Sam,

You  have a choice of 3 basic routes to satisfy the  EMC Directive.

1.  The standards  route.   You had the product tested  to  the appropriate
harmonised  Standards.   So you have  evidence you pass.  You can self declare.

2.  You use the Technical Construction File Route.  This mandates  production
and retention of the TCF  document.  Then you self declare.

3.  The EC Type examination route.  Getting a  Notified Body involved.
     They will get all the documents out of you, their checks  reduce your risk
considerably.  You get a certificate  instead of a self declaration.  This route
is a bit old.


For your  own peace of mind  the minimum  material I would  store  to back up D
of C would be the test reports + BOM and schematics  of the product  to prove
identification at any later  challenge.

Only  route 2.  requires  production of a formal TCF  but  actions you took to
comply with routes 1 and 3  would create a  document trail anyway.

My option has  been to use  route 1 wherever possible  and keep  supporting
evidence  with the product file.

Jerry Roberton
International Compliance Manager
NET Europe Ltd.
www.net.com


"Wismer, Sam" wrote:

> Bob et. al,
> Thanks for your comments.  I use the term TCF only because we include all
> the same materials as would be required if we did submit it to a competent
> body.   Perhaps Technical file is more appropriate.  We do not submit it
> because we do not deviate from the Directive.  However some feel that it is
> a document that, according to the directive, must be created to back up your
> declaration.  My question is, does the directive really require such a
> document be created?
>
> Sam Wismer
> RF Approvals Engineer
> LXE, Inc.
> (770) 447-4224 Ext. 3654
>
> Visit Our Website at:
> http://www.lxe.com
>
> -----Original Message-----
> From: Chaplis, Bob [mailto:chapl...@genrad.com]
> Sent: Tuesday, February 29, 2000 3:14 PM
> To: 'John Juhasz'
> Cc: Wismer, Sam
> Subject: RE: TCF for EMC Directive
>
> John,
>         I think what Sams question relates to is a TCF required to show
> compliance with the EMC Directive, and to that the answer is no, The TCF is
> but one avenue that a manufacturer can use to show conpliance to the
> Directive. I wonder if Sam did not mean "Techical File: instead of TCF. Is
> that correct Sam? The TCF must be under control of a Competant Body.
>
>        Bob Chaplis
>          Genrad.
> > -----Original Message-----
> > From: John Juhasz [SMTP:jjuh...@fiberoptions.com]
> > Sent: Tuesday, February 29, 2000 12:38 PM
> > To:   'Wismer, Sam'; EMC Forum (E-mail)
> > Subject:      RE: TCF for EMC Directive
> >
> > Sam,
> >
> > Regarding TCFs, it really depends on your product/product's configuration
> > management.
> >
> > If you have a product (with a specific model name/munber) that will only
> > be used 'as is'
> > (no variations) then a TCF is required.
> > However, if you have a product which is a base model for which there may
> > be numerous
> > variations, then the TCF is the way to go.
> >
> > John Juhasz
> > Fiber Options
> > Bohemia, NY
> >
> >
> > -----Original Message-----
> > From: Wismer, Sam [ <mailto:wisme...@lxe.com>]
> > Sent: Tuesday, February 29, 2000 10:34 AM
> > To: EMC Forum (E-mail)
> > Subject: TCF for EMC Directive
> >
> >
> >
> > All,
> > Thank you for your replies to my VCCI question.  The point came through
> > loud
> > and clear that VCCI certification is only voluntary, however maybe
> > mandated
> > by the market.  In short, if your customer doesn't care, then why bother.
> >
> > New question:
> >
> > There is some debate whether or not it is mandatory for a manufacturer to
> > create and maintain a TCF to show compliance to the EMC Directive(ITE
> > Equipment only).  We currently do create a TCF for every product when we
> > apply the EMC directive.  Some here think it is necessary, and some think
> > not, however in any case it happens to be a great place to keep test
> > reports, schematics, drawings and the like so it is not really an issue
> > until we contract a vendor to produce a product for us.  Usually we
> > require
> > them to obtain all the necessary approvals so that we don't have to.
> >
> > With this scenario, and the difference of opinion in the necessity for a
> > TCF, should we require our vendor to create a TCF?  If they choose not to,
> >
> > are we liable since we will private label it and place it on the market?
> > Should we create the TCF with their reports?
> >
> > Thanks in advance
> >
> >
> >
> > Sam Wismer
> > RF Approvals Engineer
> > LXE, Inc.
> > (770) 447-4224 Ext. 3654
> >
> > Visit Our Website at:
> > <http://www.lxe.com>
> >
> >
> >
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