Wow, Chris, this IS an interesting question - but don't you find that the trickiest questions are often the simplest..
This is a question that my company has agonized over - and the answer we have come up with is YES oh and NO!! Superficially the EMC specification is clear - you MUST CE mark anything that is sold to an end user & clearly an upgrade fits in that category. But the situation is NOT so clear when a company attempts to implement the standard in such a way that does not bankrupt the company. For example, our products have a shelf life of >25 years. The products we manufacture usually are a significant capital investment to our customers and our customers buy new products on an infrequent basis. BUT they do buy upgrades..get the picture? Some of our early products barley passed emissions and will NOT pass the immunity standards so we have the same quandary you do with the added cost burden of "fixes" to bring the older products into compliance. So, in a long-winded fashion, we: a) For "old" mature pre-1996 units we sell the upgrade WITHOUT the CE mark. But we DO perform an emissions test to the previous EMI standard the product was qualified for to ensure we are NOT a source of EM interference. Yes this means the old VDE spec..don't throw away the loop!! Recently we tested a power supply upgrade to one of our products to VDE Class B - the products original specification! Yes, we recognize that we are not fullfilling ALL the requirments of the EMC directive, but we feel that to do so in ALL case would be ruinious. Besides we have a successful track record with the newer products to demonstrate "good faith". b) For newer products we ensure the upgrade HAS the CE mark. Time will tell if our approach is OK. Chas Grasso --------------------------( Forwarded letter 1 follows )--------------------- X-Router: (TAO/SMTP Gateway 1.1.34) <emc2m...@ccsvm.stortek.com> Received: from stortek.com by CCSVM.STORTEK.COM (IBM VM SMTP V2R3) with TCP; Fri, 25 Oct 96 08:18:51 MDT Received: from ruebert.ieee.org by stortek.com with SMTP id AA05505 (5.65c/IDA-1.4.4); Fri, 25 Oct 1996 08:19:10 -0600 Received: (from daemon@localhost) by ruebert.ieee.org (8.7.5/8.7.3) id JAA23740 for emc-pstc-list; Fri, 25 Oct 1996 09:50:18 -0400 (EDT) Message-Id: <199610251347.oaa27...@netserver.fisonssurf.co.uk> Comments: Authenticated sender is <cdupres@[193.130.56.129]> From: "Chris Dupres" <cdup...@vgmicrotech.com.smtp> To: emc-p...@ieee.org List-Post: emc-pstc@listserv.ieee.org Date: Fri, 25 Oct 1996 14:41:56 +0000 Mime-Version: 1.0 Content-Type: text/plain; charset=US-ASCII Content-Transfer-Encoding: 7BIT Subject: Field Upgrades. Priority: normal X-Mailer: Pegasus Mail for Windows (v2.42a) Sender: owner-emc-p...@mail.ieee.org.smtp Precedence: bulk Reply-To: "Chris Dupres" <cdup...@vgmicrotech.com.smtp> X-Resent-To: Multiple Recipients <emc-p...@majordomo.ieee.org> X-Listname: emc-pstc X-List-Description: Product Safety Tech. Committee, EMC Society X-Info: Help requests to emc-pstc-requ...@majordomo.ieee.org X-Info: [Un]Subscribe requests to majord...@majordomo.ieee.org X-Moderator-Address: emc-pstc-appro...@majordomo.ieee.org Gentlemen, and Ladies, and 'others'. A simple question, but one that I couldn't provide a one paragraph answer to.. 1. We sold a piece of equipment, well before the time CE marking became relevant, to a customer in Europe. 2. We now sell this customer an 'upgrade' kit which essentially allows him to have two outputs, rather than one. The question is, does the equipment need to be EMC certified and CE marked before it's put back into service? I look forward to the learned opinions of the group. Regards, Chris Dupres EMC Specialist. VG Microtech. cdup...@vgmicrotech.com tel +44 (0) 1825 761077 fax +44 (0) 1825 768343 'Opinions expressed are personal, not necessarily Corporate'
