Hi John, If prototype board can't get CE mark because of EMC may be it can get CE mark because of other directive. I'm not on time (probably wrong English) (I have speed a year developing new devices and now I will spend next year on CE bureaucracy - I dream to times when developing/bureaucracy was 90%/10%). I have heard that during I was busy ROHS become CE. If the prototype board are not excluded from ROHS you have the way to put CE on it and avoid entering Europe without any marking or DoC. Many prototype boards use some RF communication - than may be R&TTE will help you to make DoC and put CE on it.
Best Regards Piotr Galka ----- Original Message ----- From: EMC Guy To: EMC-PSTC@LISTSERV.IEEE.ORG Sent: Friday, October 25, 2013 5:47 PM Subject: Re: [PSES] EMC requirements for developer/evaluation boards Hi Brian, Your summary is exemplary. It points out exactly what I have also read in the Guide, that lead me to believe that a Developer Kit might by excluded from the EMC Directive. Particularly the End User definition. Which brings me to the second part of the problem: entering Europe without any marking or DoC whatsoever. Do you know of an established method to declare the non-applicability of CE-marking related directives, so the customs officials do not deny entry each time one of these boards is shipped to Europe. Something that would resemble FCC Form 740 for example. To John Woodgate: Thanks for the lead on Farnell, I have asked them the question, I'll post their answer if I ever get one. John On Fri, Oct 25, 2013 at 10:25 AM, Kunde, Brian <brian_ku...@lecotc.com> wrote: The Guide for the EMC Directive may be somewhat helpful. As it is sold, do you feel this type of product is really an "Apparatus"? It has no function as sold. Don't you have to incorporate it with other Components to make it work? Isn't it really a Component or sub-assembly incorporated with other Components or sub-assemblies to create a Prototype Apparatus not intended to be marketed? Can you classify it as a "Component" or "Sub-Assembly" which is NOT Intended for Incorporation into an Apparatus??? Referring to the Guide for the EMC Directive 2004/108/EC (8th February 2010), look at the Flow Charts starting on page 10; then go to Flow-Chart 2 on page 16. A "Component or Sub-Assembly NOT Intended for Incorporation into an Apparatus" would be "Excluded from the EMC Directive". An Apparatus must also be intended for the "End User". Though in this case, the End User would be an Engineer with knowledge of Electronics which would most likely include at least some knowledge of EMC. On page 17 of the guide where it describes what an End User is, see the text that says, "Generally an end-user is deemed to have no qualifications in the field of electromagnetic compatibility." Products not intended for the End User is Excluded from the EMC Directive. In the scope of the EMC Directive, it says, "When compliant with the provisions of the EMC Directive, equipment may be placed on the market and/ or put into service in the Community territory, freely moved and operated as designed and intended in the expected electromagnetic environment." So what is the "expected electromagnetic environment" for a product like this? It is intended to be used Temporarily in an engineering lab or Research and Development lab. What is the "Expected" EMC Environment of such an area where prototype electronic devices without any EMC testing is commonly operated for long periods of time? Though I cannot find any text that specifically excludes prototype electronic devices operating in an R&D environment, it is kind of a no brainer. Hope this is somewhat helpful. Brian -----Original Message----- From: John Woodgate [mailto:j...@jmwa.demon.co.uk] Sent: Friday, October 25, 2013 6:22 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] EMC requirements for developer/evaluation boards In message <caey+zhmv+erfxd--dvutjklyva7wbr1dtjdkjxfqyj6m5lg...@mail.gmail.com>, dated Fri, 25 Oct 2013, EMC Guy <emc.guy....@gmail.com> writes: >. My literature research did not come up with anything helpful, >especially for Europe As I explained, you will not find anything explicit about this issue. Wherever you are, you can ask Farnell, but the answers will be Europe-oriented. -- OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk If dictionaries were correct, we would only need one, because they would all give the same information. 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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