Good explanation Nick But the following I have to add.
point 4. The EMC directive only uses the Standards and the TCF route. The type approval route for mainly transmitters will very soon (April 8th) be withdrawn in favor of the TTE-directive that comes into force and that allows the standards "plus" method to be used for transmitters. The plus stands here for the notified body that needs to comply with your frequency scheme for the miscellaneous countries. If not compliant with all countries then a special symbol has to be added to the ce sign stating that it is not compatible with some countries and the manual should be read. Equipment using such a symbol may not be used in all EC member states but may be freely sold and im/exported. Waiting for the European frequency scheme to be harmonized. We are working on that toooooo.... You already pointed us in this direction under point 6 but I felt some extra information was required. 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 Nick Williams >>Sent: Thursday, March 02, 2000 12:58 PM >>To: emc-p...@majordomo.ieee.org >>Subject: Re: Technical Construction File >> >> >> >>There seems to be come confusion on the matter of technical files and >>technical construction files, and referring to the text of the CE >>mark directives, it's not difficult to see why since there is no >>consistency in the way in which the terms are used. My understanding >>is as follows. >> >>1.With the exception of the EMC Directive, all CE mark directives >>require the Responsible Person to compile a file of documentation >>which demonstrates how the manufacturer justifies their claim of >>compliance with the requirements of the relevant directive. >> >>2. This collection of documentation is known variously as a Technical >>File or a Technical Construction File. Except in the EMC Directive, >>these terms seem to be used interchangeably to mean the same thing. >> >>3. There is no provision in any directive to require that the >>information relevant to compliance with one directive need be kept >>separate from that for any other and therefore in most cases a >>combined technical file which covers compliance with all directives >>(and lots of other information) makes sense from an organisational >>point of view. >> >>4. Under the EMC Directive, a manufacturer has three options for >>compliance. These are the Standards route, the Technical Construction >>File route and the Type Approval route. >> >>5. Under the Standards route, the manufacturer simply claims >>compliance with the requirements of the relevant harmonised >>standards, and thus with the requirements of the directives. While he >>would, in most cases, be foolish to do this without having some >>documentary evidence that tests have been completed and passed, this >>is not mandated under the Directive. >> >>6. Under the Type Approval route, the manufacturer gives the product >>to a suitably qualified test house who test it and issue a >>certificate of compliance. This method of complying with the >>directive is primarily intended for communications (transmitting) >>apparatus and therefore the new R&TTE Directive will have a major >>bearing on much equipment which has formerly followed this route. >> >>7. The Technical Construction File (TCF) route to compliance with the >>EMC Directive is intended for use in those situations where the other >>two routes do not apply. This will be either because the apparatus is >>not transmitting apparatus, or because there are no appropriate >>harmonised standards. >> >>8. Under the TCF route, the manufacturer creates a justification for >>a claim of compliance with the requirements of the EMC Directive >>based on such factors as the location and use of the equipment, the >>results of any tests which have been done and the requirements of any >>standards which are relevant, if only in part. >> >>9. The key point about the EMC directive's TCF is that for it to be >>used as the basis of CE marking a product, the file must be submitted >>to a Competent Body (a term defined in the directive and distinct >>from a Notified Body) who must examine it and agree to the logic used >>to justify the claim of compliance. Thus, the TCF route to complying >>with the EMC directive is NOT a self-certification process. >> >>10. To cloud the matter even further, there is a (complicated) >>provision within the Machinery Directive which allows for a >>manufacturer to involve a notified body in the creation and storage >>of the Technical File for certain machinery. This really only has >>relevance in the context of annex IV machines which require type >>approval (etc.). I don't know of any situation where such a provision >>has been applied, and it's a mystery to me and to several other >>people I have spoken to about this subject as to quite what the >>Commssion was thinking when it drafted this section of the directive. >> >>As I mentioned at the beginning, the EC have done us no favours in >>being muddled about the terminology they apply in the different >>directives, but it is important to understand that the TCF specified >>under the EMC Directive has a quite distinct and different legal >>status to the technical documentation requirements of the other >>directives. >> >>Hope that helps! >> >>Nick. >> >> >>------------------------------------------- >>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 >> >>
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