Tom,

Be warned, something like this was tried by a UK manufacturer.  They failed
the tests, then persauded a Competent body to sign off a TCF stating that the
failed tests were not applicable or were unpassable by their equipment.  They
then CE marked and placed on the market. Within their documentation they
placed a warning about how it should be used which effectively negated the CE
mark. The local Trading Standards body (the UK CE policeing body) found out.
They did not take them to court, but made them withdraw all their
products(several thousand) and fix the problem so the equipment passed.

And their equipment did pass after redesign.

Regards

Ray Garner

EMC Consultant WRSL





Message date : Nov 13 2003, 05:47 PM 
>From : rehel...@mmm.com 
To : T.Sato 
Copy to : emc-p...@majordomo.ieee.org 
Subject : Re: Immunity testing mitigations 


On 12 Nov 2003, Tom wrote 
>If you are so sure that your product complies with the protection 
>requirements of the EMC Directive even if it failed to pass the test, 
>you have chance to use TCF Route instead of the Standard Route. 

>Regards, 
>Tom 

Tom, could you explain your thinking on this a little more? I feel that 
too often TCFs are written just to get around test failures or to bypass 
testing even when standards apply. Some test houses are even implying in 
their advertising that they can "get around the testing" by writing a TCF. 

Bob Heller 
3M EMC Laboratory, 76-1-01 
St. Paul, MN 55107-1208 
Tel: 651- 778-6336 
Fax: 651-778-6252 



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