Isn't this one of the product compliance conditions that a Notified Body can issue a judgement? They *should* cast in your favor.
On Wed, Sep 27, 2023 at 7:35 AM Scott Douglas <[email protected]> wrote: > * This message originated outside of DISH and was sent by: > [email protected] <[email protected]> * > ------------------------------ > > Hello List Experts, > > We have a product that operates at line frequency (50 or 60 Hz). It is a > power conditioner which includes filtering, surge suppression, and extreme > voltage shut down. It is purely analog and contains nothing more complex > than transistors. > > We believe the EU EMC Directive does not apply to the product because it > does not operate any higher than 60 Hz and cannot generate EMI whether > radiated or conducted. > > From EU Directive 2014/30/EU, Article 2 (2 (d)): > > > 2. This Directive shall not apply to: > > (d) equipment the inherent nature of the physical characteristics of which > is such that: > > (i) it is incapable of generating or contributing to electromagnetic > emissions which exceed a level allowing radio and telecommunication > equipment and other equipment to operate as intended; and > (ii) it operates without unacceptable degradation in the presence of the > electromagnetic disturbance normally consequent upon its intended use; > > I am not aware of any EMI standards that cover this type of product, most > conducted EMI starts at 9kHz or 150 kHz, and radiated EMI typically starts > at 30 MHz. > > There is an inspector in an EU country that believes the EMC Directive > does apply. Their letter makes these statements: > > The EU Declaration of Conformity (DoC) is incorrect or incomplete (Article > 15; Annex IV; etc. of EU Directive 2014/30/EU). > > A conformity assessment procedure seems to be incomplete (Article 14) to > demonstrate that the apparatus meets the essential requirements set out in > Article 6 and Annex I of EU Directive 2014/30/EU. EU Directive 2014/30/EU > is missing. > > > Our DofC does not list the EMC Directive, specifically because we think it > does not apply. It also does not list any EMI/EMC standards as we find none > that apply. > > Is there a Harmonized Standard that would cover this type of product for > the EMC Directive? > > Is it normal to list a directive in a DofC if that directive does not > apply? > > How does one convince the inspector that the directive does not apply? > > Looking forward to any and all comments. > > Scott > ------------------------------ > > 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 All > emc-pstc postings are archived and searchable on the web at: > https://www.mail-archive.com/[email protected]/ > <https://www.mail-archive.com/[email protected]/> > > Website: https://ewh.ieee.org/soc/pses/ > <https://ewh.ieee.org/soc/pses/> > Instructions: https://ewh.ieee.org/soc/pses/list.html (including how to > unsubscribe) > <https://ewh.ieee.org/soc/pses/list.html> > List rules: https://ewh.ieee.org/soc/pses/listrules.html > <https://ewh.ieee.org/soc/pses/listrules.html> > > For help, send mail to the list administrators: > Mike Sherman at: [email protected] > Rick Linford at: [email protected] > > For policy questions, send mail to: > Jim Bacher at: [email protected] > ------------------------------ > > To unsubscribe from the EMC-PSTC list, click the following link: > https://listserv.ieee.org/cgi-bin/wa?SUBED1=EMC-PSTC&A=1 > <https://listserv.ieee.org/cgi-bin/wa?SUBED1=EMC-PSTC&A=1> > -- Charles Grasso Dish Technologies (c) 303-204-2974 (w) 303-706-5467 (h) 303-317-5530 (e ) [email protected] (e2) [email protected] - ---------------------------------------------------------------- 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 <[email protected]> All emc-pstc postings are archived and searchable on the web at: https://www.mail-archive.com/[email protected]/ Website: https://ewh.ieee.org/soc/pses/ Instructions: https://ewh.ieee.org/soc/pses/list.html (including how to unsubscribe) List rules: https://ewh.ieee.org/soc/pses/listrules.html For help, send mail to the list administrators: Mike Sherman at: [email protected] Rick Linford at: [email protected] For policy questions, send mail to: Jim Bacher: <[email protected]> _________________________________________________ To unsubscribe from the EMC-PSTC list, click the following link: https://listserv.ieee.org/cgi-bin/wa?SUBED1=EMC-PSTC&A=1
