Brian, I always appreciate your comments based upon your experience and your enthusiastic cynicism toward life. Altho I tried to separate the variables it appears that I did not do it sufficiently. In my prior post I allowed as how the certification expenses are on a product or product family basis including associated certificate costs. The FUS, however, is based upon factory location and by similar equipment group (e.g. UL Efile #s); the inspection is based upon looking at something in each equipment group so not every product type is examined each FUS Qtly visit. Further the inspection time/cost is fixed so that the FUS cost to the mfgr is spread out over the units produced , whether a single product or several related products and includes the volume (not from the inspectors point of view but from the mfgrs bean counter point of view). My example pointed to this type of scenario. Perhaps this provides more clarification.
:>) br, Pete Peter E Perkins, PE Principal Product Safety & Regulatory Affairs Consultant PO Box 23427 Tigard, ORe 97281-3427 503/452-1201 IEEE Life Fellow p.perk...@ieee.org -----Original Message----- From: Brian O'Connell <oconne...@tamuracorp.com> Sent: Tuesday, June 19, 2018 10:43 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] UL Listing of Computer Keyboard FUS audit and certification and license costs are not necessarily able to be distributed over a larger production number; will depend on the particular NRTL/SCC. For many product combinations, there is no cost efficiency for volume or for factory consolidation for the respective 'regulatory' remit. The agencies will always find a way to structure fees and processes to extract maximum dollars and minimize engineering time. That is, for any given agency, invoiced line items will always increase, while provided services will always decrease. Doubleplusgood. Less is more. Brian Senior News Reviewer of Oceania From: Pete Perkins [mailto:00000061f3f32d0c-dmarc-requ...@ieee.org] Sent: Tuesday, June 19, 2018 8:56 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] UL Listing of Computer Keyboard James, As an American I’m not privy to the inner workings of making the sausage called EU Directives. However, there is a political process involved an all of this work and I’m sure that manufacturers and political regulators pushed back and forth to get to the final result for the update to the LVD. I agree with your assessment that companies don’t want the extra cost of type approval and have prevailed at this point for this set of circumstances. Somewhat related comment; since your keyboard is USB powered you need to understand that USB, like POE, is going to higher power delivery – 100W coming for USB3. There are additional issues that need to be addressed and IEC 62368-3 addresses power over communication cables no matter what the product type is; products using such comm cables will need to be assessed to ensure that they provide the proper protection coming and going when attached to these common outlet sockets. Again, NRTL certification is appropriate for evaluating this equipment. Finally, yes, these NRTL certifications are on a product by product basis; you can bunch similar models into one certification report tho. From experience, the FUS unit cost decreases as there is more product produced. Increasing the volume of either a product model or adding more similar models will drive down the unit cost as the inspection time is spread over more models and units. For instance for your 1K dollars/Euros or whatever, if the factory only produces a single unit per inspection quarter then that unit eats the entire cost; if the factory produces 10K units per inspection quarter then the unit cost is quite cheap. :>) br, Pete Peter E Perkins, PE Principal Product Safety & Regulatory Affairs Consultant PO Box 23427 Tigard, ORe 97281-3427 503/452-1201 IEEE Life Fellow p.perk...@ieee.org - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <emc-p...@ieee.org> All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <sdoug...@ieee.org> Mike Cantwell <mcantw...@ieee.org> For policy questions, send mail to: Jim Bacher: <j.bac...@ieee.org> David Heald: <dhe...@gmail.com> - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <emc-p...@ieee.org> All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <sdoug...@ieee.org> Mike Cantwell <mcantw...@ieee.org> For policy questions, send mail to: Jim Bacher: <j.bac...@ieee.org> David Heald: <dhe...@gmail.com>
