Gert

My comment about major manufacturers was partially based on the appearance
of a Sony TV on the apartmenttherapy website, as linked by Cortland, which
appeared to be unduly susceptible to external interference and you would not
expect that from a large manufacturer of that stature - and that made me
speculate as to which other such company's products have the same issues?

John E Allen
W. London, UK

-----Original Message-----
From: ce-test, qualified testing bv - Gert Gremmen
[mailto:g.grem...@cetest.nl] 
Sent: 01 October 2016 10:57
To: John Allen; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] [RFI] Part 15 isn't enough..

John Allen wrote:
>That's probably why the products from some major multinationals (as
mentioned in the previously linked >website) could not be sold elsewhere in
the major World markets without suitable compliance and >verification, and
yet can be sold in the US.

I was wondering if that is really the case ?  Can our US collegues witness
that product of reputable manufacturers are not wearing the CE marking in
the US. ??  




Regards,

Ing. Gert Gremmen
Approvals manager
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From: John Allen [mailto:john_e_al...@blueyonder.co.uk]
Sent: Friday 30 September 2016 15:31
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

Dieter

Yes, that's what the words state, and have done for years - but, with no
clear requirements or guidelines as to the technical requirements (tests,
limits, pass/fail conditions etc.) or the actual need to do verification,
then many/most suppliers appear to me to ignore those words! I think the
same was true in Europe during the period after the original EMC Directive
(76/889/EEC) was published but before the CE marking requirement version
(89/336/EC) came out and required "proof" of compliance in the form of test
reports, tech files and the CE marking - after that, things gradually began
to change! 

The big problem in 1989, and for some years after, was the almost total lack
of standards against which to do the tests and assessments on non-military
products. However, some 25+ years later, the same cannot be said as there
are many international, and even US trade-body, standards which could almost
immediately be used as the basis for realistic sets of requirements to be
formulated.

Many multi-national and US companies already do that as normal development
practice, but in the current US legislative environment they can then "cost
cut" for the US market by either not doing that testing on US-market
specific products, or "cost reducing" their internationally-sold products
for sale in that market. That's probably why the products from some major
multinationals (as mentioned in the previously linked website) could not be
sold elsewhere in the major World markets without suitable compliance and
verification, and yet can be sold in the US. 

John E Allen
W. London, UK

From: Paasche, Dieter [mailto:dieter.paas...@christiedigital.com]
Sent: 30 September 2016 13:59
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

In general I believe that changing part 15 will be very difficult since it
is a legal  (political) document and would need congress approval for
changes. Different that than in the EU where you have directives and
harmonized standards somehow separately. 

 
Also the US is part of international committees and heavily participates on
emissions and immunity standards. However implementation and enforcing is
always difficult.
 
And finally, isn't FCC indirectly stating that immunity has to be met as
well?  FCC Part 15.5 (b)
§15.5   General conditions of operation.
     (a) Persons operating intentional or unintentional radiators shall not
be deemed to have any vested or recognizable right to continued use of any
given frequency by virtue of prior registration or certification of
equipment, or, for power line carrier systems, on the basis of prior
notification of use pursuant to §90.35(g) of this chapter.
     (b) Operation of an intentional, unintentional, or incidental radiator
is subject to the conditions that no harmful interference is caused and that
interference must be accepted that may be caused by the operation of an
authorized radio station, by another intentional or unintentional radiator,
by industrial, scientific and medical (ISM) equipment, or by an incidental
radiator.
     (c) The operator of a radio frequency device shall be required to cease
operating the device upon notification by a Commission representative that
the device is causing harmful interference. Operation shall not resume until
the condition causing the harmful interference has been corrected.
     (d) Intentional radiators that produce Class B emissions (damped wave)
are prohibited.
 
Sincerely, 
 
Dieter Paasche
 
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