The legislation is a mess,its unclear and misleading, it seems it would take a court case to sort out what it all actually means.
Can I ask, is TTN a goer for UK for a commercial application? Presumably we have to use a CE approved gateway and nodes. Any recommendations would be much appreciated.
Sounds like a really nice concept.
I am new at arduino programming too and I want learn the ins and outs of it.
I see that it has been a while since you have posted this reply over here, so I want to ask and find out if you got to know which modules can you use legally in the UK so that I can also get started on some project.
Also any ideas for a project will be of a great help
I have a mentor who is guiding me so difficulty level is not really an issue here.
Thanks in advance!
The question is not really related to LoRaWAN but more to do with point to pont LoRa comms.
Most of the mentioned modules can be used legally, but what is legal depends on frequency, bandwidth, transmit power and duty cycle. Duty cycle is in turn highly dependant on how much data you want to send and how often.
The devil is in the detail, so basically you can only work out what is legal by planning you application and studying the regulations carefully, see IR2030.
Recently Italy, UK and Switzerland stated that LoRaWAN is not an SRD protocol and have disallowed national LoRa networks. We are working to clarify with regulatory bodies. APC will help.
What constitutes a national network? How does that impact mine /others efforts building out regional networks. If I stop one town short of national is that ok? âŚbut seriouslyâŚif using ttn/tti as underpinning is that then national⌠Who is not allowed, me, others, ttn? typical gov dumb think imho
@mark-stanley what have your buddies @ digital catapult had to say/contribute on this? I gather Alex @ the ttn-Conf⌠May be worth having a chat with him?
Hi Jeff,
I canât speak for the Catapult.
Iâd like to see a reference to where Ofcom said this, because I havenât been able to find it. My immediate feeling is of disbelief.
I donât understand the relationship between not being SRD and so not being allowed nationwide.
If true Iâd be wondering how IoT Scotland (a public sector funded national LoRaWAN) network got approved?!
Iâd also wonder if this applied to other LPWAN - Sigfox, NB-IoT etc., and if not, what makes LoRa special?
I suspect the slide is missing some context.
Iâll try to check with some old L-A & Ofcom contact in coming daysâŚperhaps you could do the same & we come back here or the recently opened TTN UK Communities & Gateways Thread to update all?
I wasnât as Conf so unsure whose pitch it wasâŚperhaps we can get them to own the statement & follow upâŚjust saw slide posted in the Conf Paparaze thread & thought WTF!!
I found Ofcom fairly unknowledgable when I queried them about the impact of the recent changes to CE, and the consequences for DIYers making LoRa nodes.
I suggested they change the advice on the Website to reflect how the regulations now read, they said no, and was advised to consult a lawyer to establish the reality of the regulations.
Hi @Jeff-UK, thanks for this but I think that this is completely fake news. The organisation that I work for is participating in Ofcom workshops on âSupporting the expanding role of wireless innovation in UK industryâ. As part of the documentation for this, Ofcom is actively promoting âLow Power Wide Area Technologiesâ and lists Sigfox, LoRa and NB-IoT. Sigfox and LoRa are both listed as operating in the â868 MHz licence exempt band.â The use of LoRa is also actively promoted in other recent Ofcom documents such as the Connected Nations 2018 UK report.
As a bit of Sunday morning entertainment I trawled through all the ERC and ETSI documents that are relevant to SRD. These are legalistic documents filled with formal definitions but nowhere is âshort rangeâ defined in terms of distance, it is only referred to in terms of RF power and the capability to interfere with other radio systems.
It seems very unlikely to me that the UKâs Ofcom is about to attack Sigfox or LoRa.
Appreciate that is the case and currently plodding on with deployments! I do worry that there may be some assumptions here and also fake news via LoRa-Alliance would not be confidence building so am prepared to believe there is something behind this on basis of âno smoke without fireâ.
Also whilst we are all happily deploying on local/community/regional level there is another aspect to the statement - "disallowed national LoRa networksâ (is that short range vs national the issue?!) - what does that mean for my plans for world (sorry, strike that) domestic domination or the roll of TTN/TTI as a national infrastructure provider (âŚsilently strokes his fluffy white catâŚ)
you really think LoRa-Alliance would spread âfakeâ news ?
This is politics imho⌠like with Brexit, UK citizens canât own .EU domains⌠things like that, the EU must punish the UK , must âhurtâ them ⌠they act like children imho
No I dont - unless by accident! This was ref to Timâs @cultsdotelecomatgmai comment earlier in thread calling this (fake news) out as possibility.
Also this is supposed to be a UK (Ofcom?) decision - so I cant blame on Eu this time Poss self inflicted wounds!
We do need L-A to âownâ their statement, howeverâŚdonât know whoâs pitch it was as just an uncaptioned picture from teh Conf Paparaze thread. Do you know? Can you ding them or one of the TTN guys to follow up and explainâŚclearly a cause of concern & potential stressâŚ
There are more from the same talk on that twitter.
This is the LoRaWAN Regional Parameters Standardization talk by David Smith, CTO of MultiTech and Co-chair LoRa Alliance regional parameters working group
âŚbut seriouslyâŚif using ttn/tti as underpinning is that then national⌠Who is not allowed, me, others, ttn? 
typical gov dumb think imho 
Poss self inflicted wounds!