On the subject of TCF and waiving tests, lets say you were to waive a test because its non-applicable. For instance, line conducted when the unit is battery powered. Does this mean that you are required to go the TCF route?
-----Original Message----- From: tinb...@aol.com [mailto:tinb...@aol.com] Sent: Monday, October 02, 2000 10:25 AM To: cdup...@cs.com; fr...@amcomm.com Cc: emc-p...@ieee.org Subject: Re: Getting Started Chris, I am interested in knowing the basis of your response to items 1 and 2, as it is contrary to my understanding of the EMC Directive. Specifically, it was my understanding that unless the manufacturer is following ALL of the requirements specified in Standard(s), that they must follow the TCF route and obtain a report or certificate from a Competent Body, as outlined per Article 10(2) of the EMC Directive states that "In the case of apparatus for which the manufacturer has not applied, or has applied only in part, the standards referred to in Article 7(1) or failing such standards, the manufacturer or his authorized respresentative established within the Community shall hold at the disposal of the relevant competent authorities, as soon as the apparatus is placed on the market, a technical construction file. This file shall describe the apparatus..... and include a technical report or certificate, one or other obtained from a competent body." If a manufacturer uses their engineering rationale to waive all of the EMC testing specified in standards, they have only applied part of the standard and as such, the EMC Directive would require that the rationale and the TCF be reviewed by a European EMC Competent Body. Furthermore, I believe that UK's DTI is consistent with EMC Directive's philosophy outlined in Article 10(2). In the October 1992 DTI's Guidance Document on the Preparation of a Technical Construction File as required by EC Directive 89/336, Section 1.3 outlines the "Circumstances where the TCF might be used", "ii) For apparatus where harmonized standards exist but the manufacturer applied that standard in part only, eg where a manufacturer can justify that a particular type of apparatus complies with the protection requirements of the Directive without performing tests to any or all of the phenomena described in the relevant harmonized specifications." I am interested in learning whether UK has established an updated position which allows manufacturer to waive testing (altogether) and still self-declare conformity to the EMC Directive through the standards route? Regards Tin In a message dated Sun, 1 Oct 2000 2:58:00 AM Eastern Daylight Time, cdup...@cs.com writes: << In a message dated 29/09/00 15:43:06 GMT Daylight Time, fr...@amcomm.com writes: << I'm just getting started in the world of EMI and would like to ask a few questions. I'm not sure if I should be going the TCF route or the Standards Route. The company that I work for manufactures products which have many variants. 1) Is it EC law that a manufacturer must perform EMI testing before applying the CE mark? No. In the UK, the Electromagnetic Compatibility Regulations don't require testing if you follow the Standards Route. But you must make the Declaration of Compliance before you use the CE mark and be able to provide evidence of compliance to the regulatory authorities when challenged. This can be test results, or detailed analysis, or statements etc. Again, 'testing' per se is not a particular requirement. For instance, a simple resistive convection heater could be stated to Comply because there are no non-linear elements to produce or be affected by EMI. No need to test. Having said that, testing is the only absolutely certain way of proving compliance. And don't forget that the Regulations are Criminal Law! 2) If a manufacturer follows the Standards Route, does EC law require each variant to be tested? No. There is nio statutory need to test. But you need to provide firm evidence, when asked, that the variant is not significantly different in EMC terms to the original subject of the Compliance Declaration. A detailed technical statement would suffice, but must be accurate and traceable. Again, we are taking Criminal Law here! 3) If, when testing, the limit is exceeded, can the CE mark still be applied? No. The CE mark means that ALL relevant Directives have been complied with. If EMC limits are exceeded when using the Standards Route then it doesn't comply with the EMC Directive. If the product can't be produced without exceeding the limits, then the TCF route to compliance should be used. 4) Are the services of a Competent Body required in order to put together a TCF or can the manufacturer do that on his own? A TCF is only valid when qualified by a Competent Body. A manufacturer can build his own TCF, or an external Test House/Competent Body can build it, but at the end of the day the Competent Body signs/takes responsibility for it. Think of a TCF as a new EMC standard which relates ONLY to that particular product. A simple rule is 'if it complies with the Standards then use the Standards Route, if it doesn't then use the TCF route. Hope is useful. Chris Dupres Surrey, UK. >> ------------------------------------------- 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
