Pragmatically, so far as EMC is concerned, the only thing likely to give
rise to any enforcement interest is if you manage to make something that
causes interference to other equipment outside the boundary of your site.

If you briefly document the rationale for your decision to apply (or not)
the EMC Directive, and you don't upset anybody else, that will probably be
an end to it.

Other directives, most notably machinery, deliberately use the "put into
service" wording, thus removing any doubt.

John C

-----Original Message-----
From: T.Sato [mailto:vef00...@nifty.ne.jp] 
Sent: 19 September 2012 14:13
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Test Fixture for Self

On Wed, 19 Sep 2012 12:40:30 +0000,
  Charlie Blackham <char...@sulisconsultants.com> wrote:

> Quoting from the Guide for the EMC Directive 2004/108/EC, available from
http://ec.europa.eu/enterprise/sectors/electrical/documents/emc/guidance/ind
ex_en.htm
> 
> 1.2.6 Products for own use
> Where an apparatus is manufactured for own use, placing on the market is
considered to take place at the moment of putting into service; the
obligation to comply with the Directive begins with first use.

Well, but EMCD itself says:

  `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 elec-
  tromagnetic disturbance, or the performance of which is
  liable to be affected by such disturbance;

Is such test fixtures "made commercially available as a single
functional unit"?

Regards,
Tom

-- 
Tomonori Sato  <vef00...@nifty.ne.jp>
URL: http://homepage3.nifty.com/tsato/


> From: Robert Heller [mailto:rehel...@mmm.com]
> Sent: 19 September 2012 13:24
> To: EMC-PSTC@LISTSERV.IEEE.ORG
> Subject: [PSES] Test Fixture for Self
> 
> If a manufacturer builds a test fixture only to be used by the
manufacturer (not commercially available), does the test fixture need to
undergo EMC testing? If so, where is this called out?
> 
> Can "placing on the market" and "putting into service" be different
things?

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