The deficiencies noted in this article are of particular importance to those countries that are still planning to adopt the R&TTE Directive. Many of these countries may not have a mechanism for powerful market protection. According to the directive, testing is no longer necessary. In reality, testing prior to market has simply been exchanged for testing TTE after it has been delivered to the customer.

For years, the approval process inhibited product development because the nature of the process prevented frequent upgrades and product innovation. Moreover, the cost of obtaining approvals put an additional burden on TTE manufacturers. The European Community tried to find a mechanism to make this process easier in multinational Europe. The question is whether this is really possible for TTE, and, if so, under what conditions. The approval process is influenced by standards documents, TTE connection modes, testing, the manufacturing process, and equipment usage and control.

Background

After many experiments to determine the most suitable model for TTE approval, the latest initiative of the European Commission (EC) produced a major change. In 1999, the R&TTE Directive (99/5/EC) was accepted, and by the time it was introduced in April 2000, the EC decided that TTE manufacturers would be responsible for determining equipment requirements and functionality. TTE was to be designed according to demands of the network operator where the equipment was going to operate. The R&TTE Directive is the EC's third attempt to simplify or eliminate the verification of TTEs before they are put on the market.^1,2 As part of the European Union's new approach directives, the R&TTE Directive was designed to meet the following objectives:³

Generally, these goals are valid and valuable for promoting the movement of most goods. Unfortunately, TTE and radio equipment are lumped into the same category as water boilers, elevators, refrigerators, flatirons, and so forth. However, everywhere product certification is mentioned in the verification process, the directive does not require that the product itself be verified. The directive requires only that a product enclosure be verified. All products must fulfill essential requirements. The manufacturer must ensure that the product does not transmit electromagnetic radiation. Likewise, the equipment must be immune to radiation from the environment. Manufacturers must ensure that operators are protected from dangerous voltage from the equipment.

In the case of TTE, however, it is critical that manufacturers ensure that the equipment communicates properly with a telecommunications network (establishing and maintaining a communication channel and using the lower layers of the communication protocol to ensure proper function) and that it communicates with other equipment in the network (ensured by the higher layers of the communication protocol). Figure 1 shows an example of mutual communication in a telecommunications network. A basic condition of free TTE movement, which is not part of the directive however, is the need for a uniform European local loop to be harmonized as a standard. Instead of defining the basis for harmonization "expressed only by essential requirements," the new directive makes the process more complicated for network operators, users, and TTE manufacturers. Of course, the biggest change is that TTE type approval no longer requires third-party testing before a product can enter the market. Manufacturers now simply provide a Declaration of Conformity stating that the product complies with the necessary standards.

Standards

For manufacturers to declare that their telecommunications or radio equipment are compliant, they must first know the standards documents against which it is possible to recognize conformity. Most manufacturers declare that their products comply with all harmonized standards. Much of the equipment tested at the PTT Research Institute, however, is noncompliant. For example, of the integrated services digital network (ISDN) TTEs tested (between 30 and 40 per year), many have been found to be noncompliant with the requirements (primarily for layer 1) specified in TBR 3. Some of the ISDN TTEs tested had been manufactured for more than five years.

The early 1990s marked the beginning of TTE market liberalization in Eastern Europe. At that time, the standards on which TTE approval was based were actually created during technical approval of the equipment. Requirements of analog local loops were defined. In those early years, these loops were the only way to connect TTE to a system. At the same time, the European Telecommunication Standards Institute (ETSI) started to draft its TTE standard (ETS 300 001) with the idea to standardize requirements in European countries.⁴

Agreement had been expected mainly in the area of measurement methods because the use of different techniques for building telecommunications networks in Europe left a legacy not only of different requirements but also in how they should be measured. In practice, this meant that if any value were known and the measurement method was not known, it was not possible then to know whether a given value complied with requirements. Work on this large-scale ETSI document (about 1000 pages) has been finished. The result is that every country has its own method for quantifying requirements, as well as its own measurement methods.

The ETSI standard was built to harmonize the common requirements and, as the essential requirements, only these would be measured and evaluated. In some cases, technical bases for regulation (TBR) documents were needed. In all, ETSI worked out 44 documents: 26 documents for radio equipment and 18 for telecommunications terminal equipment. The R&TTE Directive voided all TBRs for telecommunication equipment. Only TBRs for radio equipment were retained as harmonized documents.

The TBR documents covered mostly the essential requirements of telecommunications equipment transmitter parameters. Receiver parameter requirements were not essential. Using this logic, it could be assumed that both the receiver and all equipment met given requirements on the basis of only the transmitter measurement of a particular TTE. But this is not logical because the TTE receiver is connected to the local loop. The primary and secondary parameters (given by its cable construction and their length) influence the evaluation of the received information.

Putting these two equipment requirements in the directive could lead to problems, especially in light of this statement in one harmonized document: "In some countries, lower current is used in the lines. In case the equipment is connected to the lines, it need not work properly." This greatly affects new network technologies such as ISDN. For example, an ISDN local loop with basic access requires a terminal adapter that can be connected to the digital local loop and that can use classical analog TTEs. ATM networks and access networks with V5.1 or V5.2 signaling also use analog TTEs.

Those who drafted the directive focused on a solution for TTE interface requirements but failed to understand that a key part of the communication problem is located at the public exchange interface. TTE requirements are assigned by the local-loop interface system it is connected to. Two switching systems (S12 and EWSD) have become the dominant systems in Europe.

Even new technologies such as ISDN can be implemented using a specification based on the definition of signaling messages and their elements listed in the standard documents. Digital enhanced cordless telecommunications (DECT) and global system for mobile communications (GSM) equipment manufacturers have introduced solutions to this problem for mobile communications. Using requirements defined in ETSI and CENELEC standards and following common testing procedures enables equipment from different manufacturers to be compatible. Unlike TTEs connected to fixed lines, mobile-communications equipment manufacturers do not depend on transmission medium requirements.

TBR documents are no longer valid for verifying compliance with requirements to obtain technical approval. The directive does not offer an alternative, which essentially contradicts its goal to provide "a mechanism of free movement based on protection against business barriers, on mutual recognition, and on technical harmonization." Of course, if a harmonized document does not exist, the simplest step for network operators is to return to national requirements. Some EU countries have already done this. With the advent of the R&TTE Directive, cooperation on the consolidation of TTE requirements has come to a halt and, therefore, TTE production has become more complicated.

Connection to the Network

Currently, network operators do not have to provide TTE to a customer. TTE is usually customer property and is connected to the subscriber line on the basis of a contract with the service provider. According to the R&TTE Directive, network operators must design and publish TTE connection interfaces. Perhaps interface requirements—especially the layer structure—should be decided by a national operator with a long tradition of offering telecommunications services. It is uncertain what new operators would do to ensure quality operation without an interface definition. The directive essentially forces network operators to hire and train workers to ensure these activities. How can network operators (whose basic task is to offer telecommunication services and ensure network operation) design a basis for all interfaces? Such activities should rest with the manufacturers of switching systems. They know the requirements of their own equipment and have access to complete technical documentation. This is the simplest way to define and publish the technical specifications of an interface. It would also ensure that interface requirements would be published more quickly and more effectively.

Another fault with the directive, which affects the compliance recognition process, was a change of switching systems. During the transition to digital switching systems in Eastern Europe, manufacturers of these systems could make agreements with TTE manufacturers concerning requirements to ensure the use of a uniform interface and uniform signaling criteria on the local loop.

The timing of the transition was unfortunate because the directive states: "Member states shall ensure that operators of telecommunications networks do not refuse to connect telecommunications terminal equipment . . . where that equipment complies with the applicable requirements . . ." Focusing on users is unnecessary because it is unlikely that a user would ever be affected. If users discover that equipment does not work, they usually either throw it away or return it to the place of purchase for a refund. Guidelines are needed to provide direction for registering complaints against manufacturers.

Telecommunication Equipment Production

Previously, a manufacturer was responsible for the design and manufacture of a product with the aim to put it on the market under the company's own name. The R&TTE Directive, however, has changed the definition of a manufacturer. Now, TTE manufacturers or manufacturers of telecommunication equipment in general can label equipment, even if they have only integrated the TTE into a separate system manufactured by someone else. In such cases, a distributor rather than the actual manufacturer declares that equipment requirements have been met. Because they did not design the equipment, however, they are unable to repair faulty equipment. Experience has shown that there are many examples of equipment that are not produced by the manufacturer on the label, even among well-known manufacturers of telecommunication equipment.

Currently, only one approval body exists that provides public documents with the interface requirements of a given country. Manufacturers (with few exceptions) have not been especially interested in these documents. Instead, most manufacturers opt for TTE that has been developed for large customers and then determine whether it could be suitable for other countries. Such equipment could be used only in Europe provided that the interface requirements and signaling criteria are unified as they were in the new GSM and DECT techniques based on the harmonized standards.

It appears that with the advent of the R&TTE Directive, TTE development is now more similar to its development prior to TTE market liberalization in Eastern Europe. For TTE type approval, manufacturers must invest much time and money to ensure that technical requirements for a given country can be met. Much testing is required to ensure that TTE will be compatible with the public telecommunications network equipment and that no problems will arise during its installation and use.

The new directive gives manufacturers the ability to declare that equipment complies with published conditions in a given country, but, in fact, it is impossible to test them against the different country-specific requirements. Because the measurement methods are different, manufacturers must take on the additional cost of testing a product in a particular country. Even if manufacturers are certain that the equipment fulfills specific requirements, they must still negotiate with the competent body in that country to test the equipment. Small manufacturers that may not be able to afford expensive single-purpose test equipment must still follow the same procedure.

Many manufacturers in countries that have adopted the R&TTE Directive do not appear to understand what was really changed. When asked for test results of the requirements to simplify the verification process of telecommunication equipment, the response is often: "We don't have any test results. We don't need to test equipment in our country anymore." What they fail to realize is that, according to the R&TTE Directive, the responsibility falls to the manufacturers to test the equipment themselves or to use a third-party test house to ensure compliance with appropriate standards. The manufacturer must keep test results and documentation for 10 years.

Connection Method

The interface in a telecommunications network is simply defined, and its requirements can be verified even if it is implemented in only a single system (e.g., a switching system) and is produced by only one manufacturer. In the past, there was only a single method for connecting TTE to a switching system. Now the connection method can vary. Figure 1 shows the main components of an access network and the TTE connection. To use that same TTE (using its connection method) on other access networks, it must be verified to ensure that its manufacturers or suppliers can provide the same interface conditions and signaling capability as stated in the switching system. Regulation and verification of equipment supplied for open networks are expected. Such regulation protects TTE users, so that when they change network operators or local-loop accessories, they are not forced to purchase new TTE.

Figure 1. Telecommunications access network interfaces.

An interface defined by the network operator, as required by the R&TTE Directive, rather than by the manufacturer is insufficient. The interface usually defines only requirements that have bearing on the transport medium and the subscriber's plug. Provided that the equipment communicates with a switching system, it is imperative that the requirements be defined for both the subscriber signaling system itself and the testing conditions, including measurement methods. It is also critical that identification of individual interfaces be normalized.

The entire technical approval process, as it is used currently, is focused on protecting TTE users and network operators. The concept of demonstrating homology is based on the testing of essential TTE requirements and on defining the conditions of their connection into the telecommunications network. The EU directives call for essential requirements that have not yet been defined. In the Slovak Republic, however, these requirements were defined in 1991, and, with minor modifications, they are still in use today.

The idea of not providing for verification of TTE requirements and defining conditions for their connection to a network could cause serious problems for equipment set free on the market. Ultimately, this system could force users to buy TTE from the network operator when they subscribe to a service. As a result, TTE manufacturers would have to compete with operators for equipment sales. In addition, this could give rise to a conflict of interest. Manufacturers would try to maintain their long-term relationships with the telecommunication network operators. TTE users would not buy their equipment on the open market, which would cause unequal market conditions for manufacturers and could lead to a less-than-free market for TTE.

Users are generally not technical people, and, therefore, it would become necessary to provide places for them to test their TTE or to seek a technical opinion, which could then be used for a product liability claim.

Market Surveillance

Market conditions such as these would certainly require effective surveillance of the TTE market. Surveillance should be overseen by experts with access to suitable measurement equipment. The group's main tasks should be market protection and removal of unfair competition. Otherwise, the free movement of goods would allow inadequate products onto the market, and the TTE utility value would be demonstrated only once a product was connected to a telecommunication network. Diligent surveillance would require more than simply assessing documents. Physical testing of chosen samples is imperative. In the meantime, testing is the fastest and the most reliable way to verify the information declared by a manufacturer or dealer. Instead of testing equipment before putting it on the market, many products must be tested only after their first connection to the telecommunication network.

Pros and Cons of the Directive

There are certainly some advantages to the R&TTE Directive. TBR documents that did not mention the essential requirements on TTEs, but only on transmitting parts, have been canceled. Effective market surveillance is expected to compensate for the fact that equipment is not tested before it is put onto the market.

However, the R&TTE Directive opens the door to national requirements being defined not only in every country but also independently among various operators within one country. Moreover, it has stopped the progress toward a uniform local loop in Europe.

Production costs for TTE manufacturers will be higher, and they will produce equipment according to the demands of the network operators. By nature, this will increase the variations produced. For TTE manufacturers, the R&TTE Directive complicates their communication with the network operators. In some cases, TTE manufacturers now must obtain interface requirements from the network operators. An unfair market, possibly even an illegal one, may develop. Users could be forced to buy TTE that works with a particular network's system.

Unfortunately, the directive ends more than 15 years' work by the international standards bodies on creating harmonized technical documents. The process of removing unsatisfactory TTEs from the market has been complicated. With the new directive, all the accredited and authorized third parties are excluded from the verification process of technical requirements.

Proposed Solution

A solution to problems created by the directive relies on the development of a technical position rather than an administrative one. Such a solution could be reached with agreement from the telecommunications industry. Several changes are needed for manufacturers to produce TTE that will be sufficient for a common European market. Manufacturers must cancel national specifications of user interfaces and define a uniform digital and analog local loop, including a concept for TTE connection to a telecommunications network. Common essential TTE technical requirements and signaling criteria must be determined so that a uniform switching environment can be developed jointly.

Requirements must be defined that can be adjusted according to the length of the local loops (e.g., for analog equipment). It is essential that requirements be determined with the understanding that signaling criteria on an analog local line can also be transmitted in digital form (e.g., by frequency-shift keying modulation). An agreement must be made on user tones and announcements focused on user information about the connection (a significant number of tones are still used that are not used by the current user of a given network).

Such a telecommunications environment will allow free TTE movement. It will also be easier for manufacturers to produce equipment with uniform communication interfaces for a common European market without forcing buyers to figure out which operator the equipment can be connected to.

Conclusion

The R&TTE Directive could create a number of problems for TTE manufacturers. Telecommunications networks are critical. Without effective control and regulation of the telecommunications environment, the outcome could be disastrous for TTE manufacturers and subscribers.

References