Is there anywhere on the TTN website that you are aware of that makes this clear? It’s certainly not something that I’ve found in my reading and I think it should probably be a bit more obvious!
If you use TTN hardware (when available) this won’t really be an issue because it will be CE and LoraWAN certified.
If you really want to play it safe, you will need to use a certified gateway, e.g. TTN, Conduit etc, and certified radio’s, e.g. the RN2483 with the antenna it was certified with (a regular whip). Technically and legally you are then in the clear.
That being said, most TTN’ers at this moment don’t give a wooden nickel about certification and liabilities and happily use hardware that are only meant for demonstration or evaluation purposes. Chances are indeed quite low anyone would complain about it. For now at least.
Even if the RN2483 is certified as a module you’ll always to re-recertify your final device where the RN2483 mounts to otherwise you’re not really in the clear especially since the RN2483 requires RF traces on the PCB and an extra microcontroller.
The issue is two fold. Epyon is correct in that many TTNers are ignorant of local laws or ignoring them. Secondly, they are local laws so each country may differ (commonality in EU?). If I remember right, Mark Stanley (Reading TTN, UK TTN) has been in contact with OfCom in the UK but didn’t receive any guidance regarding TTN.
I’d still suggest a less alarmist approach. It does appear* that self-certified devices are likely possible from my reading (eg. http://www.conformance.co.uk/adirectives/doku.php?id=cemarking) where the RF components have already been certified.
showing the best paths through
It seems from my point of view that because the information on CE marking, and particularly the RF side is quite closed off (behind paid services, inside companies with specialists, behind paywalls) there is a general approach that certification is difficult, troublesome and expensive.
While certification does exist to specify safe operation of consumer equipment and to ensure the free usage of the RF spectrum; it’s not specifically there to stifle innovation. And there are ways to get devices certified. The testing and certification means builders have to have made all the relevant checks to their devices, and to certify liability if they are incorrect.
I’m aware that there are specialists out there with more complete knowledge of the process, and I’d like to encourage them to speak up if there are any obvious routes through how someone can build and deploy their own devices in the UK. Otherwise (while I’m aware that warnings of dire consequences are appropriate) it’s also worth showing the best paths through the legal thicket path, rather than just saying “you can’t do that” .
*) I’m currently working through the process of how to certify an iC880a+RPi device and would like to be as open as possible through that process.
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This is a very sensible approach IMHO and having had time to reflect since my initial “OMG, IT’S ALL ON FIRE!!!” response from earlier, I’m now considering the following approach:
If the requirement is that the radio part of the device is certified, then if part of the kit is a pre-soldered radio chip/PCB/Arduino/Antennae with headers that sensors can be soldered on to by others, then in theory I should be safe as far as the sensors are concerned
I can then work on the gateway certification (or just move to a pre-certified gateway!)
Just wondering, is there any historical reason why the legislation is that rigid in the UK when compared to other countries?
The requirement is that the whole device is certified - not just parts of it. The radio part being certified just helps you make the claim that the device will meet the certification (you can reuse the radio part and skip some but not all of the testing)
The UK is actually quite lax compared to other countries like Germany - at least on the actual implementation/enforcement. In Germany you’d need certification, WEEE (waste electronics) management plans etc.
I wonder if the gateways could fall under “Radio equipment for radio amateurs, unless it is commercially available” given that I do not intend to charge for the finished product but supply it “at cost”…
If you keep the traces and the antenna identical as used during radio certification (Microchip gives the layout in documentation) you should be okay. Certification is then only paperwork, and some would even take the risk to do it afterwards.
Also, like I read it @proffalken use case is demonstration on the node side: people use it to learn to solder, experiment with it but don’t use it permanently. The gateway stays on permanently, to allow the users to experiment.
This is a sensible approach. In theory, you aren’t even the integrator but only the part supplier, relieving you from certification needs. Just make sure your gateway is certified and you should be in the clear.
Amateur radio operators - and the language means licensed amateurs - cannot, other than in very specific cases, encrypt communications, however that encryption is a core feature of LoRaWAN.
I’m sure many users would expect to keep using their nodes permanently after they soldered them.
As to who is the integrator you can also supply a Raspberry Pi and the ic880a and let the final user be the “integrator”. To me there is no difference, actually in the gateway you may be in a better position because both boards are finished, tested, products
I don’t want to speak for @proffalken, but that probably wouldn’t fit in the price point he is targetting 
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What else would one do with soldered boards other than give them to whoever assembled them? Unsolder everything again for future workshops?
That reminds me I bet he hasn’t looked into RoHS compliance either … 
Maybe we need a LoRa workshop cruise - run on international waters 
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Thanks all,
I’ve look briefly into RoHS Compliance, but that’s for another day.
For now, I have answers to most of the questions I had, now I need to get the backbone up and running!
Matt
Hi Folks,
There’s a new reoprt on the Ofcom site - https://www.ofcom.org.uk/__data/assets/pdf_file/0031/98275/Review-of-latest-developments-in-the-Internet-of-Things.pdf
It is 143 pages of joy - something for the weekend?
Cheers, Mark
Was there a conclusion to this thread?
Is it illegal for someone in the UK to run a gateway as it is a publicly available?
On the CE side, there’s an explainer video from eevblog that went up the other day: https://youtu.be/f0uvS80YIGU
‘Sound and fury signifying nothing’ and I’m not sure that I’m adding too much to this discussion but I pulled out of design when the onus of CE arrived - take it too strictly and it become prohibitively expensive. There are however a few points:- a) this CE marked product has become available http://shop.imst.de/wireless-modules/lora-products/36/lite-gateway-demonstration-platform-for-lora-technology?c=7 b) sensible self certification is an option particularly if you consider the manner in which the German authorities police their system compared to our complaint driven system (after all an engineer actually going to jail when so few rouge Directors roam the streets). ‘Chwarae Teg’ as they say here in Wales. c) technically, under the 1949 WTA flashing your cars headlights is an offense and d) a lot of the above does sound like the sort of ludicrous stories we are hearing about planes being grounded if deals are not found which leads me onto e) Brexit … nope I’m just going to have to give up (again) … sigh!