1. STF 279 Changes to be introduced to ETSI Guide ETSI EG 201 299 v1.3.1 & Pro-forma ETSI SR 001 470 v1.1.6 Document STF 279 020

2. 28 February 2005STF 2792 Substance of Guide and Pro-forma remains sound EG & SR could have been applied more rigourously Tone & context no longer appropriate Different emphasis would be appropriate Introduction

3. 28 February 2005STF 2793 Proposed Changes EG & SR should be combined Editorial Elements of the SR Pro-forma should be incorporated in the materials supported by Edithelp Background information in section 4 of EG to be removed Any information in section 4 should be retained in an annex Standard indroduction in pro-forma should incorporated into EG as an annex Scope of HS to be unambiguous Use of expressions such as test suite, ERTS & other test suites to be reviewed

4. 28 February 2005STF 2794 Proposed Changes EN-RT should be mandatory and restructered to remove ambiguity Where HS covers apperatus intended to be available seperately, then separate EN-RT should be generated for each part EG should clarify that generally Rx parameters (other than Spurious emissions) are not to be specified in HS unless Rx directly affects Tx parameters, or a 3.3 requirement has to be fulfilled Normative References must be uniquely identified unless reference to a HS is made (at the discretion of the TB)

5. 28 February 2005STF 2795 Proposed Changes Informative text etc may be included in HS (but clearly identified as such) Where relationship between requirement/test and corresponding essential requirement is not evident rationale for inclusion should be provided Section 6 of EG to be decoupled from annex A integrating relevant concepts from A.2 into section 6 with a checklist for confirming relevance to essential requirements The justification of all requirements against the decision tree should be removed Where TB deviates from the guidence, OCG chair should be informed

6. 28 February 2005STF 2796 Proposed Changes Where equipment Scoped in HS is the object of other legislation the HS must not include normative info with regard to that other legislation unless there is an explicit cross reference in the legislation itself. Where there is no such cross reference, informative references to such legislation can be made without giving the impression that complience with HS gives presumption of conformity with anything other than R&TTE. HS should address complete application of one essential requirement under R&TTE. If not this must be made clear Informative references to specific requirements/tests relevant to essential requirements outside the scope of the HS should not be made Guidence concerning Antennas in EG should reflect the further deliberations in TCAM

7. 28 February 2005STF 2797 Because of the regulatory status of a HS, statements of the following types should be avoided: Statements referring to the role of national authorities in general, for example indicating that national authorities may relax the standards requirements, ignore them or make them more severe. Statements concerning the legal responsibilities or legal roles of parties involved (manufacturers, operators, authorities etc.). Statements referring to sales restrictions, legal sanctions, obligations for entering the market, ban of sales, contractual arrangements/ relations between parties. Statements imposing obligations outside the scope of the standards, for example an obligation to perform tests in locations defined by non-technical parameters, such as manufacturers premises or third party laboratories. Note: Only technical requirements may be imposed to test locations.

8. 28 February 2005STF 2798 Statements to be avoided: Statements related to cases of dispute, such as "In case of dispute, the method used by the manufacturer shall be used". Note: Where alternative test methods are provided, the principle should be that compliance with the requirements may be demonstrated by either or any of the methods described in the standard. Statements including dates of regulatory application Note: If ETSI Technical Bodies find it useful to give advice in such matters, it should be done in separate documents and not included in the text of standards. This does not apply to information about national transposition of standards. Statements introducing provisional limits or requirements.

9. 28 February 2005STF 2799 Other Proposed Changes The ETSI Technical Officer concerned should be pro- active in his/her role of advising Technical Bodies about the drafting guidance. When considering revision of HS, TB must take due account of implementation costs for industry. HS titles should be translated into all the EU languages.

10. 28 February 2005STF 27910 Essential Radio Test Suite (ERTS) Apperatus meets relevant HS (complying with all normative requirements/tests) = Member States presume compliance with essential requirements covered by the standard Unless HS allows normative tests to be applied on a selective basis dependent apperatus features Relevant parts of HS applied in full to achieve compliance

11. 28 February 2005STF 27911 ERTS Not permitted for manufacturer, at his own discretion to mix and match normative requirements/tests STF279 believes these requirements precident when seeking to establish the presumption of compliance This principal must be clear in all HS If a particular test may be omitted or alternative used then the test cannot have normative status (although underlying requirement is normative) The understanding of EN-RT, ERTS and Other Test Suits must respect this principal

12. 28 February 2005STF 27912 ERTS Proposal IN R&TTE ERTS Applies only to Tx STF279 considers Rx parameters may be pertinent to R&TTE essential requirements STF279 proposes the concept of ERTS can be applied to the above cases (for Rx) ERTS becomes the totality of normative tests specified in a HS

13. 28 February 2005STF 27913 Conclusion Current EG states test methods should be specified only where …the value obtained may vary according to the method of measurement employed… Accordingly tests specified become part of the ERTS Where no tests are specified in HS they are addressed as Other test suites of the manufacturers choosing