I read in !emc-pstc that Gary McInturff <[email protected]> wrote (in <[email protected]>) about 'Legal requirements linking GS and EMC' on Tue, 25 May 2004:
> The claim has once more been put forth by a major European based NRTL >doing business in the us that they cannot grant a GS mark for ITE equipment >unless they have the emissions data during the safety review. AIUI, the GS mark is a 'private' mark, with no statutory significance. If so, the proprietors of the mark can require anything they like, even a pond of flesh, if they so choose. > I believe that they may want it but it is not required under statutes, >and in fact can hamper the certification process by turning a somewhat >parallel process into an absolutely serial process. Indeed, but in which order? >About the only >connection that comes to mind is the X and Y capacitors - at least in most >cases. They have safety requirements as well as EMC requirements. So if one >goes through safety with parts that are identified as safety critical items >and then have to make changes because of EMC one has to return to the safety >agency and have a review of those components. Equally, if you do EMC first and then have to make changes to achieve a safety 'pass', you may have to go back and do EMC again. >If not the factory inspections >would show a non-approved (sorry not a good choice of words) to maintain the >agency mark. But the EMC data does not need to be presented. See above. > In my opinion, and you all may well be about to change that, is that the >safety NRTL has no rights under the LVD, EMC, or the CE marking process to >tie the two processes into their approval. I agree in principle. But 'approval' is not correct in the context of CE marking. There is no third-party approval involved, for almost all products. The manufacturer has to sign the DOC and the DOC has to be true. The manufacturer uses the test-house reports to satisfy himself (and any regulatory authority that challenges the product's conformity) that the DOC is true. >If there isn't such a legal >requirement I will be dropping the vendor and move on to one of the many >others who can now provide the same services. If there is such a law I'm >stuck and grudgingly concede. I support your position. Tomorrow, I may have an opportunity to ask some people who are in a position to give authoritative advice on this matter. If so, I'll respond on Saturday. -- Regards, John Woodgate, OOO - Own Opinions Only. The good news is that nothing is compulsory. The bad news is that everything is prohibited. http://www.jmwa.demon.co.uk Also see http://www.isce.org.uk
