Let's discuss apples vs apples and keep the discussion to ITE. Household appliances are not subject to EN 55022:1998, but have their own product specific standard.
The law is 89/336/EEC, the EMC Directive (or as I like to call it, the EMC Professional Employment Act of 1989). It lays down, as you note, the essential requirement that a product not cause undue interference and that it operate as intended in its itended environment. No more, no less. No limits for emissions are provided in the EMC Directive. The question then comes up, how do we show compliance with the essential requirements in 89/336/EEC? The answer, of course, is to test to the applicable requirements that have been published in the OJ. For ITE, the emissions limits are contained in EN 55022:1998. Fine. I read EN 55022:1998 and it is simply a number of modifications to CISPR 22, 3rd Edition. Well and good. I read CISPR 22, 3rd Edition and it defines Class A and Class B. If there are different emissions limits between various standards, that needs to be addressed in CISPR. My question is this - is there a significant interference problem in Europe from ITE? Based on a survey returned by over 50,000 households in the U.S., there certainly isn't one here. Whatever is being done, it is adequate. Peace! Ghery -----Original Message----- From: CE-test - Ing. Gert Gremmen - ce-marking and more... [mailto:cet...@cetest.nl] Sent: Wednesday, December 06, 2000 10:39 AM To: Pettit, Ghery; 'William D'Orazio'; EMC Posting (E-mail) Subject: RE: EN55024 Hi Ghery,group, Standards are NO LAW ! My reply was directed against the Clause in EN 55022, not against the possibility of EN 55022 to define suitable environments. However, there is a standards writing committee guidance document that requests the committees not to deviate more then absolutely needed from the test levels and environmental conditions as described in the generic standards EN 50082-1/2. The standards writing committees have been very independent (members of CENELEC) and all kind of powers could and have been influencing the contents of many standards. Even today commercial interests find their way into harmonized standards. The EC requested CENELEC to create standards that are compatible to the Essential requirements of the EMC-directive, it cannot be so that a house hold kitchen machine need to comply to other limits then a house hold computer. The interference a receiver receives is not less interfering if it comes from a vacuum cleaner or from a modem. Same environment, same levels. The problem comes with mixed environment products. In the past products could escape from limits by a warning label "this product may cause radio interference" and the suggestion to increase distance between products. At low reception levels of FM-radio and the close distances of modern urban livings that solution is not sufficient anymore. Product group level EN-type harmonized standards are (in Europe) targeted towards the details of "how to test" and "how to judge performance" and "how to connect test gear" and only deviate from levels and frequency range in the benefit of the product group if absolutely necessary. It would be absolutely unjust if some equipment would be able to interfere more then others, just because it had a label on it saying that it would only be allowed to use it in an heavy industrial environment, if the equipment (such as a mainframe) itself suggests their application in a domestic or mixed environment. Manufacturers of Class B complying equipment could easily sue manufacturers of equivalent Class A equipment if their limit exceeding interference was not due to absolutely \ necessary requirements given by the nature of the product or process being done. (Fa electro-heating with RF-waves, welding and therapeutic use of RF-frequencies) Please Note also that the report mentioned is for the standards writing committees of CENELEC creating harmonized standards and is not applicable for IEC and/or CISPR versions of the same standard. Hope to got things straightened out somewhat. Regards, Gert Gremmen, (Ing) ce-test, qualified testing =============================================== Web presence http://www.cetest.nl CE-shop http://www.cetest.nl/ce_shop.htm /-/ Compliance testing is our core business /-/ =============================================== >>-----Original Message----- >>From: Pettit, Ghery [mailto:ghery.pet...@intel.com] >>Sent: Wednesday, December 06, 2000 5:25 PM >>To: 'CE-test - Ing. Gert Gremmen - ce-marking and more...'; Pettit, >>Ghery; 'William D'Orazio'; EMC Posting (E-mail) >>Subject: RE: EN55024 >> >> >>Gert, >> >>All ITE equipment must meet the Class B limits? Where does it say that in >>either EN 55022:1998 or CISPR 22, 3rd Edition? Section 4.1 of CISPR 22 is >>quite clear about what equipment must meet the Class B limits. There are >>many types of ITE that do not fall into the examples provided in the >>document. EN 55022 does not amend this part of the document in its common >>modifications. As 89/336/EEC does not provide limits of any >>kind, where am >>I supposed to see a requirement that servers and mainframe >>computers (which >>are, indeed, ITE) must meet the Class B limits? >> >>Ghery Pettit >> >>-----Original Message----- >>From: CE-test - Ing. Gert Gremmen - ce-marking and more... >>[mailto:cet...@cetest.nl] >>Sent: Wednesday, December 06, 2000 1:14 AM >>To: Pettit, Ghery; 'William D'Orazio'; EMC Posting (E-mail) >>Subject: RE: EN55024 >> >> >>Hi Group, >> >>The type of clause (see below) from EN 55022 about adding notes and >>restrictions >>to equipment is just the type the European Commission >>objects against their use in the EN 55022 standard. >> >>The reason is that the CENELEC was asked to propose limits and >>test methods, not to replace politics by limitng the applicability >>of their standards. >> >>The use of such a clause to sell ITE equipment to Class A limits >>is illegal >>and will not hold when the presumption of conformity to the essential >>requirements >>of the EMC-directive is being tested. >> >>Information equipment is and wil be used in all environments, therefore >>the distinction between such environments is artificial. >> >> >> >>Regards, >> >>Gert Gremmen, (Ing) >> >>ce-test, qualified testing >> >>=============================================== >>Web presence http://www.cetest.nl >>CE-shop http://www.cetest.nl/ce_shop.htm >>/-/ Compliance testing is our core business /-/ >>=============================================== >> >> >>>>-----Original Message----- >>>>From: owner-emc-p...@ieee.org [mailto:owner-emc-p...@ieee.org]On Behalf >>>>Of Pettit, Ghery >>>>Sent: Tuesday, December 05, 2000 11:46 PM >>>>To: 'William D'Orazio'; Pettit, Ghery; EMC Posting (E-mail) >>>>Subject: RE: EN55024 >>>> >>>> >>>> >>>>OK. EN 55022 is the ITE specific emissions standard. It does >>>>have two sets >>>>of limits with a statement that Class B is intended for certain product >>>>types which may be used in a domestic type environment and a >>>>statement that >>>>Class A products should have a warning that they may cause >>interference if >>>>used in a domestic environment. CISPR 22 does not use the term >>>>"industrial" >>>>to define an environment. It merely warns that the class A >>limits may not >>>>provide enough protection to neighboring users of the RF spectrum if the >>>>device is used in a domestic environment. >>>> >>>>Ghery >>>> >>>>-----Original Message----- >>>>From: William D'Orazio [mailto:dora...@cae.ca] >>>>Sent: Tuesday, December 05, 2000 2:37 PM >>>>To: 'Pettit, Ghery'; William D'Orazio; EMC Posting (E-mail) >>>>Subject: RE: EN55024 >>>> >>>> >>>>BYI, EN55011 should read EN55022. >>>> >>>>William D'Orazio >>>>CAE Electronics Ltd. >>>>Electrical System Designer >>>> >>>>Phone: (514) 341-2000 (X4555) >>>>Fax: (514)340-5552 >>>>Email: dora...@cae.ca >>>> >>>> >>>>-----Original Message----- >>>>From: Pettit, Ghery [mailto:ghery.pet...@intel.com] >>>>Sent: Tuesday, December 05, 2000 5:33 PM >>>>To: 'William D'Orazio'; EMC Posting (E-mail) >>>>Subject: RE: EN55024 >>>> >>>> >>>>EN 55024 is the ITE specific immunity standard. It is based on CISPR 24 >>>>which makes no distinction between environments. EN 55011 is >>>>based on CISPR >>>>11 and relates to different product families. They do not come from the >>>>same subcommittees in CISPR, so it's like comparing apples and oranges. >>>> >>>>Ghery Pettit >>>>Intel >>>> >>>>-----Original Message----- >>>>From: William D'Orazio [mailto:dora...@cae.ca] >>>>Sent: Tuesday, December 05, 2000 1:22 PM >>>>To: EMC Posting (E-mail) >>>>Subject: EN55024 >>>> >>>> >>>> >>>>Gents, >>>> >>>> Why is it that EN55011 defines test levels for both industrial and >>>>residential environments (class A, B) and EN55024 does not? Are >>>>the levels >>>>in EN55024 applicable to all environments (obviously not) so >>how does one >>>>define the test levels for an ITE in an industrial environment? >>>> >>>>Thanks in advance, >>>> >>>> <<...>> >>>> >>>>William D'Orazio >>>>CAE Electronics Ltd. >>>>Electrical System Designer >>>> >>>>Phone: (514) 341-2000 (X4555) >>>>Fax: (514)340-5552 >>>>Email: dora...@cae.ca >>>> >>>> >>>>------------------------------------------- >>>>This message is from the IEEE EMC Society Product Safety >>>>Technical Committee emc-pstc discussion list. >>>> >>>>To cancel your subscription, send mail to: >>>> majord...@ieee.org >>>>with the single line: >>>> unsubscribe emc-pstc >>>> >>>>For help, send mail to the list administrators: >>>> Jim Bacher: jim_bac...@mail.monarch.com >>>> Michael Garretson: pstc_ad...@garretson.org >>>> >>>>For policy questions, send mail to: >>>> Richard Nute: ri...@ieee.org >>>> >>>> >>>> >>>> >>>>------------------------------------------- >>>>This message is from the IEEE EMC Society Product Safety >>>>Technical Committee emc-pstc discussion list. >>>> >>>>To cancel your subscription, send mail to: >>>> majord...@ieee.org >>>>with the single line: >>>> unsubscribe emc-pstc >>>> >>>>For help, send mail to the list administrators: >>>> Jim Bacher: jim_bac...@mail.monarch.com >>>> Michael Garretson: pstc_ad...@garretson.org >>>> >>>>For policy questions, send mail to: >>>> Richard Nute: ri...@ieee.org >>>> >>>> >> ------------------------------------------- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher: jim_bac...@mail.monarch.com Michael Garretson: pstc_ad...@garretson.org For policy questions, send mail to: Richard Nute: ri...@ieee.org
