Tuesday, May 02, 2017

Note on receivers in the EU Radio Equipment Directive and ETSI standards

The European Union has focused new attention on radio receiver standards through terms in the Radio Equipment Directive (RED) which came into force last year. The RED’s requirements that any “receiver [must have] a level of performance that allows it to operate as intended and protects it against the risk of harmful interference, in particular from shared or adjacent channels” have been reflected in new ETSI standards.

The Radio Equipment Directive

The Radio Equipment Directive 2014/53/EU (OJ L153, 22 May 2014) has been applied in EU Member States since 13 June 2016. It replaces the Radio & Telecommunication Terminal Equipment Directive (RTTED) 1999/5/EC (OJ L91, 7 April 1000) as of that date, and covers equipment that intentionally transmits or receives radio waves for communications or radiodetermination, regardless of primary function.

The citations, e.g. "OJ L153, 22 May 2014," are to the Official Journal of the European Union (OJEU). Directives and other publications in the OJEU can be found via http://eur-lex.europa.eu/oj/direct-access.html. Take the OJ reference (e.g. for the RED, "OJ L153, 22 May 2014") and select the year and month under "Access by year." For the RED, select 2014 from the dropdown and click May. Then find "L153" in the "L (Legislation)" column; clicking the link will resolve to a page with links to the texts in all the official languages.

The ETSI webinar by Michael Sharpe on 27 April 2017 provides a useful overview of the RED and associated ETSI standards.

Compared to the RTTED, the RED has an increased emphasis on efficient use of spectrum, in particular by improving radio receiver requirements, and improved provisions for market surveillance and  enforcement (in particular between Member States). There is a clear link with the Radio Spectrum Decision 676/2002/EC.

The RED does not cover

  • Wired telecommunication terminal equipment (product requirements covered by the Low-Voltage Directive (LVD) and Electromagnetic Compatibility Directive (EMCD), and interfaces covered by Directive 2008/63/EC (OJ L162 21.6.2008))
  • Equipment exclusively for public security, defense etc.
  • Equipment for radio amateurs (unless made available on the market)
  • Marine equipment falling under 96/98/EC (Marine Equipment Directive)
  • Airborne Products falling under Regulation 216/2008 (EASA Regulation)
  • Equipment using radio waves for other purposes (e.g. RF heating, medical imagery...)

The salient excerpts from the RED regarding receivers are
(10) “… in the case of a receiver, it has a level of performance that allows it to operate as intended and protects it against the risk of harmful interference, in particular from shared or adjacent channels, and, in so doing, supports improvements in the efficient use of shared or adjacent channels.” 
(11) “Although receivers do not themselves cause harmful interference, reception capabilities are an increasingly important factor in ensuring the efficient use of radio spectrum by way of an increased resilience of receivers against harmful interference and unwanted signals on the basis of the relevant essential requirements of Union harmonisation legislation.”
Article 3 
3.1(b) “1. Radio equipment shall be constructed so as to ensure: (a) …; (b) an adequate level of electromagnetic compatibility as set out in Directive 2014/30/EU.”  
3.2 “Radio equipment shall be so constructed that it both effectively uses and supports the efficient use of radio spectrum in order to avoid harmful interference.” 

Article 3.2 seems to be taken as a mandate on the performance of receivers.

ETSI Standards

ETSI standards are optional, not mandatory. However, they are very attractive to manufacturers since “[r]adio equipment which is in conformity with harmonised standards [cited in the OJEU]... shall be presumed to be in conformity with the essential requirements...” of the RED (Article 16). Even better, Article 17.3 allows a manufacturer to self-declare conformity to Articles 3.2 and 3.3 if it has applied harmonised standards cited in the OJEU. (Note that the standards must be cited in the OJEU to be valid for self-declaring conformity; publication by ETSI is not sufficient. Since 2015, the Commission must sign off on harmonized standards delivered by ETSI; so far this has always happened, but the review process introduces delay.)

Manufacturers have alternative routes, but “EU-type examination” or “conformity based on full quality assurance” both require use of a Notified Body, not just self-certification. For more details, see the European Commission's “Vademecum on European standardization.”

Michael Sharpe’s webinar summarizes ETSI work on harmonized standards to date. Receiver-related highlights include:

  • There are many more products under the scope of RED than were under RTTED, e.g. anything with a GPS receivers is now covered (slide 11)
  • A method to characterize UWB receivers has been developed (TS 103 361, slide 25)
  • A new version of EN 300 328 (2.45 GHz wideband data transmission systems – Wi-Fi, Bluetooth etc.) is being developed which will inter alia improve receiver performance to reject MFCN in adjacent bands (TS 103 521, slide 24)
  • In EN 301 893 (5 GHz Wireless Access Systems / Radio LAN) now specifies receiver blocking requirements to meet the RED (TS 103 521, slide 26)
  • There are now standards for terrestrial and satellite TV receivers, and broadcast radio receivers (slide 28)
  • Various radars (marine, aeronautical, automotive, meteorological) now subject to standardization (slide 28)

A lot of effort is evidently going into receiver standards. While receivers are not the only reason for ETSI’s RED revisions, they are presumably a significant part of the 169 separately-numbered Harmonised Standards in the pipeline. Of these, 98 Standards have already been cited in the OJEU as of 12 April 2017, and 26 have been published by ETSI and awaiting citation in the OJEU.

These requirements obviously do not apply to the US market, but it will be interesting to see if they are observed de facto, given that manufacturers of global products will have to comply with ETSI standards.

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