Impact of Non-Listing of EN 303.687 in European Market

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Coex SC received an update on ETSI BRAN activities and identified the risk of EN 303.687 not being listed in the OJEU, affecting self-certification process for European market placement. Request for feedback was sent to IEEE staff and 802 Coex SC Chair. Feedback session took place in May 2024 meeting with updates provided by Jodi Haasz and James Gilb.

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May 2024 doc.: IEEE 802.11-24/0922r0 Impact of non-listing of EN 303 687 in the OJEU Date: 2024-05-14 Authors: Name Marc Emmelmann Affiliations SELF Address Berlin, Germany Phone email emmelmann@ieee.org Submission Slide 1 Marc Emmelmann, SELF

May 2024 doc.: IEEE 802.11-24/0922r0 Abstract Coex SC received an update on ETSI BRAN activities during the March 2024 meeting. The update identified the potential risk that EN 303 687 is not listed in the OJEU as it includes a normative reference to 802.11ax. This prevents manufacturers from applying the self-certification process to place their products on the European market. The Coex SC requested the SC chair to follow up with IEEE staff on this issue regarding steps taken by IEEE on that matter. This slides acts as a summary for this action and as a discussion point for the May 2024 Coex session to which IEEE staff and the 802 Chair are invited to update the SC on this matter Slide 2 Submission Marc Emmelmann, SELF

May 2024 doc.: IEEE 802.11-24/0922r0 Request for feedback sent to IEEE staff and 802 Coex SC Chair contacted on March 15, 2024: Jodi Haasz (IEEE staff), Dorothy Stanley and Robert Stacey (outgoing and incoming 802.11 Chairs), Paul Nikolich and James Gilb (outgoing and incoming 802 Chairs), and Joseph Levy and David Law Request sent: It is likely that the European Commission (EC) will not list Version 1.1.1 of Harmonized Standard (HS) EN 303 687 (Wireless Access System / Radio Local Area Network in the license-exempt 6GHz band) in the Official Journal of the EU (OJEU). This HS contains a normative reference to IEEE Std 802.11ax- 2021. If it denied, the HS cannot be used to provide presumption of conformity. The EC criticizes that the HS contains a normative reference to an IEEE standard. According to IEEE 802.11 members, the EC explained to ETSI that it only recognizes ISO, IEC, and ITU as SDOs. Because the EC does not recognize IEEE as an SDO, the EC does not permit standards listed in the OJEU to refer to IEEE standards as normative references. Without the HS listed in the OJEU, manufactures need to seek approval of their products by a notified body to place their product on the market of the EEA (European Economic Area). Only if the HS is listed in the OJEU, manufacturers can apply self-certification as an alternative to gaining approval by a notified body. Seeking notified body approval is a time consuming and costly process as compared to self-certification. The attendees of the 802.11 Coexistence Standing Committee (SC) tasked me in my capacity as Chair of the SC to contact you to seek information on how the SA is addressing or plans to address this issue. I am asked to provide feedback at the next IEEE 802.11 meeting in May and I would appreciate if you could provide me with an update by April 30th, 2024. Submission Slide 3 Marc Emmelmann, SELF

May 2024 doc.: IEEE 802.11-24/0922r0 Feedback to Coex SC Coex SC Chair approached IEEE staff and the 802 Chair again during the May 2024 meeting. Jodi Haaze (IEEE program management) and James Gilb (802 Chair) volunteered to attend the Coex SC session (Tuesday PM1) in May to provide the group with an update and engage in subsequent discussion. Feedback will be included in the Coex SC May 2024 meeting minutes. Submission Slide 4 Marc Emmelmann, SELF