Good answer. I agree. I think it's a good idea to get a cross section of opinion on this issue.
tony_fredriks...@netpower.com ---------- From: tjmeck To: emc-p...@ieee.org; jlovell%mfg.trim...@ngmsmtp.trimble.com; rfm; Tony Fredriksson Subject: RE: CE Mark product standards for purchased equipment List-Post: emc-pstc@listserv.ieee.org Date: Tuesday, March 11, 1997 3:14PM Priority: High Hello: Wouldn't this fall into `due diligence'. The system integrator's record of compliance and proper files may provide basis for pleading, in a credible way, proper intent. Also, I thought the purpose of the regulations allowing individual components to be CE marked was to provide a `reasonable' amount of certainty of compliance. However, if the system is a standard product configuration why wouldn't the integrated have tested this configuration? Remember this is only my personal novice interpretation! > From: Tony Fredriksson <tony_fredriks...@netpower.com> > To: "emc-p...@ieee.org" <emc-p...@ieee.org>, > "jlovell%mfg.trim...@ngmsmtp.trimble.com" <jlovell%mfg.trim...@ngmsmtp.trimble.com>, > rfm <r...@itsqs.com> > Subject: RE: CE Mark product standards for purchased equipment > Date: Tue, 11 Mar 97 08:36:00 PST > Reply-to: Tony Fredriksson <tony_fredriks...@netpower.com> > > Hi, > > This is very intriguing. Let me throw out a scenario > for comment. Let's say that I have a PC with CE > marking and I integrate a video card and 15" monitor, > also with CE Marking, and all declared to Class B > levels. > > Now suppose I import the system to Germany and don't > test to verify the combination since these "new > guidelines" say that it is OK to do so based on the > fact that all of the items bear the CE Marking. The > authorities obtain a sample, test it, and find that > video emissions are over the Class B limits at > multiple frequencies (this happens all the time by > the way). > > Let's also say that it is the particular > monitor/video card combination that is the problem. > Each manufacturer can demonstrate Class B compliance > on some other combination of their respective > products with some other CE marked support device. > Each vendor has supporting documentation from a > legitimate test lab to support their declarations. > > How will the authorities decide who is at fault? The > EMC directive says that the manufacturer or his > authorized rep within the Community shall affix the > CE Marking and certify conformity. In this case, the > monitor vendor can point a finger at the system and > video card vendor, the system vendor can point a > finger at the monitor and video card vendors, and the > video card vendor can implicate the system and > monitor vendors. > > Won't the authorities ultimately go after the system > vendor for integrating the stuff and placing it on > the market without testing to verify comliance with > the applicable directives? If this is the case, the > new guidelines would not appear to have any practical > application. > > All comments on this scenario would be helpful! > > Regards, > tony_fredriks...@netpower.com > > ---------- > From: rfm > To: emc-p...@ieee.org; > jlovell%mfg.trim...@ngmsmtp.trimble.com Subject: RE: > CE Mark product standards for purchased equipment > Date: Tuesday, March 11, 1997 7:42AM > > The 'new' guidelines on interpreting the EMC > directive allow for the integration of multiple CE > marked products without having to retest the full > system. The caveat in that however is that the CE > marking must be "relevant". That is, the original CE > mark must have been applied based on tests which are > equivalent to the environment that you are planning > for the system. > > The fact that you say the printers "were not designed > for these severe spikes..." indicates that they were > NOT marked based on relevant standards. You must > therefore fully test them in accordance with the > appropriate standards as part of your system. > > > Bob Martin, PE, NCE > EMC Department Manager > ITS-Boxborough > (508)263-2662 > (508)266-1870 fax > r...@inchqs.com > ______________ > The views expressed are my own and not necessarily > those of my employer. > ------------------------ > ---------- > From: jlovell%mfg.trim...@ngmsmtp.trimble.com > To: emc-p...@ieee.org > Subject: CE Mark product standards for purchased > equipment Date: Monday, March 10, 1997 2:07PM > > > Hi, > > We are producing a product for use in marine > navigation. It is an intentional transmitter, so we > are getting it type-approved by a notified body, the > DRA in the UK. DRA has told us ETS300339 is the > relevant product standard. ETS300339 calls for most > of the usual emissions and immunity tests such as > EN55022 and IEC1000-4-x, but it also calls for > testing to ISO7637, an automotive spike and surge > immunity standard. > > The system will ship with a choice of printers that > are DC-powered at 12 to 24 volts and that are > purchased CE-marked from a reputable printer > manufacturer. > > My question is: do these off-the-shelf printers have > to comply with ISO7637 because they are part of this > larger system, or can they stand alone with their > current CE marking? The printers were not designed > for these severe spikes and surges and will likely > fail. > > ------------------------------------------ > John Lovell > Director of Quality > Trimble Navigation Ltd. > +408-481-2012 Voice > +408-481-8194 FAX > john_lov...@trimble.com > ------------------------------------------ Best regards, Terry J. Meck Senior QA/Test Engineer 215-721-5280 tjm...@accusort.com Accu-Sort Systems Inc. Telford, Pa USA
