Do passive RFID tags fall under the RTTE Directive and require to be CE Marked?

Both readers and transponders shall bear the CE marking. In the case of small, passive transponders1 supplied independently of readers, it may be appropriate to apply the CE marking to packaging rather than the transponder itself. In all cases, appropriate user information should be supplied. In the case of small, passive transponders supplied independently of readers the user information may be provided with each batch of transponders delivered to the supplier using them for stock identification etc. For the purposes of Article 6.3 of the R&TTE Directive, the supplier of the product incorporating the transponder or to which the transponder is attached shall be regarded as the user of the transponder and not the eventual purchaser of the product itself.

Please also refer to TGN12 from the RTTECA, which is freely available from here: http://www.rtteca.com/html/download_area.htm

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Is mobile installation a new requirement, how is this CE marked?

Mobile installations cannot fall under the fixed installations requirement as they do not fall under a pre-defined location. Mobile installations therefore follow the apparatus route to compliance. Trains for example are mobile apparatus and have their own harmonised standards.

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I only have a certificate for my product, is that OK?

Without seeing the certificate it is difficult to say, we would need to check the standards applied, the testing organisation etc.. If it checked out a certificate could be ok (especially if it is for “certification” of the product eg: for GS mark, TÜV, VDE etc. as these can be verified on-line and would indicate that the product has been properly tested).

Our recommendation is to always obtain the report as this contains details of the testing conducted and the components/material used for the product.

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My company supplies products to OEMs who usually wish to label the product with their own details. What are are labelling requirements? What do we need to put on our product label?

The labelling requirements are the same. The CE marking must be affixed provided the products fall within the scope of an applicable Directive along with any other markings required for the device in question (e.g. manufacturer, model number / type reference, crossed wheelie bin). If the OEM replaces your label with their own it is their responsibility to ensure the correct markings remain and moreover to ensure adequate information remains to make sure it correlates with the Declaration of Conformity.

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How would an importer set up a manufacturing process, if he takes responsibility for equipment imported into the EU via the R&TTED?

The importer does not need to set up a manufacturing process to take responsibility for the product under the RTTED. But they do need to have access to the Technical Documentation and be able to draw up the Declaration of Conformity and apply the CE Mark. Alan Binks Page 2 of 5 1st March 2010

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Our products are too large to test in an EMC Chamber. What testing am I expected to carry out on my products?

If it is not feasible to test a product in an EMC chamber then in order to satisfy the essential requirements there will need to be a combination of in-situ testing and Risk Analysis work. The in-situ testing can be conducted either at your facilities or at the final place of installation. The tests conducted would be dependant on the equipments location. It may not be feasible or practically possible to conduct certain tests. The technical documentation produced will therefore need to take into account all of the phenomena applicable to equipment in its operating environment. Where tests cannot be performed in-situ then technical rationale will need to be produced and include the good EMC engineering practises that have been employed. This might include shielding, cable segregation and maybe the addition of EMC filters. Installation and maintenance guidance with respect to EMC will also need to be supplied.

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Can I just up-issue my Declaration of Conformity to show compliance against the New Directive?

Some issues before doing this:

Analyse if product meets the latest harmonised EMC standards,

If standards to which product was previously tested are out of date then a comparison needs to be made for each individual test to determine if there are now more onerous requirements (for example your product may not meet all of the requirements for Radiated Immunity due to increases in frequency ranges for test and some test levels)

Depending on the results of this gap analysis it might be possible to base compliance upon technical rationale. If not then further testing may be required.

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