Thanks all who responded. I have a better idea in mind of how to proceed. 

 "There are known knowns; there are things we know we know.
 We also know there are known unknowns; that is to say, we know there are some 
things we do not know.
 But there are also unknown unknowns - the ones we don't know we don't know.

Heavy sigh
Gary


-----Original Message-----
From: Pete Perkins [mailto:peperkin...@cs.com] 
Sent: Wednesday, April 03, 2013 6:02 AM
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?

PSNetters,

        This whole issue of how to treat incomplete products has existed
from the beginning.  In many cases it was quite clear that the components
didn't require a CE marking/DoC but component manufacturers started using it
anyway to clearly indicate that their component was compliant.  So, the
situation was backed into in a sense. 

        I have lamented the situation before.  It is unfortunate the EU
didn't take a page from the UR program and declare requirements for
components in a unique way.  It would have been quite straightforward to
expand the use of the Declaration of Incorporation (DoI) from the Machinery
Directive for general use in this sense. It would have covered the
importation/control aspects as well as provided clarity in applying the
component in the end product.  Politicians/Regulators never seem to quite
understand the needs of business in implementing their requirements.

        I do like the comments regarding adding the Conditions of
Acceptability and Installation/Electrical Code Information; it makes the
document more self standing. 

        Perhaps this will start a groundswell of common sense application of
needed information on the documentation, a needed improvement as stated in
this thread.     

:>)     br,     Pete
 
Peter E Perkins, PE
Principal Product Safety Engineer
PO Box 23427
Tigard, ORe  97281-3427
 
503/452-1201     fone/fax
p.perk...@ieee.org
 

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