1. NLF Time Frame (Implementation Time Scales)
Andrew Hoare
Senior Engineer Inspection and Certification Body
UL VS Ltd

2. Agenda for Presentation
Introduction
Time Scale for LVD change
Time Scale for EMC-D change
Time Scale for R&TTE-D to RE-D change
Questions and Answers on the Time Scales
Annex 1: Reference Links

3. The objectives of this presentation are:
Introduction
The objectives of this presentation are:
To look at the time scales for the implementation of the new LVD, EMC and RE Directives
Apply these times scales by looking at the impact upon Manufacturers.
LVD and EMC-D were bundled together and pushed through EU Council along with another 6/7/8 directives
About half the slides are going through the official cut-off / hand-over points. The majority of the remaining slides look at scenarios as to how the change over impacts manufacturers.
It will be easier to understand the big picture once the presentation has been completed.

4. LVD – Time Scale for Change
Directive 2014/35/EU – Low Voltage Directive mandates the following:
Extract from new LV-D (2014/35/EU)

5. LVD – Time Scale for Change (cont.)
Directive 2014/35/EU – Low Voltage Directive mandates the following:
Extract from new LV-D (2014/35/EU)

6. LVD – Time Scale for Change (cont.)
What do Articles 25, 26 and 27 in 2014/35/EU mean in practice?
Article 25: Transitional Provisions
The Member states can’t stop a manufacturer placing on the market Electrical Equipment that meets Directive 2006/95/EC (old LVD) before 20th April 2016.
Placing on the market is either:
Leaving an EU based manufacturing facility Or
Clearing Customs at an EU controlled border.
If the Goods are still airport side then the Goods are deemed still to be located in International Waters (best analogy for the moment)

7. LVD – Time Scale for Change (cont.)
What do Articles 25, 26 and 27 in 2014/35/EU mean in practice?
Article 26: Transposition
The Member states shall, by the 19th April 2016, have written in to their National Law, the required wording to comply with the articles listed in Article 26.
This new wording is applied as of 20th April 2016.
Article 27: Repeal
Directive 2006/95/EC (old LVD) can’t be used on or after the 20th April 2016.
This means that EU member states and manufacturers can’t reference
Directive 2006/95/EC as of 20th April 2016.

8. LVD – Time Scale for Change (cont.)
Summary Time Line
2006/95/EC Directive is written in to National Law and is used by manufacturers
2006/95/EC Directive is removed from National Law and can no longer be used by manufacturers
2014/35/EU Directive is written in to National Law but is not implemented
Directive can’t be enforced by an EU Member State nor can it be used by a manufacturer
2014/35/EU Directive is implemented in to National Law and is now enforced.
Directive is used by manufacturers

9. EMC-D – Time Scale for Change
Directive 2014/30/EU – EMC Directive mandates the following:

10. EMC-D – Time Scale for Change (cont.)
Directive 2014/30/EU – EMC Directive mandates the following:

11. EMC-D – Time Scale for Change (cont.)
What do Articles 43, 44 and 45 in 2014/30/EU mean in practice?
Article 43: Transitional Provisions
The Member states can’t stop a manufacturer placing on the market Electrical Equipment that meets Directive 2004/108/EC (old EMC-D) before 20th April 2016.
Placing on the market is either:
Leaving an EU based manufacturing facility Or
Clearing Customs at an EU controlled border.

12. EMC-D – Time Scale for Change (cont.)
What do Articles 43, 44 and 45 in 2014/30/EU mean in practice?
Article 44: Transposition
The Member states shall, by the 19th April 2016, have written in to their National Law, the required wording to comply with the articles listed in Article 44.
This new wording is applied as of 20th April 2016.
Article 45: Repeal
Directive 2004/108/EC (old EMC-D) can’t be used on or after the 20th April 2016.
This means that EU member states and manufacturers can’t reference
Directive 2004/108/EC as of 20th April 2016.

13. EMC-D – Time Scale for Change (cont.)
Summary Time Line
2004/108/EC Directive is written in to National Law and is used by manufacturers
2004/108/EC Directive is removed from National Law and can no longer be used by manufacturers
2014/35/EU Directive is written in to National Law but is not implemented
Directive can’t be enforced by an EU Member State nor can it be used by a manufacturer
2014/35/EU Directive is implemented in to National Law and is now enforced.
Directive is used by manufacturers
Old NANDO data base needs to be replaced with the new NANDO data base that references EMC NBs that are accredited to the NEW EMC-D.
Old EMC OJ replaced with New EMC OJ.
A lab can’t perform testing against old EMC / LVD EU OJ as these documents have now been archived. A lab is now accredited to the new standards applicable for the new LVD and EMC-D

14. R&TTE to RE-D – Time Scale for Change
Directive 2014/53/EU – RE Directive mandates the following:

15. R&TTE to RE-D – Time Scale for Change (cont.)
Directive 2014/53/EU – RE Directive mandates the following:

16. R&TTE to RE-D – Time Scale for Change (cont.)
What do Articles 48, 49 and 50 in 2014/53/EU mean in practice?
Article 48: Transitional Provisions
The Member states can’t stop a manufacturer placing on the market Radio Equipment that meets Directive 1999/5/EC (old R&TTE-D) before 13th June 2017.
(Providing the equipment is in conformity prior to 13th June 2016)
Placing on the market is either:
Leaving an EU based manufacturing facility Or
Clearing Customs at an EU controlled border.

17. R&TTE to RE-D – Time Scale for Change (cont.)
What do Articles 48, 49 and 50 in 2014/53/EU mean in practice?
Article 49: Transposition
The Member states shall, by the 12th June 2016, have written in to their National Law, the required wording to comply with the articles listed in Article 49.
This new wording is applied as of 13th June 2016.
Article 50: Repeal
Directive 1999/5/EC (old R&TTE-D) can’t be used on or after the 13th June 2016.
This means that no new Radio equipment can use Directive 1999/5/EC as of 13th June 2016.

18. R&TTE to RE-D – Time Scale for Change (cont.)
Summary Time Line
1999/5/EC Directive is written in to National Law and is used by manufacturers
1999/5/EC Directive is removed from National Law and can no longer be used by manufacturers for new equipment
Manufacturers can still place on the market equipment that has been DoCed prior to 13th June 2016.
2014/53/EU Directive is written in to National Law but is not implemented
Directive can’t be enforced by an EU Member State nor can it be used by a manufacturer
2014/53/EU Directive is implemented in to National Law and can now be enforced.
Directive is used by manufacturers for all new Radio equipment
Old R&TTE OJ replaced with New RE OJ

19. R&TTE to RE-D – Time Scale for Change (cont.)
Summary Time Line
1999/5/EC Directive is removed from National Law and can no longer be used by manufacturers for new equipment
Manufacturers can still place on the market equipment that has been DoCed prior to 13th June 2016.
1999/5/EC Directive already removed from National Law for a year. Has not been used for new radio equipment for a year.
Now, no radio equipment DoCed prior to 13th June 2016 can be placed on the market.
2014/53/EU Directive is written in to National Law and now implemented.
Directive is used by manufacturers for all new radio equipment
2014/53/EU Directive has been implemented in National Law for a year.
New Radio equipment has been using this Directive for a year
Now, all Radio equipment placed on the market has to comply to this Directive
Old NANDO data base needs to be replaced with the new NANDO data base that references RE NBs that are accredited to the NEW RE-D.
Old R&TTE OJ replaced with New RE OJ

20. Question
A product currently meets the LVD (2006/95/EC) and EMC Directive (2004/108/EC) with DoC signed before 19th April, 2016: how long can it be placed on the market? Answer : 20th April 2016, provided there are no design changes
At the present time, there is no transition period!!!
But, there is a question on this that has been placed with the EU commission Working Group for EMC as a result of the recent EUANB (EMC NB group) meeting held in December 2014.

21. Question
Why is there no transition period for the new LVD (2014/35/EU) and EMC Directive (2014/30/EU) but there is for the new RE Directive (2014/53/EU)? Answer: The harmonised standards associated with the new LVD and EMC Directives are only undergoing administrative changes NOT technical changes. That is why the new LVD and the EMC-D were two of nine directives pushed though the EU Council / EU Commission.
NB not involved with either Annex II or Annex III but can be involved with Annex II at the Manufacturer’s request (old EMC-D)
NB not involved with Annex II but is involved with Annex III (Type Examination Certificate) (new EMC-D)

22. Telephone Terminal Equipment (TTE)
From 20th April 2016, TTE is to use the new LVD and EMC-D
From 13th June 2016, TTE is removed from the R&TTE. Which Directive(s) should I use for my NEW TTE product between 20/04-12/06/2016?
Answer: The intention is that the manufacturer should show compliance against the new LVD and EMC-D but there is nothing stopping them using the R&TTE Directive that has yet to be repealed.

23. Question
My Telephone Terminal Equipment (TTE) has moved to the new EMC Directive, how do the time scales effect my product? (Answer : The intention is that TTE {cooper connect} will have until 13th June 2016 to transition to the new EMC Directive) BUT……

24. Question
Is there anything stopping a manufacturer from issuing a DoC for a TTE device on, say, 2nd June 2016 against the R&TTE Directive and shipping that device out of their UK based factory until 12th June 2017?
=> NO
Esta pregunta es para la audiencia

25. R&TTE-D & New LVD & EMC-D
Summary for TTE
The two previous slides have shown that, for TTE products, it is highly dependent when the DoC is issued.
Before , only use R&TTE-D
Between , can use both R&TTE-D and new LVD & EMC-D
From , only use new LVD & EMC-D
R&TTE-D & New LVD & EMC-D
R&TTE-D Only
New LVD & EMC-D
Time

26. Question
A product currently meets the R&TTE Directive (statement signed before June 12, 2016): how long can it be sold without changing the statement? (Answer: 12th June 2017, provided there are no design changes)
How does a Market Surveillance Authority know that the DoC was signed before 12/06/2016 (or 20/04/2016 for that matter)???

27. Question
A manufacturer who places on the market a new radio product between June 13, 2016 and June 12, 2017, can they choose RE-D or R&TTE? Answer: No, the Manufacturer can only choose the RE-D. The R&TTE Directive is repealed so cannot be used.
….. And the standards (OJ listing) has been archived for reference only.

28. Question
A product currently meets the R&TTE Directive (1999/5/EC) with DoC signed before 13th June, 2016 If the product has a Design change between the 13th June 2016 and the 12th June 2017, what Directive has to be met? Answer: The RE Directive. Therefore the edict from the manufacture’s compliance team to their Design team is: “Make no design changes to that device already DoCed!!!”
In reality => What can I get away with!
If you have an NB Opinion issued against the R&TTE, the NB can’t update it as there are now no NBs for the R&TTE.
A test lab can’t perform testing against the original standards that the device was tested against as the R&TTE EUOJ has been archived.
A NB can be involved with Annex III (essential test suite), Annex IV and Annex V. A NB not involved with Annex II and Annex III (TTE) (old R&TTE)
A NB is not involved with Annex II but is involved with Annex III (Type Examination Certificate) and Annex IV (FQA)

29. Before 20.04.2016, use current EMC-D
Additional Point
My product is a Broadcast Receiver and it has moved from the EMC Directive to the new RE Directive, how do the time scales effect my product? Answer:
Before , use current EMC-D
Between use ?????
From , use new RE-D
In reality, the time between 20th April and 12th June 2016 will be used to get the new standards up and running and labs capable of performing the new test requirements.
The pragmatic approach will be to allow EMC-D to be used (but Manufacturer will need to check).
Current EMC-D
New RE-D
???
Time

30. Question
My product is a Transmitter that operating below <9kHz and it has moved from the EMC-D to the new RE-D, how do the time scales effect my product? (Tx <9kHz have moved from EMC-D to RE-D) Answer: See Information given for Broadcast Receivers on the previous slides.
Hearing aid coils

31. Important Note
In addition to the already published Blue Guide. The EU Commission will be publishing individual guides for the directives to provide guidance for the manufacturers. It has been requested that the EU Commission include in their guides, information about what is and is not allowed for the transition period. It is hoped that this will take the form of a Time Line.
Another “wait to see” what the EU Commission has to say

32. ETSI Standard Updates for the RE-D
Standards will fall in to 1 of 5 categories for conversion for use with the RE-D.
1st Group: Standards that can be cited with minimal update. This group is for standards that already have (reasonable) receiver requirements. Examples: - EN v EN x (most of them) - EN x (EMC)

33. ETSI Standard Updates for the RE-D – Cont.
2nd Group: Standards that need to be assembled from known sources (such as -1 and -2). This group is for standards that already have (reasonable) receiver requirements in the -1, and the current R&TTE requirements in -2. Examples: - EN EN EN

34. ETSI Standard Updates for the RE-D
3rd Group: Standards which require new technical elements to be developed. This group is for standards that do not have sufficient requirements. ETSI will have to work on what the requirements should be, and how to test to them. Examples: EN EN (BRAN)

35. ETSI Standard Updates for the RE-D
4th Group: New standards (such as broadcast receivers, radio determination and below 9 kHz). This group is for new standards due to changes in the scope of directive. ETSI will have to work on what the requirements should be, and how to test to them. Examples: - EN (in draft and will be ready for the RE-D) - TBA (Hearing loop, etc.)

36. ETSI Standard Updates for the RE-D
5th Group: Obsolete standards. This group is for standards that no longer fall within the scope of directive, or they are not used anymore (change of spectrum). Examples: - EN and EN EN and -2
EN = Maritime Emergency Position Location Radio Beacons
EN = Terrestrial Flight Telecommunications System
EN = SRD using UWB technology 6 to 9GHz

37. Annex 1: Some links
Electrical Safety: Low Voltage Directive. Both the current (2006/95/EC ) and the new (2014/35/EU) LVDs can be accessed at: Electromagnetic Compatibility: EMC Directive-D Both the current (2004/108/EC ) and the new (2014/30/EU) EMC-Ds can be accessed at: OJEU for current LVD (2006/95/EC ) and EMC (2004/108/EC) LVD: EMC: OJEU for new LVD and new EMC TBA

38. Annex 1: Some links cont.
RED Blue Guide R&TTECA REDCA RTTE OJEU RED OJEU TBA (not likely to be released until 2016)

39. Annex 1: Some links cont.
NANDO Data Base: Home Page: Country/UK:

40. For 2004/108/EC (EMC-D): Annex 1: Some links cont.
New EMC-D is listed in the NANDO data base but there are no NBs listed against 2014/30/EU
The reason for doing this is that the new EMC-D has been published but there are no NBs accredited for the new Directive yet.

41. Annex 1: Some links cont.
For 1995/05/EC (R&TTE):

42. Thank you! Questions?!! Andrew Hoare UL VS Ltd andrew.hoare@ul.com