Hello Scott,

I believe that there are at least two reasons analog music players are 
exempted. The first is that the instructional safeguard in the standard is to 
provide a specific notification to the user when they exceed 85 dBA. This is 
not practical on a purely analog device. The instructional safeguard must be 
repeated  for every 20 hours cumulative listening above 85 dB, and an analog 
device cannot easily make this measurement. Second, analog devices such as a 
portable cassette tape player are not practical to use for extended periods. A 
user who wanted to listen to 10 hours of continuous music would need to carry 
around quite a few cassette tapes or would have to listen to the same tape over 
and over. 

I believe that portable CD players are within the scope of the requirement. 
However, a portable DVD player that includes a screen is different from a CD 
play.  Although it is technically possible to walk around with a DVD player 
while watching a movie, it is neither practical nor a normal use. However, I am 
not qualified to say with certainty whether a portable DVD player is exempted. 
It is possible that you can make a reasonable argument that a portable DVD 
player would not fit within the scope. However, that will depend on the design 
and features of the DVD player. 

It may be best to consult an attorney who is familiar with the regulations to 
determine if a particular product is within or outside of the scope.

Regards,
Ted Eckert
Compliance Engineer
Microsoft Corporation
ted.eck...@microsoft.com

The opinions expressed are my own and do not necessarily reflect those of my 
employer.



-----Original Message-----
From: Scott Xe [mailto:scott...@gmail.com] 
Sent: Monday, February 04, 2013 8:15 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: EN 60065 A12 - Sound Pressure Restriction

Dear Sir/Madam,

In this requirement, there is a following exemption.

€    analogue personal music players (personal music players without any
kind of digital processing of the sound signal) that are brought to the market 
before the end of 2015.

NOTE 4

This exemption has been allowed because this technology is falling out of use 
and it is expected that within a few years it will no longer exist. This 
exemption will not be extended to other technologies.

I believe the old design portable DVD players with a pair of earphones and 
operated on batteries or rechargeable batteries are qualified for such 
exemption.  I am seeking advice why the digital processing of sound signal is 
so critical to this sound pressure restriction and how to identify if the 
digital processing is built in the unit or not.

Thanks and regards,

Scott

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