I believe so....
I know that testing and CE Doc update to EN 300 328 v1.8.1 is in process.
by when will it be available for customers?
1.7.1 will be void E / 2014 so customers need an updated document.
Per the instructions here: Broadcom CYW2073XS SiP Module Regulatory Approvals
These can be requested through you local Broadcom Sales/Manufacture's Rep as they are stored internally on a website called Docsafe.
What is the status of the EN300328 v1.8.1 testing?
My opinion is, without these certification we can't sell the SIP in the market.
yes, I got it, but the most EU customers and the certification institutes didn't accept an internal test report. That mean, that they must do the test again. These cost some additional money. I have a such case on my desk.
The risk for the customer is very high to go forward with an internal test report only.
Ok but if you don't want to pass this certification mandatory.
Our customer definitely will choose another module from another supplier.
Does it mean that you will stop to promote those BLE modules?
I will raise the concern with our regulatory team. Please ask you local Broadcom sales channel to do the same.
I spoke to the regulatory team today and they stated that CE (RTTE) compliance can be self-declared based on internal or external test data and that there is no requirement to test in an outside test house.
Please refer to RTTE directive Annex II (see below). Involvement of a Notified Body Opinion is not required either.
CONFORMITY ASSESSMENT PROCEDURE REFERRED TO IN ARTICLE 10(3)
Module A (internal production control)
1. This module describes the procedure whereby the manufacturer or his authorised representative established within the Community, who carries out the obligations laid down in point 2, ensures and declares that the products concerned satisfy the requirements of this Directive that apply to them. The manufacturer or his authorised representative established within the Community must affix the CE marking to each product and draw up a written declaration of conformity.
2. The manufacturer must establish the technical documentation described in point 4 and he or his authorised representative established within the Community must keep it for a period ending at least 10 years after the last product has been manufactured at the disposal of the relevant national authorities of any Member State for inspection purposes.
3. Where neither the manufacturer nor his authorised representative is established within the Community, the obligation to keep the technical documentation available is the responsibility of the person who places the product on the Community market.
4. The technical documentation must enable the conformity of the product with the essential requirements to be assessed. It must cover the design, manufacture and operation of the product, in particular:
- a general description of the product,
- conceptual design and manufacturing drawings and schemes of components, sub-assemblies, circuits, etc.,
- descriptions and explanations necessary for the understanding of said drawings and schemes and the operation of the product,
- a list of the standards referred to in Article 5, applied in full or in part, and descriptions and explanations of the solutions adopted to meet the essential requirements of the Directive where such standards referred to in Article 5 have not been applied or do not exist,
- results of design calculations made, examinations carried out, etc.,
- test reports.
5. The manufacturer or his authorised representative must keep a copy of the declaration of conformity with the technical documentation.
6. The manufacturer must take all measures necessary in order that the manufacturing process ensures compliance of the manufactured products with the technical documentation referred to in point 2 and with the requirements of this Directive that apply to them.
Thank you very much.
I know these. But please aware the following situation in the EU:
Yes, our customer can do their own approval, but they don't like it. The risk for a callback of their complete products in the market is very high and the don't like to have a bad "name " then in the market through a recall.
That mean, the most customers will go with an external certification institute, that the certification approvals are save. So then can avoid the risk for their company.
If Broadcom will not go these way and other suppliers will offer a complete certification after EN300328v1.8.1 with a similar price, then the most customers will use the module from the other vendor.
We like the Broadcom solutions and we will offer your products in the market. But, if we see a problem, then we will inform you, maybe Broadcom is not so familar with some of the european regulations and feelings. Then can Broadcom decide what they like to do.
I have priced out the external certification with the Regulatory team and will approach your local sales management to gain their input on the the decision to see if they feel its necessary as well. If yes, we will present the case to the business unit as they will need to provide the funding for the external testing.
Also, note that this discussion has been moved to the public forum based on its relevance to many others. Please do not mention any customer specifics in the thread.
Here's an update per my discussions with our Regulatory team and the business unit:
Broadcom will engage UL, the original test lab, and arrange a test schedule and report for the BCM20732S to the EN 300 328 v1.8.1.
Broadcom will provide an updated CE DOC.
A letter of similarity on models, BCM20732S, BCM20736S and BCM20737S can be provided as the 3 models are covered under the same ID.
We expect this work will be complete sometime mid-late November.
Thanks for your patience.
Thank you very much!
Some of the standards listed in AoC/DoC and NBSO documents I obtained from rep sales rep need to be updated to the latest standard. The document lists EN 300 328 V1.7.1. Is there any update on AoC/DoC and NBSO documents that include EN 300 328 v1.8.1 yet?