In message <4787e8ae.6020...@sun.com>, dated Fri, 11 Jan 2008, Monrad Monsen <monrad.mon...@sun.com> writes:
>The same is true for Europe. The "Guide for the EMC Directive >2004/108/EC (22nd March 2007)" does not use the term "system >integrator", but the guide does describe the system integrator role and >states that for the purpose of the EMC Directive that entity that >combines/designs/puts together the system becomes the "manufacturer". >As manufacturer, the entity (system integrator) becomes responsible for >ensuring that the system complies with the requirements for an >apparatus as given in the EMC Directive. The guide states on page 19 >in section 1.2.2 the following: > - - - - - - >1.2.2 Combination of finished appliances (systems) >A combination of several finished appliances which is made commercially >available as a single functional unit intended for the end-user is >considered to be apparatus. Such a system, within the sense of the EMC >Directive, is combined, and/or designed and/or put together by the same >person (the "manufacturer") and is intended to be placed on the market >for distribution as a single functional unit for end-use and to be >installed and operated together to perform a specific task. All >provisions of the EMC Directive, as defined for apparatus, apply to the >combination as a whole. > >It should be noted that combining two or more CE finished appliances >does not automatically produce a "compliant" system e.g.: a combination >of CE marked Programmable Logic Controllers and motor drives may fail >to meet the protection requirements. > - - - - - - > >The guide has a footnote that points to the base EMC Directive >2004/108/EC paragraph 2(1)(b) which has the simple apparatus >definition: > = = = = = >(b) 'apparatus' means any finished appliance or combination thereof >made commercially available as a single functional unit, intended for >the end user and liable to generate electromagnetic disturbance, or the >performance of which is liable to be affected by such disturbance. > = = = = = > >Hope this helps. > Some unofficial 'interpretation' may assist. The words 'made commercially available as a single functional unit intended for the end-user' can be interpreted as 'invoiced at a single inclusive price'. 'Commercially available' may be interpreted that such a combination is not put together specially for a single customer, but is offered (e.g. in a catalogue or advertisement) to all-comers. The underlying concept is that the 'manufacturer' can assess and, if necessary, test the combination as a whole, while testing is often not economically realistic for a 'one-off' special combination. Such a special combination might be invoiced as separate items so as to emphasise its special nature. -- OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk For very important information, please turn over. John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. Website: http://www.ieee-pses.org/ To post a message to the list, send your e-mail to emc-p...@ieee.org Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@ptcnh.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: emc-p...@daveheald.com All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc
