John, To illustrate your worry on the 50% non-compliant Doc's, I show a quite recent example of a EU DoC for a product that should comply with the R&TTE Directive.
************************* DECLARATION OF CONFORMITY Application of directive 89/336/EEC standards to which conformity is declared: - IEC60950, 3rd ed - UL60950, 3rd ed - CSA C22.2 No.60950 3rd ed, <xxxx> mark - EN55022:1994 - EN61000-3-2 & -3-3 - EN55024:1998 (+listing of all basic standards) - FCC Part 15 A - ICES-003 Model/ Partno to which conformity is declared: - Model: <xxxx> - Part no: <listing all sub-assy's> Conformity is declared: Person 1, <title>, <date>, <signature> Person 2, <title>, <date>, <signature> Person 3, <title>, <date>, <signature> ************************ And I did not accidently forget the name of the mftr, it is simply not on the DoC. Regards, Kris Carpentier From: John Allen [mailto:john.al...@era.co.uk] Sent: woensdag 8 oktober 2003 16:56 To: 'Bill Stumpf'; 'lfresea...@aol.com'; emc-p...@ieee.org Subject: RE: Missing Emissions data from D of C? Hi Wrt to Bill's comment on the weakness of the DoC, I would personally say that the DoC in question is non-compliant with the EMCD since it does not declare compliance with a relevant full set of harmonised standards for bothimmunity and emissions or reference a relevant Competent Body-approved TCF, and therefore it does not demonstrate compliance with the requirements of Articles 3 & 4 (and related requirements) of the Directive. Therefore, the weakness is probably not with the concept of the DoC as stated in the Directive, but with the manner in which compliance with the Directive in general and the DoC requirements in particular is, or is not, enforced, (i.e. very rarely in many EU countries!). Nevertheless it would be interesting to be given the actual wording of that DoC so that we could comment in detail, since - in my experience - around 50% of DoC's are incorrect in some form, especially when prepared by someone who does not know both the relevant Directive(s) and the related interpretive documents. (In fact I wonder if it even referenced the EMCD, as I have seen some that called up only relevant standards and not the relevant overarching Directives). Regards John Allen, Technical Consultant EMC and Safety Engineering ERA Technology Ltd. Cleeve Road Leatherhead Surrey KT22 7SA UK Tel: +44-1372-367025 (Direct) +44-1372-367000 (Switchboard) Fax: +44-1372-367102 From: Bill Stumpf [mailto:bstu...@dlsemc.com] Sent: 03 October 2003 17:04 To: 'lfresea...@aol.com'; emc-p...@ieee.org Subject: RE: Missing Emissions data from D of C? Derek, This points out one of the weaknesses of the self-declaration (DOC). The responsible party can self declare for whatever standards they feel suite their needs. For instance, just because a product is CE marked, it doesn't mean that it has been tested or passed to all the relevant standards. It may just be safety. The only way to tell for sure is to look at the actual DOC, which lists the standards the product has been tested to. In the case you brought up, The product should have been tested for emissions to EN 55014 at the very least. We would also recommend EN 55022, since the potential for interference goes well beyond the 300MHz called out in EN 55014. William M Stumpf DLS Electronics 166 South Carter St. Genoa City WI 53128 ph: 262-279-0210 fx: 262-279-3630 email: bstu...@dlsemc.com ----Original Message----- From: lfresea...@aol.com [mailto:lfresea...@aol.com] Sent: Thursday, October 02, 2003 1:02 PM To: emc-p...@ieee.org Subject: Missing Emissions data from D of C? Hi all, while reviewing a clients competitors D of C, I was surprised to see that only Immunity and Low voltage were address, there were no emissions requirements called out. The product is a professional arcade game. Is this product exempt? Any thoughts why this could be allowed? Cheers, Derek N. Walton Owner, L F Research EMI Design and Test Facility Poplar Grove, IL 61065 _____________________________________________________________________ This e-mail has been scanned for viruses by MCI's Internet Managed Scanning Services - powered by MessageLabs. For further information visit http://www.mci.com ************************************************************************* Copyright ERA Technology Ltd. 2003. (www.era.co.uk). All rights reserved. The information supplied in this Commercial Communication should be treated in confidence. 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