Mario


There's no equivalent in Europe and CISPR 11 is not the right place to look



The Radio Equipment Directive applies to "Radio equipment" which is defined as 
" ..an electrical or electronic product, which intentionally emits and/or 
receives radio waves for the purpose of radio communication and/or 
radiodetermination, or an electrical or electronic product which must be 
completed with an accessory, such as antenna, so as to intentionally emit 
and/or receive radio waves for the purpose of radio communication and/or 
radiodetermination;"



Now, if the device ONLY ever operated when it was inside the human body, you 
might be able to argue that it wasn’t “radio equipment” as it didn’t emit Radio 
Waves, which are defined as “radio waves’ means electromagnetic waves of 
frequencies lower than 3 000 GHz, propagated in space without artificial 
guide;” as they weren’t been propagated in free space – but a counter argument 
would say that they aren’t fully absorbed by the body or subject to 100% 
internal reflection, so would propagate from the body.



Ideally, your product would operate in a suitable radio band as listed in CEPT 
REC 70-03<https://www.ecodocdb.dk/download/25c41779-cd6e/Rec7003e.pdf> or List 
of Class I Frequencies<https://ec.europa.eu/docsroom/documents/40361>, but they 
don’t include 300 MHz as that is allocated to different use in Europe


If it is very low power and really does need to operate at 300MHz, it would be 
possible to bring it to market, but would involve at least one Spectrum 
Regulator and a Notified Body

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247



-----Original Message-----

From: Mario de Aranzeta <[email protected]>

Sent: 04 June 2020 19:58

To: [email protected]

Subject: [PSES] intentional radiator in Europe



In the US we can have an intentional radiator of a very low output power in any 
band except the restricted bands of 15.205 and 15.209.



This allowed under 15.209(a),(c). That is if you can keep the fundamental and 
harmonics under the radiated limits of 15.209.  Is this sort of thing possible 
in Europe.



The device in mind is a medical device that is ingested with the fundamental at 
300 MHz and a field strength under 47 dBuV/m @3m I've looked through EN55011: 
2016  Table 1 and footnotes and can't see that it is or isn't.



Thanks,



Mario de Aranzeta, N4TSV





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