Darrell, This is my general understanding of the FCC Rules regarding keyboards. A keyboard is considered a peripheral device under 15.3(r). As such it is subject to, Declaration of Conformity or Certification under 15.101(a) . This may or may not apply to your product. *All views are my own and not those of my employer* Ray M
______________________________ Reply Separator _________________________________ Subject: Re: CE Marked Subassemblies & Components Author: "Jim Hulbert" <hulbe...@pb.com> at internet List-Post: emc-pstc@listserv.ieee.org Date: 6/12/97 5:00 PM I agree that your keyboard subassemblies in and of themselves need not be CE marked or FCC certified if they not sold to the end user. It sounds from your description that they are sold to a system integrator who in turn sells the final system to the end user. The system integrator is responsible for the compliance of the whole system, which will include your keyboard. The system integrator, however, would expect that the subassembly you supply for use in his system would be designed with EMC in mind and would not cause his system to fail EMC testing. I don't see how you as a supplier can guarantee that without doing some testing of your own. It is perfectly acceptable for a system integrator to use different suppliers' subsystems (i.e. PC chassis, monitor, keyboard, mouse, printer, etc...) that are individually CE marked and declare system compliance with the EMC Directive, provided that any conditions of the CE marking for the subsystems (i.e. use of shielded cables, etc...) are strictly followed. However, it is wise for the system integrator to make sure CE marked subsystems have in fact been properly tested for compliance. I would request, as a minimum, a copy of the test report. If the manufacturer can't or won't supply test data, I would either test myself or find another vendor for that subsystem. The same goes for systems assembled from individually FCC certified subsystems. When a product is CE marked, I don't believe it is ever necessary to list the representative systems the product was tested in on the Declaration of Conformity. The DoC should list the Directives that are met and the standards that were applied. If there is a wide variety of possible system configurations, it may be wise to follow the TCF route to compliance. In that case the DoC should name the competent body that assessed the TCF. One final note, CE marking (or FCC certification) is generally only appropriate for equipment or subsystems that have an intrinsic function for an end user, such as a PC or a CRT monitor. It is generally not appropriate for individual components that in and of themselves have no intrinsic function. If you assemble a product from "uncertifiable" components, obviously you are obligated to do complete compliance testing on the final product yourself because you place your product on the market. *All views are my own and not those of my employer* ______________________________________________________________________ Jim Hulbert Tel: 203-924-3621 Senior Engineer - EMC Fax: 203-924-3352 Pitney Bowes email: hulbe...@pb.com P.O. Box 3000 35 Waterview Drive Shelton, CT 06484-8000 U.S.A. ______________________________ Reply Separator _________________________________ Subject: CE Marked Subassemblies & Components Author: dlo...@advanced-input.com at SMTPGWY List-Post: emc-pstc@listserv.ieee.org Date: 6/11/97 9:46 PM We manufacture application specific subassemblies (keyboards) that are used on special computer systems, workstations etc. We typically do not place these goods on the market, as they are designed specifically for a particular system, and have no intrinsic functions of their own. Sometimes our customers who are the system integrators will ask for the CE Mark or FCC certification. We explain that this is really putting the cart before the horse as the "system" is what must be tested and CE Marked or FCC certified. I have noticed that desktop computer subassemblies are often CE Marked, even when the same manufactuerer logo is on the whole system. I would assume that these subassemblies (i.e. keyboards) can be used with several systems, and are consequently tested with a few "representative" systems and then marked. Do the "representative" systems need to be noted on the Declaration of Conformity? If I test my subassembly with System A and B, can System C claim they are compliant because they have a similar product and are using my CE Marked subassembly? There seems to be the potential for marketing games to be played by suppliers of components and subassemblies by promoting the CE mark to the end user (or potential customer), with the promise of "use all CE Marked parts and your end product will be compliant". If nothing else, it looks like there may be a lot of redundancy in testing of products. Darrell Locke Advanced Input Devices