IMO, part of the answer is how it is being sold. If the product is known and sold as Model ABC, then it should be tested as a system for compliance to the applicable directives and standards and a DoC would be written for Model ABC and it would indicate the various 'components' that comprise Model ABC. If we assume LVD and EMC then it would be tested as a system for compliance in a typical user configuration (we won't go down that path for now).
The TCF would have critical components list, basically the various 'components' that make up Model ABC and if they all have their own individual approvals, your done. If, however, they do not have individual approvals you may need to describe them in mode detail in the TCF. When additional 'components' are added, again assuming they have their own approvals you can add them to the DoC and the TCF. If you decide to not do any additional testing then write an Engineering Justification as to why no additional tests were done. Or you can retest the original configuration with the additional 'components'. My two cents worth. > On August 12, 2019 at 2:31 PM Brian Kunde <bkundew...@gmail.com> wrote: > > If I have an electronic product that I want to place on the market in > Europe, and the product is made up of several individual electronic devices > each powered by AC mains (packaged and sold together), do I place the CE > marking on only one of the devices or all devices? > > And if the answer is "all devices", then do I need a DoC for each device > or will one DoC be ok? If each device has its own identifier, can I just list > all identifiers on the DoC? OR can I simply list what the devices are > instead of their specific part numbers? > > In the same train of thought, If my product is called "E-box One", for > example, AND the product is made up of many individual electronic devices > each with their own identifying part number, does the marketing name "E-box > One" have to be on at least one of the devices that make it up OR does it > have to be on every one of the devices? > > How do we handle the case were say two years down the road a customer > with a 4-device system wants to expand to a 5-device system? Individually > these devices are nothing and could be viewed as an upgrade kit. Does this > "kit" have to have its own CE Marking and DoC? What if the "kit" is not > officially marketed; just the customer ordered a kit similar to ordering a > replacement part? > > How should these be handled? > > Thanks, > The Other Brian > - > ---------------------------------------------------------------- > > 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 mailto: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) http://www.ieee-pses.org/list.html > List rules: http://www.ieee-pses.org/listrules.html > > For help, send mail to the list administrators: > Scott Douglas <sdoug...@ieee.org mailto:sdoug...@ieee.org > > Mike Cantwell <mcantw...@ieee.org mailto:mcantw...@ieee.org > > > For policy questions, send mail to: > Jim Bacher <j.bac...@ieee.org mailto:j.bac...@ieee.org > > David Heald <dhe...@gmail.com mailto: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>
