Coping with the EU Radio Equipment Directive in the automotive industry
08 October 2018
The wireless world is having a significant impact on the automotive supply chain. As levels of connectivity increase, and the automotive industry introduces ever-more complex and convergent technologies, so too does the compliance process become increasingly intricate and unpredictable – as this piece discusses.
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Economic operators associated with the automotive industry (vehicle and radio equipment manufacturers, importers, integrators of radio equipment and distributors) now have the EU’s Radio Equipment Directive 2014/53/EU (RED) to deal with, and must ensure that they have implemented their responsibilities accordingly. The RED is applicable to all electrical and electronic devices that intentionally emit and receive radio waves at frequencies below 3,000 GHz.
The obligations of the various economic operators depend on whether the host vehicle is a type approved vehicle for use on a public highway or not.
Road vehicles for use on the public highway must be type approved before they can be registered and used. There is various European legislation presently in force covering such automotive type approvals, for example, the Whole Vehicle Framework Directive 2007/46/EC, as amended by EU 2015/166. Type approved vehicles include, for example, cars, trucks, trailers and caravans, and in Europe fall under the ‘e Marking’ EC/EU directives and regulations.
The other separate vehicle regulation for ‘e marking’ are the familiar UNECE (United Nations Economic Commission for Europe) regulations, which includes Regulation 10 for EMC (Electromagnetic Compatibility).
The application of the RED to vehicles is partially addressed in the RED Guide to the Radio Equipment Directive 2014/53/EU (Section 188.8.131.52 Radio equipment installed in vehicles), which is available from the European Commission Europa website.
A radio product for use in a type approved vehicle needs to fully comply with the RED and all applicable European legislation for that radio, unless specifically falling within any exceptions of the RED. Thought should be given to the responsibility of which economic operator is making the radio product available and/or placing the product on the market, as this could be the type approved vehicle manufacturer which integrated the radio module.
Vehicles that are not for use on the public highway and are not subject to type approval will be subject to other applicable European legislation and directives, for example the RED and Machinery Directive. This effectively makes the entire vehicle fall under the scope of the RED when the vehicle is not under the scope of a type approval regime.
Such a vehicle without type approval, but with an installed radio product, can then be defined as ‘combined equipment’ and there is RED guidance for this (for example ETSI Guide EG 203 367 V1.1.1). Vehicles that are not type approved for the public highway require CE marking against the applicable directives.
Importantly, the radio product manufacturer needs to consider the intended use and environmental conditions of the radio product in the host vehicle for all applicable RED essential requirements, as well as RED Article 3.1(a) which covers health and safety, and reasonably foreseeable conditions.
Aftermarket radio products
Aftermarket radio products that can be fitted by end users and/or dealerships have additional RED consideration for compliance, and the risk assessment must consider the intended use of the radio in the vehicle.
It is important to note that the RED guide states a radio equipment installer/integrator is considered to be the manufacturer of the radio equipment if:
• the compliance of the host is impacted because the instructions provided for the radio equipment were not followed; or
• the intended function or performance of the host product is modified.
Radio spectrum requirements
In the automotive industry, the most significant change is that radio broadcast receivers are now included within the scope of the RED.
Additionally, vehicles which use automotive radar equipment for collision avoidance and proximity sensing, as well as Global Navigation Satellite System (GNSS) tracking, also fall under the scope of the RED, as they are radiodetermination products.
ETSI (www.etsi.org) has produced several new RED harmonised standards for the purpose of testing such products. Consequently, many manufacturers are finding achieving compliance to be a significant challenge as they have not been previously required to undertake RF testing. The added complexity is that radio equipment being placed into vehicles needs to consider the possible compatibility problems associated with multiple radio transmitters and receivers operating in close proximity to each other.
RED and vehicle EMC requirements do not align, and this should be considered by radio and vehicle manufacturers when deciding a sensible compliance strategy and risk assessment for a product. Differences include the test frequency ranges and immunity levels.
It should also be noted that RED EMC testing is focused on the radio EMC performance. In contrast, vehicle electromagnetic (EM) requirements include EMC and Electromagnetic Safety (EMS) compliance. This must not be confused with the RED Article 3.1a health and safety requirements, which remains mandatory for all radio equipment under the scope of the RED.
The significant risk for system critical radio products associated with vehicle safety, such as radar collision avoidance EM testing, obviously needs additional compliance considerations compared to, for example, an FM/DAB car radio receiver.
Health and safety requirements
Although the radio equipment manufacturer may supply a RED health and safety assessment, this may not consider all of the intended operating modes and environmental conditions for its use in the vehicle. This is an important aspect for radio equipment integrators to consider, so that overall vehicle safety is not impacted.
Assessing the risk
The risk assessment for both manufacturers of radio equipment and integrators of radio equipment into vehicles remains a critical part of the regulatory compliance process, which should be instigated at the start of the conformity assessment process.
It is important to remember to demonstrate compliance, with the aim to reduce (mitigate) the risk as far as practicably possible by, for example, compliance testing and user guidance. Since the intended use and environmental conditions of radio equipment in vehicles may well be more safety critical/onerous then a standalone radio product, this should be carefully considered in the risk assessment by the manufacturer.
The RED has introduced a range of new responsibilities for the entire automotive supply chain, including responsibility for product traceability, risk analysis and assessment, sample testing, and, if required, a register of complaints and product recalls. These radio equipment compliance considerations will only increase as vehicles achieve higher levels of SAE (Society of Automotive Engineers) autonomous capability.
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