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David
Thanks for your quick and careful review.
We should reword the paragraph that you cited, perhaps: “'Placing products on the market in the European Economic Area (EEA) requires that they are compliant with applicable EU rules (e.g., essential requirements relating to the relevant Union harmonization legislation), and compliance with harmonized standards is a path that provides a presumption of conformity to these rules.”
While the current issue may be resolved in this specific instance with copyright permission, the difficulty created by the lack of an ISO/IEC version of 802.11ax remains and further issues may yet pop up.
Also, if 802.11 revises that table in the future, another round of copyright permission and copying would be required. Having a version of 802.11 as an ISO/IEC standard would make it much easier.
At least that is the feedback that I have been given.
--
James Gilb
IEEE 802 LMSC Chair
Feb 4, 2025, 9:32 AM by 0000363ca596b6f2-dmarc-request@xxxxxxxxxxxxxxxxx:
Hi James,
I note that the draft letter to the IEEE SA president regarding the current status of the PSDO process says, 'Placing products on the market in the European Economic Area (EEA) requires that they are compliant with requirements expressed in HarmonisedStandards (HSs).'. I hate being difficult, but I don't believe this is entirely accurate. Instead, I believe that products have to comply with the applicable EU rules (e.g., essential requirements relating to the relevant Union harmonisation legislation), andcompliance with harmonised standards is a path that provides a presumption of conformity to these rules. I believe this is addressed in an FAQ on the EU's 'Conformity Assessment' website (see below).
As an aside, with respect to addressing the immediate issue related to EN 303 687 (Wireless Access Systems including Radio Local Area Network operation in the license-exempt 6 GHz band), I thought the issue was that it had a normative reference to a singlefigure in IEEE Std 802.11ax-2021. Further, I understood that the IEEE SA had indicated that should they receive a copyright permission request from ETSI to incorporate the IEEE Std 802.11ax-2021 figure directly into the ETSI standard, the IEEE SA was willingto grant permission. Perhaps Jodi could confirm if I have understood correctly.
Best regards,
David
-----
EU Conformity assessment FAQs <> https://europa.eu/youreurope/business/product-requirements/compliance/conformity-assessment/index_en.htm#inline-nav-3> >:
Do you have to follow harmonised standards?
No, the use of harmonised standards remains voluntary. You are free to choose another technical solution to demonstrate compliance with the mandatory legal requirements.
If you choose not to follow harmonised standards in your assessment, you can prove compliance by referring to technical specifications such as national standards, non-harmonised European and international standards, or your own technical specifications.In these cases, you will have to provide more details in your technical documentation explaining how your products comply with legal requirements.
-----Original Message-----
From: ** IEEE 802 LAN-MAN Standards Committee ** <STDS-802-LMSC@xxxxxxxxxxxxxxxxx> On Behalf Of James P. K. Gilb
Sent: 04 February 2025 05:32
To: STDS-802-LMSC@xxxxxxxxxxxxxxxxx
Subject: [802-LMSC] Chairs slides and draft letter to IEEE SA president regarding PSDO process
All
My slides for the 4 February 2025 teleconference can be found at:
https://urldefense.com/v3/__https://mentor.ieee.org/802-ec/dcn/25/ec-25-0012-00-LMSC-chairs-slides-february-2025.odp__;!!NpxR!jduEArR6o41Kf6NEiLUbsXNgx_g36qlNHMhivWe0QgIVlhTPtbw-KMxTRzH_DR5Wn8UsChm9uc5ojgb7K9gWl8Uof3w$
In addition, at the end of the call I would like to discuss a draft letter to the IEEE SA president regarding the current status of the PSDO process. If there is consensus, we will have a short review and then email ballot to approve. The draft can befound on mentor as:
https://urldefense.com/v3/__https://mentor.ieee.org/802-ec/dcn/25/ec-25-0027-00-LMSC-ieee-sa-president-regarding-psdo-process.docx__;!!NpxR!jduEArR6o41Kf6NEiLUbsXNgx_g36qlNHMhivWe0QgIVlhTPtbw-KMxTRzH_DR5Wn8UsChm9uc5ojgb7K9gW64FtUIU$
--
James Gilb
IEEE 802 LMSC Chair
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