I like your pragmatism, but to what directive should you apply the ce mark then ? Applying the ce mark without an applicable directive is illegal and an economic crime.
Regards, Ing. Gert Gremmen, BSc g.grem...@cetest.nl www.cetest.nl Kiotoweg 363 3047 BG Rotterdam T 31(0)104152426 F 31(0)104154953 Before printing, think about the environment. -----Oorspronkelijk bericht----- Van: emc-p...@ieee.org [mailto:emc-p...@ieee.org] Namens McInturff, Gary Verzonden: Wednesday, March 28, 2012 10:46 PM Aan: 'oconne...@tamuracorp.com'; 'EMC-PSTC@LISTSERV.IEEE.ORG' Onderwerp: RE: [PSES] Shipping into Europe - Basic question <I propose an IECEE form for the Proclamation of the Declaration of a Certification of Conformity.> Why propose new documents when good old circular reasoning can solve the problem. Especially if the real problem is not necessarily complying with the directive but getting it past the customs folks. Being able to CE mark the thing makes that easier since they generally stop when they see the CE mark and documentation. They rarely, in my experience, stop the import while they check out if it really should be CE marked. However, if it's not marked that often seems to catch their eye. So if all other things were even then having the CE mark and the claim to meet the directive in place would be the best choice. One can attest to the directives a number of ways, Harmonized standards, NCB's, TCB's etc, and quite frankly just plain ol' "I just think it meets the requirements". There are differing consequences for each choice when it all goes bad - but each of them is doable. The self analysis portion is imperative given Charlie's citations. 1.2.3.2 expressly must be understood to determine you don't need to apply the directive to the pcb. Using the directive itself, thanks to Charlie's citations to the EMC directive, we can use the directive to defeat the directive. >From Charlie's citation: <1.2.3.2 Excluded components/sub-assemblies Components and sub-assemblies intended for incorporation by persons other than the end user into apparatus and/or a subsequent sub-assembly are not considered to be "apparatus" and are therefore not covered by the EMC Directive. This may also be applied to the examples in 1.2.3.1.> And now the circular reasoning. The directive says I have to consider the EMC directive when applying the CE mark. This reference above says the pcb it's out of scope and I don't need to mark it. But since marking is the presumed better solution I want to mark the part. Since I did read, I did understand, I know I don't have to mark. But in knowing it's out of scope I actually comply with the directive and I should apply CE mark. Ta da The conversation between Yosarian and Orr in the book "Catch 22" which discusses Orr's apple cheeks is the best example of circular reasoning I've ever read. It not only makes you laugh but frustrates the heck out of you as you try to follow the logic. It is a classic "catch 22" Gary - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <emc-p...@ieee.org> All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.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...@radiusnorth.net> Mike Cantwell <mcantw...@ieee.org> For policy questions, send mail to: Jim Bacher: <j.bac...@ieee.org> David Heald: <dhe...@gmail.com> - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <emc-p...@ieee.org> All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.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...@radiusnorth.net> Mike Cantwell <mcantw...@ieee.org> For policy questions, send mail to: Jim Bacher: <j.bac...@ieee.org> David Heald: <dhe...@gmail.com>
