[PSES] FCC plan to open New 5GHz band for WiFi

[Chris]

Folks,
 
I saw the comments below in FCC Jan 9, 2013 news?
 "Chairman Genachowski said that the FCC will take the first steps next month 
to unleash up to 195
megahertz of spectrum in the 5 gigahertz band. This would be the largest block 
of unlicensed spectrum to
be made available for expansion of Wi-Fi since 2003".
 
FCC will open “New” 5GHz band for WiFi
devices.
w   5350-5470MHz
w   5850-5925MHz
 
will part of the 5350-5470MHz band be included in DFS band?
good to get 5850-5925MHz open for WiFi use.
 
regards
 
Christopher

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[PSES] Conflict Minerals Due Diligence Webinar

[Peter Merguerian]

Dear members

Regret delay in informing you on this informative webinar tomorrow 9:00 am PST

Registration link on my website. 

www.goglobalcompliance.com/news_and_events

Sent from my iPhone

Peter S. Merguerian
pe...@goglobalcompliance.com
Go Global Compliance Inc.
www.goglobalcompliance.com
(408) 931-3303

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Re: [PSES] One DoC per manufactured Unit?!

[John Woodgate]

In message 
<617eb8c8634c9149aa66c853d7b8ac53d...@by2prd0310mb389.namprd03.prod.outlo
ok.com>, dated Mon, 14 Jan 2013, "Crane, Lauren" 
 writes:


I very quickly learned that law makers do not have any obligation to 
understand in depth the industry/ies they may be impacting. Most of 
them have only very high level understanding of how businesses work at 
a practical level,


In Britain, I have seen an improvement over the last ten years or so in 
the understanding possessed by civil servants about industry issues, but 
it is still the case that what one industry person tells them tends to 
be assumed to be true of all industry sectors.


So, for example, if a person selling large machines to 
technically-enlightened customers says he can provide DoCs with 
individual serial numbers and colour pictures, it might be assumed, 
without much thought, that people selling inexpensive electronic devices 
to consumers can do the same. ***It's up to those people to make their 
views known, whether they are asked for or not.***

--
OOO - Own Opinions Only. See www.jmwa.demon.co.uk
The longer it takes to make a point, the more obtuse it proves to be.
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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Re: [PSES] One DoC per manufactured Unit?!

[Crane, Lauren]

John,

I share your hope. I have the fortunate experience of doing some policy 
advocacy on RoHS2 and WEEE2 face to face with members of Parliament and Council 
and I very quickly learned that law makers do not have any obligation to 
understand in depth the industry/ies they may be impacting. Most of them have 
only very high level understanding of how businesses work at a practical level, 
and often it is highly prejudiced towards one business sector (e.g., cell 
phones vs. ion implanters used to make semiconductors).  What is so obviously a 
non-value-added hassle to some of us may have been conceived of as a great 
solution to an abstract problem.

To rephrase... while it makes no practical sense to require a unit serial 
number in a DoC, it could well be what the Commission intended. The approvers 
of the NLF may not have understood the possible impact of what they signed into 
law. I think the little skirmish that is happening over the LVD recast in this 
regard is a sign that some few people are now "waking up".

Regards,
Lauren Crane
KLA-Tencor

From: Tyra, John [mailto:john_t...@bose.com]
Sent: Monday, January 14, 2013 12:42 PM
To: Crane, Lauren; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: One DoC per manufactured Unit?!

Thanks Lauren,

I appreciate your insight as it is always tricky business interpreting what the 
regulator's intended when they wrote the Directives.

Hopefully this is not what the powers that be intended because, as John pointed 
out, it is easier and less expensive to create paperwork then it is to produce 
a compliant product and I see no value added if this is indeed the approach we 
must comply with.

Regards,

John

From: emc-p...@ieee.org 
[mailto:emc-p...@ieee.org] On Behalf Of 
Crane, Lauren
Sent: Monday, January 14, 2013 11:56 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: One DoC per manufactured Unit?!

Thanks John and all for your comments.

There is a persistent problem knitted into this issue regarding the meaning of 
'product'.

Most inquiries to the Commission tend to end up clarifying that 'product' means 
a particular unit and not a model line or type. This is particularly true when 
struggling with the grandfathering issue. The date for which a 'product' is 
placed on the market is the date on which that particular unit entered the EU. 
It is *not* the date when the model-line or type was first introduced to the EU.

The "blue-guide" states on page 18, "Moreover, the concept of placing on the 
market refers to each individual product, not to a type of product, and whether 
it was manufactured as an individual unit or in series."

Therefore, "Object of the declaration" (and the other equivalent statements) 
required by various CE directives can well mean a model-line or type 
description (except, perhaps, the very unique language of the MD which 
references serial number). But the new add in NLF is the point 1 "1. 
No...(unique identification of the product)" and it hints to me of a per-unit 
identification number.

Why else would this new element be added by the NLF (New Legislative Framework) 
when "object of the declaration" has long been explained as 'model-line'? And 
why would parliamentarians be getting so tricky in their amendment proposals if 
it were not the Commissions intent to have this be a per-unit identifier?

Regards,
Lauren Crane
KLA-Tencor

From: Tyra, John [mailto:john_t...@bose.com]
Sent: Sunday, January 13, 2013 3:21 PM
To: Crane, Lauren; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: One DoC per manufactured Unit?!

I don't know Lauren, I read COM(2011) 773 final and NLF Council Decision 
768/2008 and I interpret it to mean you need a unique model number which can be 
cross referenced with the TCF reports for that model. I am not seeing where it 
requires each unit to have a unique ID# listed on the DoC which essentially 
means a unique DoC to be shipped with each product?

As long as the DoC has unique model numbers listed for the equipment you are 
declaring as compliant, and has the date of issue, the authorities can cross 
reference this for compliance by checking the products model number and DOM 
against the DoC which is required to be on the equipment being put onto the 
market in the EU. And of course your TCF reports must cross reference to the 
model number on the label.

Can you be more specific on which wording you are talking about?

What I found much more interesting was COM(2011) 773 final Annex IV seems to 
infer that you must ("shall") include a color photo of the equipment on the DoC

4. Object of the declaration (identification of electrical equipment allowing 
traceability.
It shall include a colour image of sufficient clarity to enable the 
identification of the
electric equipment).

COM(2011) 773 final Annex IV references Annex III of NLF Council Decision 
768/2008  which list the photo as optional

Re: [PSES] One DoC per manufactured Unit?!

[Tyra, John]

Thanks Lauren,

I appreciate your insight as it is always tricky business interpreting what the 
regulator's intended when they wrote the Directives.

Hopefully this is not what the powers that be intended because, as John pointed 
out, it is easier and less expensive to create paperwork then it is to produce 
a compliant product and I see no value added if this is indeed the approach we 
must comply with.

Regards,

John

From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Crane, Lauren
Sent: Monday, January 14, 2013 11:56 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: One DoC per manufactured Unit?!

Thanks John and all for your comments.

There is a persistent problem knitted into this issue regarding the meaning of 
'product'.

Most inquiries to the Commission tend to end up clarifying that 'product' means 
a particular unit and not a model line or type. This is particularly true when 
struggling with the grandfathering issue. The date for which a 'product' is 
placed on the market is the date on which that particular unit entered the EU. 
It is *not* the date when the model-line or type was first introduced to the EU.

The "blue-guide" states on page 18, "Moreover, the concept of placing on the 
market refers to each individual product, not to a type of product, and whether 
it was manufactured as an individual unit or in series."

Therefore, "Object of the declaration" (and the other equivalent statements) 
required by various CE directives can well mean a model-line or type 
description (except, perhaps, the very unique language of the MD which 
references serial number). But the new add in NLF is the point 1 "1. 
No...(unique identification of the product)" and it hints to me of a per-unit 
identification number.

Why else would this new element be added by the NLF (New Legislative Framework) 
when "object of the declaration" has long been explained as 'model-line'? And 
why would parliamentarians be getting so tricky in their amendment proposals if 
it were not the Commissions intent to have this be a per-unit identifier?

Regards,
Lauren Crane
KLA-Tencor

From: Tyra, John [mailto:john_t...@bose.com]
Sent: Sunday, January 13, 2013 3:21 PM
To: Crane, Lauren; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: One DoC per manufactured Unit?!

I don't know Lauren, I read COM(2011) 773 final and NLF Council Decision 
768/2008 and I interpret it to mean you need a unique model number which can be 
cross referenced with the TCF reports for that model. I am not seeing where it 
requires each unit to have a unique ID# listed on the DoC which essentially 
means a unique DoC to be shipped with each product?

As long as the DoC has unique model numbers listed for the equipment you are 
declaring as compliant, and has the date of issue, the authorities can cross 
reference this for compliance by checking the products model number and DOM 
against the DoC which is required to be on the equipment being put onto the 
market in the EU. And of course your TCF reports must cross reference to the 
model number on the label.

Can you be more specific on which wording you are talking about?

What I found much more interesting was COM(2011) 773 final Annex IV seems to 
infer that you must ("shall") include a color photo of the equipment on the DoC

4. Object of the declaration (identification of electrical equipment allowing 
traceability.
It shall include a colour image of sufficient clarity to enable the 
identification of the
electric equipment).

COM(2011) 773 final Annex IV references Annex III of NLF Council Decision 
768/2008  which list the photo as optional

4. Object of the declaration (identification of product allowing traceability. 
It may include a photograph, where
appropriate):

While this is not as onerous as having to have a unique DoC for each product it 
will still mean a lot of work for companies to modify their current DoC's to 
add the photos as I have never seen a DoC which included product photos.


From: emc-p...@ieee.org 
[mailto:emc-p...@ieee.org] On Behalf Of 
Crane, Lauren
Sent: Wednesday, January 09, 2013 5:14 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: One DoC per manufactured Unit?!

As many know, the LVD is in the process of being recast for alignment with the 
New Legislative Framework (NLF).

The Commission proposed text, (COM(2011) 773 final),  calls for what looks like 
a unique equipment identification number do be provided in the Declaration of 
Conformity (DoC). The same sort of language is used in the NLF Council Decision 
768/2008, and RoHS2 criteria for the DoC.

This seems to imply there must be a DoC provided with a unit that contains that 
unit's unique identification number (e.g., serial number), and that a DoC that 
references an entire model line would not be acceptable.

Hints that this is the case can be seen in the Parliament's proposed am

Re: [PSES] One DoC per manufactured Unit?!

[John Woodgate]

In message , dated Mon, 14 Jan 2013, 
John Woodgate  writes:


n message <021c01cdf279$f5b33720$e119a560$@acbcert.com>, dated Mon, 14 
Jan 2013, Michael Derby  writes:


I believe one of the situations that arises from the NLF is that the 
requirements of each Directive are being harmonised. This often means 
looking at all the Directives, finding the 'most strict requirement' 
and then applying it to all the others.


That is neither logical nor reasonable. Shall we have all the special 
requirements of the Machinery and Automotive Directives applied to 
toys, for example?


So, you couldn't have this requirement for the Toy Safety Directive 
and then say that it doesn't apply to other Directives, because that 
would not be in line with the Directive harmonisation and NLF.


If that is the official view, it is even more insane than anything 
previously emitted from Brussels.


Perhaps I should say more about 'harmonization'. It cannot mean 
procrustean (so look it up!) 'identicality' or 'no difference' unless it 
is of extremely restricted application. Different topics almost de facto 
imply differences in regulation.


The whole point of 'harmonization' is to eliminate **unnecessary and 
unjustified** differences. It would be difficult for anyone to object to 
that.


I wonder to what extent these new requirements are of the nature of 
'being seen to be doing something', like the air travel 'security' 
requirements.

--
OOO - Own Opinions Only. See www.jmwa.demon.co.uk
The longer it takes to make a point, the more obtuse it proves to be.
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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Re: [PSES] user's group ??

[Glen Watkins]

Sorry, I forgot to mention that TILE! also has a LinkedIn site. Go to LinkedIn 
and search “TILE!”.

Glen Watkins
Global Marcom Director
ETS-Lindgren
1301 Arrow Point Drive
Cedar Park, Texas  78613
p: 1+512.531.6414
f:  1+512.531.6514
glen.watk...@ets-lindgren.com
www.ets-lindgren.com
“Enabling Your Success”
CONFIDENTIALITY NOTICE: The information in this communication may be 
confidential, and is intended only for the use of the recipient(s) named above. 
You are hereby notified that any dissemination, distribution, or copying of 
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From: Glen Watkins
Sent: Monday, January 14, 2013 11:00 AM
To: 'Derek Walton'; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] user's group ??

There is a TILE! user group that meets every year at the IEEE EMC Symposium. 
There is also a TILE! users web portal 
https://support.ets-lindgren.com/TILE/pages/home.aspx


Glen Watkins
Global Marcom Director
ETS-Lindgren
1301 Arrow Point Drive
Cedar Park, Texas  78613
p: 1+512.531.6414
f:  1+512.531.6514
glen.watk...@ets-lindgren.com
www.ets-lindgren.com
“Enabling Your Success”
CONFIDENTIALITY NOTICE: The information in this communication may be 
confidential, and is intended only for the use of the recipient(s) named above. 
You are hereby notified that any dissemination, distribution, or copying of 
this communication, or any of its contents, to any other party, is strictly 
prohibited. If you have received this communication in error, please return it 
to the sender immediately and delete the original message and any copy of it 
from your computer system. If you have any questions concerning this message, 
please contact the sender.


From: Derek Walton [mailto:lfresea...@aol.com]
Sent: Friday, January 11, 2013 3:19 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] user's group ??

Yes, there is a linked in Teseq Compliance 5 users group
-Original Message-
From: Conway, Patrick mailto:pcon...@ball.com>>
To: EMC-PSTC mailto:EMC-PSTC@LISTSERV.IEEE.ORG>>
Sent: Fri, Jan 11, 2013 3:12 pm
Subject: user's group ??
We are considering new automation tools for some of our MIL-STD-461 and DO-160 
tests.
I am hoping that there are user’s groups or forums for some of the more popular 
software packages.

Does anyone know of, or belong to, forums for TILE!, EMC Automation (TDK), 
RadiMotion (DARE!!), EMITest (CKC), or any other?

Thanks in advance.
//
Patrick Conway
pcon...@ball.com
303.533.7165
Wetmoor WMR1
Westminster, CO 80021




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>
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[PSES] Risk Assessments in the EU

[jral...@productsafetyinc.com]

Hi,

We're looking for someone in the Netherlands to review a client's product 
safety and risk assessment process.

Please reply to my direct email.

Thanks,

John Allen
President
Product Safety Consulting, Inc.
605 Country Club Drive, Suites I & J
Bensenville, IL  60106
P - 630 238-0188 / F - 630 238-0269
1-877-804-3066
jral...@productsafetyinc.com
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Re: [PSES] One DoC per manufactured Unit?!

[John Woodgate]

In message <021c01cdf279$f5b33720$e119a560$@acbcert.com>, dated Mon, 14 
Jan 2013, Michael Derby  writes:


I believe one of the situations that arises from the NLF is that the 
requirements of each Directive are being harmonised. This often means 
looking at all the Directives, finding the 'most strict requirement' 
and then applying it to all the others.


That is neither logical nor reasonable. Shall we have all the special 
requirements of the Machinery and Automotive Directives applied to toys, 
for example?


So, you couldn't have this requirement for the Toy Safety Directive and 
then say that it doesn't apply to other Directives, because that would 
not be in line with the Directive harmonisation and NLF.


If that is the official view, it is even more insane than anything 
previously emitted from Brussels.

--
OOO - Own Opinions Only. See www.jmwa.demon.co.uk
The longer it takes to make a point, the more obtuse it proves to be.
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

-

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Re: [PSES] One DoC per manufactured Unit?!

[Michael Derby]

I think that's part of the history, John.

I believe one of the situations that arises from the NLF is that the 
requirements of each Directive are being harmonised.
This often means looking at all the Directives, finding the 'most strict 
requirement' and then applying it to all the others.

So, you couldn't have this requirement for the Toy Safety Directive and then 
say that it doesn't apply to other Directives, because that would not be in 
line with the Directive harmonisation and NLF.
The alternative would be to remove the requirement from the Toy Safety 
Directive, which obviously it not what they want to do.

I witnessed similar conversations with regard to the 5mm height of the CE Mark. 
  Some Directives don't (didn't) worry too much about CE Mark height but they 
will need to, to align through the NLF.

My glasses/spectacles have thin little stems of about 2.5mm thickness, so the 
CE Mark on the stem is about 2mm high.
I'm not sure how they could fit a 5mm CE Mark onto a 2.5mm stem.

Of course, I need to take my glasses off to see the CE Mark.   But without my 
glasses on, I cannot see a 2mm CE Mark.
So, maybe I just don't care.   Ignorance is bliss.


Michael.



Michael Derby
Regulatory Engineer
ACB Europe


-Original Message-
From: John Cotman [mailto:john.cot...@conformance.co.uk] 
Sent: 14 January 2013 16:37
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] One DoC per manufactured Unit?!

The Toy Safety Directive already has the picture requirement on the D of C.

John C

-Original Message-
From: ce-test, qualified testing bv - Gert Gremmen [mailto:g.grem...@cetest.nl]
Sent: 14 January 2013 14:37
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] One DoC per manufactured Unit?!

You can make fun of it, but all these things have been introduced with the goal 
of creating a better level playing field, thus making possible to find, an 
pursue those manufacturers that spoil the market by selling untested, possible 
unsafe cheap rubbish.


Customs are better able to simply stop products with false DoC, this way.

Imagine the poor customs guy, having to tell if these little green pieces of 
plastic with copper screws on it really are the KML032-1234-s-XX as the DoC 
states ?? 
If they are, they may withold the product and dupe the honest manufacturer, if 
they assume it's ok, another batch of unsafe rubbish may dupe the consumer (in 
the end).


If you look at it like that, the costs for even (if it were required) a serial 
number and a hologram and color image and a fully operating miniature  model 
with each DoC are a bargain compared to the increased benefit that goes with 
increased sales.;<))  if you are not on the side of the cheaters. 


And of course, it also brings the cheating to a higher level, so expect
even more stringent measures in the future... it's an everlasting battle
between the GOOD and the BAD

Regards,

Ing.  Gert Gremmen, BSc



g.grem...@cetest.nl
www.cetest.nl

Kiotoweg 363
3047 BG Rotterdam
T 31(0)104152426
F 31(0)104154953

P Before printing, think about the environment. 



-Oorspronkelijk bericht-
Van: emc-p...@ieee.org [mailto:emc-p...@ieee.org] Namens John Woodgate
Verzonden: Monday, January 14, 2013 3:00 PM
Aan: EMC-PSTC@LISTSERV.IEEE.ORG
Onderwerp: Re: One DoC per manufactured Unit?!

In message
<64D32EE8B9CBDD44963ACB076A5F6ABB0262C6D0@Mailbox-Tech.lecotech.local>,
dated Mon, 14 Jan 2013, "Kunde, Brian"  writes:

>As far as the color picture, well, that?s just stupid. Why not ask for 
>a hologram of the product?

A fully working full-size model would be even better. But for some suppliers, 
that would be too difficult.(;-)

>Our DOC is included in our manual and we are not going to add color for 
>a single picture.
>
>I?m not sure where we would put a picture anyway. Our DOC is a full 
>page now. It would most likely have to be very small or on a separate 
>page.

Does the manual have a picture of the product on the front cover already?
--
OOO - Own Opinions Only. See www.jmwa.demon.co.uk The longer it takes to make a 
point, the more obtuse it proves to be.
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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--

Re: [PSES] user's group ??

[Glen Watkins]

There is a TILE! user group that meets every year at the IEEE EMC Symposium. 
There is also a TILE! users web portal 
https://support.ets-lindgren.com/TILE/pages/home.aspx


Glen Watkins
Global Marcom Director
ETS-Lindgren
1301 Arrow Point Drive
Cedar Park, Texas  78613
p: 1+512.531.6414
f:  1+512.531.6514
glen.watk...@ets-lindgren.com
www.ets-lindgren.com
“Enabling Your Success”
CONFIDENTIALITY NOTICE: The information in this communication may be 
confidential, and is intended only for the use of the recipient(s) named above. 
You are hereby notified that any dissemination, distribution, or copying of 
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to the sender immediately and delete the original message and any copy of it 
from your computer system. If you have any questions concerning this message, 
please contact the sender.


From: Derek Walton [mailto:lfresea...@aol.com]
Sent: Friday, January 11, 2013 3:19 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] user's group ??

Yes, there is a linked in Teseq Compliance 5 users group

-Original Message-
From: Conway, Patrick mailto:pcon...@ball.com>>
To: EMC-PSTC mailto:EMC-PSTC@LISTSERV.IEEE.ORG>>
Sent: Fri, Jan 11, 2013 3:12 pm
Subject: user's group ??
We are considering new automation tools for some of our MIL-STD-461 and DO-160 
tests.
I am hoping that there are user’s groups or forums for some of the more popular 
software packages.

Does anyone know of, or belong to, forums for TILE!, EMC Automation (TDK), 
RadiMotion (DARE!!), EMITest (CKC), or any other?

Thanks in advance.
//
Patrick Conway
pcon...@ball.com
303.533.7165
Wetmoor WMR1
Westminster, CO 80021




This message and any enclosures are intended only for the addressee.  Please



notify the sender by email if you are not the intended recipient.  If you are



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>
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Re: [PSES] One DoC per manufactured Unit?!

[Crane, Lauren]

Thanks John and all for your comments.

There is a persistent problem knitted into this issue regarding the meaning of 
'product'.

Most inquiries to the Commission tend to end up clarifying that 'product' means 
a particular unit and not a model line or type. This is particularly true when 
struggling with the grandfathering issue. The date for which a 'product' is 
placed on the market is the date on which that particular unit entered the EU. 
It is *not* the date when the model-line or type was first introduced to the EU.

The "blue-guide" states on page 18, "Moreover, the concept of placing on the 
market refers to each individual product, not to a type of product, and whether 
it was manufactured as an individual unit or in series."

Therefore, "Object of the declaration" (and the other equivalent statements) 
required by various CE directives can well mean a model-line or type 
description (except, perhaps, the very unique language of the MD which 
references serial number). But the new add in NLF is the point 1 "1. 
No...(unique identification of the product)" and it hints to me of a per-unit 
identification number.

Why else would this new element be added by the NLF (New Legislative Framework) 
when "object of the declaration" has long been explained as 'model-line'? And 
why would parliamentarians be getting so tricky in their amendment proposals if 
it were not the Commissions intent to have this be a per-unit identifier?

Regards,
Lauren Crane
KLA-Tencor

From: Tyra, John [mailto:john_t...@bose.com]
Sent: Sunday, January 13, 2013 3:21 PM
To: Crane, Lauren; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: One DoC per manufactured Unit?!

I don't know Lauren, I read COM(2011) 773 final and NLF Council Decision 
768/2008 and I interpret it to mean you need a unique model number which can be 
cross referenced with the TCF reports for that model. I am not seeing where it 
requires each unit to have a unique ID# listed on the DoC which essentially 
means a unique DoC to be shipped with each product?

As long as the DoC has unique model numbers listed for the equipment you are 
declaring as compliant, and has the date of issue, the authorities can cross 
reference this for compliance by checking the products model number and DOM 
against the DoC which is required to be on the equipment being put onto the 
market in the EU. And of course your TCF reports must cross reference to the 
model number on the label.

Can you be more specific on which wording you are talking about?

What I found much more interesting was COM(2011) 773 final Annex IV seems to 
infer that you must ("shall") include a color photo of the equipment on the DoC

4. Object of the declaration (identification of electrical equipment allowing 
traceability.
It shall include a colour image of sufficient clarity to enable the 
identification of the
electric equipment).

COM(2011) 773 final Annex IV references Annex III of NLF Council Decision 
768/2008  which list the photo as optional

4. Object of the declaration (identification of product allowing traceability. 
It may include a photograph, where
appropriate):

While this is not as onerous as having to have a unique DoC for each product it 
will still mean a lot of work for companies to modify their current DoC's to 
add the photos as I have never seen a DoC which included product photos.


From: emc-p...@ieee.org 
[mailto:emc-p...@ieee.org] On Behalf Of 
Crane, Lauren
Sent: Wednesday, January 09, 2013 5:14 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: One DoC per manufactured Unit?!

As many know, the LVD is in the process of being recast for alignment with the 
New Legislative Framework (NLF).

The Commission proposed text, (COM(2011) 773 final),  calls for what looks like 
a unique equipment identification number do be provided in the Declaration of 
Conformity (DoC). The same sort of language is used in the NLF Council Decision 
768/2008, and RoHS2 criteria for the DoC.

This seems to imply there must be a DoC provided with a unit that contains that 
unit's unique identification number (e.g., serial number), and that a DoC that 
references an entire model line would not be acceptable.

Hints that this is the case can be seen in the Parliament's proposed amendments 
to the Commission's text of the LVD, where they cleverly change the unique unit 
number into a unique DoC number (much easier to deal with).


Amendment 48 - Zuzana Roithová
Annex IV - point 1
Text proposed by the Commission  --> 1. No xx (unique identification of the 
electric equipment):
Amendment Proposed --> 1. No xx (unique identification of the declaration):


Also, the previous Draft version of the RoHS2 FAQ had a question 9.9 which 
said, in effect "no, no, we meant a unique DoC number" has been entirely 
withdrawn in the current version of the FAQ.

Does anyone reading have any additional perspective on this battle

Re: [PSES] One DoC per manufactured Unit?!

[John Woodgate]

In message , 
dated Mon, 14 Jan 2013, "ce-test, qualified testing bv - Gert Gremmen" 
 writes:


You can make fun of it, but all these things have been introduced with 
the goal of creating a better level playing field, thus making possible 
to find, an pursue those manufacturers that spoil the market by selling 
untested, possible unsafe cheap rubbish.


I'm not making fun of it, but if one takes too solemn an approach it can 
leave you screaming mad.


Customs are better able to simply stop products with false DoC, this 
way.


But ARE they? Is it realistic?


Imagine the poor customs guy, having to tell if these little green 
pieces of plastic with copper screws on it really are the 
KML032-1234-s-XX as the DoC states ??


These come in bulk packs of 1000, each in a sealed plastic retail pack. 
How do you think the poor customs guy is going to check that each 
individual item has inside the sealed pack a DoC with its individual 
serial number?


If they are, they may withold the product and dupe the honest 
manufacturer, if they assume it's ok, another batch of unsafe rubbish 
may dupe the consumer (in the end).


An unsafe rubbish product can easily have all the paperwork in 
meticulous order. In fact, it's far easier to get the paperwork right 
than it is to design and manufacture safe products.


If you look at it like that, the costs for even (if it were required) a 
serial number and a hologram and color image and a fully operating 
miniature


I didn't say 'miniature'. I had a BOGOF in mind - Buy One, Get One Free.

model with each DoC are a bargain compared to the increased benefit 
that goes with increased sales.;<))  if you are not on the side of 
the cheaters.


All those things could be provided with a product that is unsafe and 
useless. These requirements DO NOTHING to assure what they are 
presumably intended to assure, so are not useful.

--
OOO - Own Opinions Only. See www.jmwa.demon.co.uk
The longer it takes to make a point, the more obtuse it proves to be.
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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Re: [PSES] One DoC per manufactured Unit?!

[John Cotman]

The Toy Safety Directive already has the picture requirement on the D of C.

John C

-Original Message-
From: ce-test, qualified testing bv - Gert Gremmen [mailto:g.grem...@cetest.nl] 
Sent: 14 January 2013 14:37
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] One DoC per manufactured Unit?!

You can make fun of it, but all these things have been introduced
with the goal of creating a better level playing field, thus making possible
to find, an pursue those manufacturers that spoil the market
by selling untested, possible unsafe cheap rubbish.

Customs are better able to simply stop products with false DoC, this way.

Imagine the poor customs guy, having to tell if these little green pieces of
plastic with copper screws on it really are the KML032-1234-s-XX as
the DoC states ?? 
If they are, they may withold the product and dupe the honest manufacturer,
if they assume it's ok, another batch of unsafe rubbish may dupe the consumer 
(in the end).


If you look at it like that, the costs for even (if it were required)
a serial number and a hologram and color image and a fully operating miniature
 model with each DoC are a bargain compared to the increased benefit 
that goes with increased sales.;<))  if you are not on the
side of the cheaters. 


And of course, it also brings the cheating to a higher level, so expect
even more stringent measures in the future... it's an everlasting battle
between the GOOD and the BAD

Regards,

Ing.  Gert Gremmen, BSc



g.grem...@cetest.nl
www.cetest.nl

Kiotoweg 363
3047 BG Rotterdam
T 31(0)104152426
F 31(0)104154953

 Before printing, think about the environment. 



-Oorspronkelijk bericht-
Van: emc-p...@ieee.org [mailto:emc-p...@ieee.org] Namens John Woodgate
Verzonden: Monday, January 14, 2013 3:00 PM
Aan: EMC-PSTC@LISTSERV.IEEE.ORG
Onderwerp: Re: One DoC per manufactured Unit?!

In message
<64D32EE8B9CBDD44963ACB076A5F6ABB0262C6D0@Mailbox-Tech.lecotech.local>,
dated Mon, 14 Jan 2013, "Kunde, Brian"  writes:

>As far as the color picture, well, that?s just stupid. Why not ask for 
>a hologram of the product?

A fully working full-size model would be even better. But for some suppliers, 
that would be too difficult.(;-)

>Our DOC is included in our manual and we are not going to add color for 
>a single picture.
>
>I?m not sure where we would put a picture anyway. Our DOC is a full 
>page now. It would most likely have to be very small or on a separate 
>page.

Does the manual have a picture of the product on the front cover already?
--
OOO - Own Opinions Only. See www.jmwa.demon.co.uk The longer it takes to make a 
point, the more obtuse it proves to be.
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

-

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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:
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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.

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For help, send m

Re: [PSES] One DoC per manufactured Unit?!

[ce-test, qualified testing bv - Gert Gremmen]

You can make fun of it, but all these things have been introduced
with the goal of creating a better level playing field, thus making possible
to find, an pursue those manufacturers that spoil the market
by selling untested, possible unsafe cheap rubbish.

Customs are better able to simply stop products with false DoC, this way.

Imagine the poor customs guy, having to tell if these little green pieces of
plastic with copper screws on it really are the KML032-1234-s-XX as
the DoC states ?? 
If they are, they may withold the product and dupe the honest manufacturer,
if they assume it's ok, another batch of unsafe rubbish may dupe the consumer 
(in the end).


If you look at it like that, the costs for even (if it were required)
a serial number and a hologram and color image and a fully operating miniature
 model with each DoC are a bargain compared to the increased benefit 
that goes with increased sales.;<))  if you are not on the
side of the cheaters. 


And of course, it also brings the cheating to a higher level, so expect
even more stringent measures in the future... it's an everlasting battle
between the GOOD and the BAD

Regards,

Ing.  Gert Gremmen, BSc



g.grem...@cetest.nl
www.cetest.nl

Kiotoweg 363
3047 BG Rotterdam
T 31(0)104152426
F 31(0)104154953

 Before printing, think about the environment. 



-Oorspronkelijk bericht-
Van: emc-p...@ieee.org [mailto:emc-p...@ieee.org] Namens John Woodgate
Verzonden: Monday, January 14, 2013 3:00 PM
Aan: EMC-PSTC@LISTSERV.IEEE.ORG
Onderwerp: Re: One DoC per manufactured Unit?!

In message
<64D32EE8B9CBDD44963ACB076A5F6ABB0262C6D0@Mailbox-Tech.lecotech.local>,
dated Mon, 14 Jan 2013, "Kunde, Brian"  writes:

>As far as the color picture, well, that?s just stupid. Why not ask for 
>a hologram of the product?

A fully working full-size model would be even better. But for some suppliers, 
that would be too difficult.(;-)

>Our DOC is included in our manual and we are not going to add color for 
>a single picture.
>
>I?m not sure where we would put a picture anyway. Our DOC is a full 
>page now. It would most likely have to be very small or on a separate 
>page.

Does the manual have a picture of the product on the front cover already?
--
OOO - Own Opinions Only. See www.jmwa.demon.co.uk The longer it takes to make a 
point, the more obtuse it proves to be.
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

-

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discussion list. To post a message to the list, send your e-mail to 


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Attachments are not permitted but the IEEE PSES Online Communities site at 
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formats), large files, etc.

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List rules: http://www.ieee-pses.org/listrules.html

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All emc-pstc postings are archived and searchable on the web at:
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http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used 
formats), large files, etc.

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Instructions:  http://listserv.ieee.org/request/user-guide.html
List rules: http://www.ieee-pses.org/listrules.html

For help, send mail to the list administrators:
Scott Douglas 
Mike Cantwell 

For policy questions, send mail to:
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David Heald: 

Re: [PSES] One DoC per manufactured Unit?!

[John Woodgate]

In message 
<64D32EE8B9CBDD44963ACB076A5F6ABB0262C6D0@Mailbox-Tech.lecotech.local>, 
dated Mon, 14 Jan 2013, "Kunde, Brian"  writes:


As far as the color picture, well, that?s just stupid. Why not ask for 
a hologram of the product?


A fully working full-size model would be even better. But for some 
suppliers, that would be too difficult.(;-)


Our DOC is included in our manual and we are not going to add color for 
a single picture.  


I?m not sure where we would put a picture anyway. Our DOC is a full 
page now. It would most likely have to be very small or on a separate 
page.


Does the manual have a picture of the product on the front cover 
already?

--
OOO - Own Opinions Only. See www.jmwa.demon.co.uk
The longer it takes to make a point, the more obtuse it proves to be.
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

-

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:
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Attachments are not permitted but the IEEE PSES Online Communities site at 
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Re: [PSES] One DoC per manufactured Unit?!

[Kunde, Brian]

I agree with John. We went through this when the new Machinery Directive came 
out a few years back. The directive itself only said, "description and 
identification of the machinery, including generic denomination, function, 
model, type, serial number and commercial name;", but the guide said, "As a 
general rule, the serial number of the machinery covered by the EC Declaration 
of Conformity shall be indicated". People all freaked out like they are doing 
now.  We even had customers call us and tell us our DOCs were invalid because 
it didn't have the serial number on it.

We contacted our NB about this and they said you only have to include the 
serial number if it is required to identify units that are CE compliant vs 
non-compliant units within the same model. If all of your products within the 
same model number are compliant then only the model number is needed and not 
the serial number.

I assume (and hope) the same logic will apply to the new LVD.

As far as the color picture, well, that's just stupid. Why not ask for a 
hologram of the product? Our DOC is included in our manual and we are not going 
to add color for a single picture.

I'm not sure where we would put a picture anyway. Our DOC is a full page now. 
It would most likely have to be very small or on a separate page.

Oh, and do they want the DOC printed in one of 26 different languages?

I love it when new directives come out. Gets the old blood boiling

The Other Brian

From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Tyra, John
Sent: Sunday, January 13, 2013 4:21 PM
To: Crane, Lauren; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: One DoC per manufactured Unit?!

I don't know Lauren, I read COM(2011) 773 final and NLF Council Decision 
768/2008 and I interpret it to mean you need a unique model number which can be 
cross referenced with the TCF reports for that model. I am not seeing where it 
requires each unit to have a unique ID# listed on the DoC which essentially 
means a unique DoC to be shipped with each product?

As long as the DoC has unique model numbers listed for the equipment you are 
declaring as compliant, and has the date of issue, the authorities can cross 
reference this for compliance by checking the products model number and DOM 
against the DoC which is required to be on the equipment being put onto the 
market in the EU. And of course your TCF reports must cross reference to the 
model number on the label.

Can you be more specific on which wording you are talking about?

What I found much more interesting was COM(2011) 773 final Annex IV seems to 
infer that you must ("shall") include a color photo of the equipment on the DoC

4. Object of the declaration (identification of electrical equipment allowing 
traceability.
It shall include a colour image of sufficient clarity to enable the 
identification of the
electric equipment).

COM(2011) 773 final Annex IV references Annex III of NLF Council Decision 
768/2008  which list the photo as optional

4. Object of the declaration (identification of product allowing traceability. 
It may include a photograph, where
appropriate):

While this is not as onerous as having to have a unique DoC for each product it 
will still mean a lot of work for companies to modify their current DoC's to 
add the photos as I have never seen a DoC which included product photos.


From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On 
Behalf Of Crane, Lauren
Sent: Wednesday, January 09, 2013 5:14 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: One DoC per manufactured Unit?!

As many know, the LVD is in the process of being recast for alignment with the 
New Legislative Framework (NLF).

The Commission proposed text, (COM(2011) 773 final),  calls for what looks like 
a unique equipment identification number do be provided in the Declaration of 
Conformity (DoC). The same sort of language is used in the NLF Council Decision 
768/2008, and RoHS2 criteria for the DoC.

This seems to imply there must be a DoC provided with a unit that contains that 
unit's unique identification number (e.g., serial number), and that a DoC that 
references an entire model line would not be acceptable.

Hints that this is the case can be seen in the Parliament's proposed amendments 
to the Commission's text of the LVD, where they cleverly change the unique unit 
number into a unique DoC number (much easier to deal with).


Amendment 48 - Zuzana Roithová
Annex IV - point 1
Text proposed by the Commission  --> 1. No xx (unique identification of the 
electric equipment):
Amendment Proposed --> 1. No xx (unique identification of the declaration):


Also, the previous Draft version of the RoHS2 FAQ had a question 9.9 which 
said, in effect "no, no, we meant a unique DoC number" has been entirely 
withdrawn in the current version of the FAQ.

Does anyone reading have any additional perspective on this battle? Will a 
"model line" DoC

Re: [PSES] One DoC per manufactured Unit?!

[Peter_Kelleher]

COM(2011)773 final is the proposal from the Commission to the Council and 
Parliament.
It does not represent a final draft of the directive.

This and proposals for other directives are currently under discussion between 
all three institutions of the EU and are subject to  further  modifications and 
amending proposals.

Regards

Peter.

From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Tyra, John
Sent: 13 January 2013 21:21
To: Crane, Lauren; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: One DoC per manufactured Unit?!

I don't know Lauren, I read COM(2011) 773 final and NLF Council Decision 
768/2008 and I interpret it to mean you need a unique model number which can be 
cross referenced with the TCF reports for that model. I am not seeing where it 
requires each unit to have a unique ID# listed on the DoC which essentially 
means a unique DoC to be shipped with each product?

As long as the DoC has unique model numbers listed for the equipment you are 
declaring as compliant, and has the date of issue, the authorities can cross 
reference this for compliance by checking the products model number and DOM 
against the DoC which is required to be on the equipment being put onto the 
market in the EU. And of course your TCF reports must cross reference to the 
model number on the label.

Can you be more specific on which wording you are talking about?

What I found much more interesting was COM(2011) 773 final Annex IV seems to 
infer that you must ("shall") include a color photo of the equipment on the DoC

4. Object of the declaration (identification of electrical equipment allowing 
traceability.
It shall include a colour image of sufficient clarity to enable the 
identification of the
electric equipment).

COM(2011) 773 final Annex IV references Annex III of NLF Council Decision 
768/2008  which list the photo as optional

4. Object of the declaration (identification of product allowing traceability. 
It may include a photograph, where
appropriate):

While this is not as onerous as having to have a unique DoC for each product it 
will still mean a lot of work for companies to modify their current DoC's to 
add the photos as I have never seen a DoC which included product photos.


From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Crane, Lauren
Sent: Wednesday, January 09, 2013 5:14 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: One DoC per manufactured Unit?!

As many know, the LVD is in the process of being recast for alignment with the 
New Legislative Framework (NLF).

The Commission proposed text, (COM(2011) 773 final),  calls for what looks like 
a unique equipment identification number do be provided in the Declaration of 
Conformity (DoC). The same sort of language is used in the NLF Council Decision 
768/2008, and RoHS2 criteria for the DoC.

This seems to imply there must be a DoC provided with a unit that contains that 
unit's unique identification number (e.g., serial number), and that a DoC that 
references an entire model line would not be acceptable.

Hints that this is the case can be seen in the Parliament's proposed amendments 
to the Commission's text of the LVD, where they cleverly change the unique unit 
number into a unique DoC number (much easier to deal with).


Amendment 48 - Zuzana Roithová
Annex IV - point 1
Text proposed by the Commission  --> 1. No xx (unique identification of the 
electric equipment):
Amendment Proposed --> 1. No xx (unique identification of the declaration):


Also, the previous Draft version of the RoHS2 FAQ had a question 9.9 which 
said, in effect "no, no, we meant a unique DoC number" has been entirely 
withdrawn in the current version of the FAQ.

Does anyone reading have any additional perspective on this battle? Will a 
"model line" DoC be possible in the future?


Regards,
Lauren Crane
KLA-Tencor

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Re: [PSES] One DoC per manufactured Unit?!

[ce-test, qualified testing bv - Gert Gremmen]

The new DoC concept for the LVD 

says in  COM2011-0773 (referring to 768/2008)

 



ANNEX IV [Annex III of Decision No 768/2008/EC] 

EU DECLARATION OF CONFORMITY 

1. No xx (unique identification of the electric equipment): 

2. Name and address of the manufacturer or his authorised representative: 

3. This EU declaration of conformity is issued under the sole responsibility of 
the 

manufacturer: 

4. Object of the declaration (identification of electrical equipment allowing 
traceability. 

It shall include a colour image of sufficient clarity to enable the 
identification of the 

electric equipment).

5. The object of the declaration described above is in conformity with the 
relevant 

Union harmonisation legislation.: 

6. References to the relevant harmonised standards used, or references to the 

specifications in relation to which conformity is declared: 

7. Additional information: 

Signed for and on behalf of:... 

(place and date of issue) 

(name, function)(signature)

768/2008 says:

 

ANNEX III

EC DECLARATION OF CONFORMITY

1. No...(unique identification of the product):

2. Name and address of the manufacturer or his authorised representative:

3. This declaration of conformity is issued under the sole responsibility of 
the manufacturer (or installer):

4. Object of the declaration (identification of product allowing traceability. 
It may include a photograph, where

appropriate):

5. The object of the declaration described above is in conformity with the 
relevant Community harmonisation

legislation: . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

6. References to the relevant harmonised standards used or references to the 
specifications in relation to which

conformity is declared:

7. Where applicable, the notified body ... (name, 
number)...performed...(description of intervention) ...and issued

the certificate: ...

8. Additional information:

Signed for and on behalf of:...

(place and date of issue):

(name, function) (signature):

 

 

Under point1 I read the type reference, where under point 4 an additional

requirement is formulated allowing to make it traceable.

I presume here that manufacture codes (manufacturing facility, possible other 
relevant details)

are meant. In case of OEM product this may include the manufacturer, or the 
batch numbers

that were referred to under chapter R2 point 5

 

 

 

 

It additionally requires a color image of the product where the original 768 
document only say "may ".

As the original stems from 2008 and this concept is from 2011 I am afraid the 
intention is to include the 

image...

 

15 april will learn more

 

 

Regards,

Ing.  Gert Gremmen, BSc

 

 

 

g.grem...@cetest.nl  

www.cetest.nl


Kiotoweg 363

3047 BG Rotterdam

T 31(0)104152426
F 31(0)104154953

 

 

 

Van: emc-p...@ieee.org [mailto:emc-p...@ieee.org] Namens Tyra, John
Verzonden: Sunday, January 13, 2013 10:21 PM
Aan: Crane, Lauren; EMC-PSTC@LISTSERV.IEEE.ORG
Onderwerp: RE: One DoC per manufactured Unit?!

 

I don't know Lauren, I read COM(2011) 773 final and NLF Council Decision 
768/2008 and I interpret it to mean you need a unique model number which can be 
cross referenced with the TCF reports for that model. I am not seeing where it 
requires each unit to have a unique ID# listed on the DoC which essentially 
means a unique DoC to be shipped with each product? 

 

As long as the DoC has unique model numbers listed for the equipment you are 
declaring as compliant, and has the date of issue, the authorities can cross 
reference this for compliance by checking the products model number and DOM 
against the DoC which is required to be on the equipment being put onto the 
market in the EU. And of course your TCF reports must cross reference to the 
model number on the label.

 

Can you be more specific on which wording you are talking about?

 

What I found much more interesting was COM(2011) 773 final Annex IV seems to 
infer that you must ("shall") include a color photo of the equipment on the DoC

 

4. Object of the declaration (identification of electrical equipment allowing 
traceability.

It shall include a colour image of sufficient clarity to enable the 
identification of the

electric equipment).

 

COM(2011) 773 final Annex IV references Annex III of NLF Council Decision 
768/2008  which list the photo as optional

 

4. Object of the declaration (identification of product allowing traceability. 
It may include a photograph, where

appropriate):

 

While this is not as onerous as having to have a unique DoC for each product it 
will still mean a lot of work for companies to modify their current DoC's to 
add the photos as I have never seen a DoC which i