Yes end user was a very poor choice of words, but manufacturer gets muddy as well. The manufacture according to the guide for Guide to the implementation of directives based on the New Approach and the Global Approach (The blue book) but having said that I should have used that term rather than end user. But I still don't see how the exempt status is indicated - by no accompanying DoC or by a note in the DoC that covers the applicable directives for the final product but with a note that says the subassembly is exempt from those standards.
It's a bit like proving - or stating at least - a negative. 3.1.1. New Approach directives A manufacturer, in the meaning of New Approach, is the person who is responsible for designing and manufacturing a product with a view to placing it on the Community market on his own behalf. The manufacturer has an obligation to ensure that a product intended to be placed on the Community market is designed and manufactured, and its conformity assessed, to the essential requirements in accordance with the provisions of the applicable New Approach directives. The manufacturer may use finished products, ready-made parts or components, or may subcontract these tasks. However, he must always retain the overall control and have the necessary competence to take the responsibility for the product (47). Gary -----Original Message----- From: John Woodgate [mailto:j...@jmwa.demon.co.uk] Sent: Tuesday, April 02, 2013 2:11 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] so what does a DoC look like for a subassembly that isn't usable on its own? In message <d250d01e39356a4e9cc3b4b459d6655094dc1...@ms-cda-01.advanced-input.com>, dated Tue, 2 Apr 2013, "McInturff, Gary" <gary.mcintu...@esterline.com> writes: >Does one just state there are no requirements at this level on the DoC, >do they reference the appropriate directives for safety and EMC for the >final product. If it's not usable on its own, it may well be something that should not have a CE mark and a DoC. From 1.2 of the 'EMC Guide' 2010: 1.2 Defining the scope of apparatus The EMC Directive defines "apparatus" as any finished appliance, or combination thereof made commercially available (i.e. placed on the market) 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 a disturbance. 1.2.1 Finished appliances A finished appliance is any device or unit that delivers a function and has its own enclosure. A finished appliance is considered as apparatus in the sense of the EMC Directive, if it is intended for the end-user and thus has to fulfil all the applicable provisions of the Directive. When the finished appliance is intended exclusively for an industrial assembly operation for incorporation into other apparatus, it is not apparatus in the sense of the EMC Directive and consequently the EMC Directive does not apply. >We custom design bits and pieces for end customers in EU, and we keep >dancing around this issue both for ITE and medical devices. End customers are presumably manufacturers, not 'end-users' as defined in the Directive? If not, 1.2.3 of the Guide is applicable: 1.2.3 Components/Sub-assemblies In contrast to finished appliances, components /sub-assemblies do not, in general, have a proper enclosure intended for their final use. Components/sub-assemblies are often intended to be fitted into or added to an apparatus in order to add an additional function. 1.2.3.1 Components/sub-assemblies within scope Components or sub-assemblies on the market which are: - for incorporation into an apparatus by the end-user; - available to end-users; are to be considered as apparatus with regard to the application of the EMC Directive. The instructions for use accompanying the component or sub-assembly should include all relevant information, and should assume that adjustments or connections can be performed by an end-user not aware of the EMC implications. Illustrative examples: Plug-in cards for computers; Programmable logic controllers; Electric motors (except for induction motors, see section 1.1.4); Computer disk drives; >It might have a digital clock but no way to measure emissions until >it's in the final enclosure. The end user would then do some final >declarations and issue DoC's. So the 'end-user' in your terminology IS a manufacturer and NOT an end-user in the meaning given in the Directive. > >We make RoHS and WEEE statements but those are not currently part of >our DoC for EU > Just what does a DoC for a rock look like if I wanted to ship it? If it's not suitable for throwing, it is benign and thus exempt. -- OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk They took me to a specialist burns unit - and made me learn 'To a haggis'. John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. 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