The EMC-directive is a special one in the series of so-called
"new approach" directives. It is considered with (for emissions)
protection of the radio spectrum.
The main goal to achieve for emissions is to assess if you
equipment is potentially interfering with other equipment.
One way is to refer directly to this goal and have a notified
(competent) body (authoritive for EMC-directive) establish if this
is the case or not. Another route to follow is comply to harmonized
standards. A list of those is regularly updated and published in the
European  Official Journal  (OJ). This route enables you to assess your
equipment against the limits in these standards. In spite of some
exceptions, most equipment (99.9) needs to comply with the limits
as found in f.a. EN 55022. For house hold and light industrial equipment
this is more stringent (ClassB) then for industrial equipment (Class A).

The 80/80 rule is mentioned in fa. this standard. It is applicable only
to apparatuses produced in substantial numbers.  Of course , statistics
become relevant when numbers are larger (> 10 ?) For small numbers tables
are listed in the standard.

The question if your product is safe is not relevant here. You will just
need
to diminish your emission level by f.a. adding a mains filter to comply with
the essential requirement of the directive by following the limit in the
standard.

I for any reason the reduction is technically impossible, you will have to
follow
the route using the NB or CB. They will as "competent" reference judge if
the
apparatus as produced by you may or may not exceed the limits, and if so
what restrictions must be applied if connected to the mains.
You may end up with an unaccepted product, or with a product that may
be used in restricted areas , fa. only outdoors, or connected to a dedicated
mains group.

Your remark about authorities recognizing that equipment may exceed limits
is possibly caused by manufacturers ignoring rules, and I cannot believe
that this is a reason
to accept non-compliant equipment.

Note that a constated excess of emission will almost always lead to
withdrawal of your product, on your costs. I have had  6 customers in 2
years
needing advice on how to limit the costs of fixing large numbers of
equipment
installed and sold.

If I can do anything to help, let me know.

Gert Gremmen
www.cetest.nl



-----Original Message-----
From: owner-emc-p...@majordomo.ieee.org
[mailto:owner-emc-p...@majordomo.ieee.org]On Behalf Of Enci
Sent: donderdag 6 december 2001 11:00
To: emc-p...@majordomo.ieee.org
Subject: EMC. 10db over limit = unsafe?



Hi Group,

If I have a product, a finished apparatus, that passes all LVD or safety
tests, i.e. earth leakage, insulation, etc., is that product "unsafe" if it
is 10db over the conducted emissions limits for EMC?

Article 4 and Annex III of the EMC directive do not refer to safety, only
to the concept that equipment will not hinder the use of other equipment
and immunity.

Where does this 80/80 rule now fit in that was discussed recently -
specifically if authorities acknowledge the fact that there may be
equipment out there that exceeds the EMC emissions limits for their product
type?

Also in Annex III, it states:

"The information required to enable use in accordance with the intended
purpose of the apparatus must be contained in the instructions accompanying
the apparatus."

Does this then imply that the manual must state that suitable measures must
be taken to ensure compliance? e.g. additional filter?


Thank you in advance,
Enci


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