Re: [PSES] D of C and product safety warnings and caution markings

[John Woodgate]

In message 
, 
dated Thu, 28 May 2015, Scott Aldous  writes:



Indeed it is. Here is the text from the RED


Effectively, it makes mandatory the advice EMC consultants have been 
giving their clients for many years. But it seems heavy-handed to do 
that.

--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk
When I turn my back on the sun, it's to look for a rainbow
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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Re: [PSES] D of C and product safety warnings and caution markings

[John Woodgate]

In message 
, dated 
Thu, 28 May 2015, Gary McInturff  writes:


We put a copy in the user manual, a web address, and an address from 
which you can get an actual signed DoC, rather than a copy of the 
signed DoC that you would download off the website. Additionally along 
with the shipping documents we include a copy of the DoC, along with 
printing the CE logo on the outside of the master shipping box but no 
separate DoC sheet with each product within the master box.


That's right. You include a DoC with the shipping documents because the 
DoC is addressed to the regulatory authorities, NOT to the end-user. 
Under the new EMC Directive, it's effectively also addressed to anyone 
who handles the product during distribution, because they are supposed 
to verify that it exists and appears correct.


--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk
When I turn my back on the sun, it's to look for a rainbow
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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Re: [PSES] D of C and product safety warnings and caution markings

[Gary McInturff]

We put a copy in the user manual, a web address, and an address from which you 
can get an actual signed DoC, rather than a copy of the signed DoC that you 
would download off the website. Additionally along with the shipping documents 
we include a copy of the DoC, along with printing the CE logo on the outside of 
the master shipping box but no separate DoC sheet with each product within the 
master box.

The last two lessons were hard learned, because we didn't mark the master box 
with CE, nor have anything with our shipping or import papers France stopped 
about 3/4 of million dollar shipment. This was about 20 years ago, and took 
about week to get resolved by sending the appropriate documentation. The 
customer was a little cranky because of the delay but no "hitches-in-the 
get-along" after that with importation to the EU and to France in particular.  

Haven't seen you since Santa Clara Ron. Hope all is well, going to play some 
golf in you old neighborhood this weekend.

mac

-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk] 
Sent: Thursday, May 28, 2015 2:05 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] D of C and product safety warnings and caution markings

In message
<0d0d5aa1cae3104f96217cad19023ec8fbf35...@vf2wdexmb2.verifone.com>,
dated Thu, 28 May 2015, Ron Baugh  writes:

>Also, if the D of C is NOT physically in the shipping box, how does the 
>country customs inspector know if we meet the required EU LVD 
>requirements?

That is why you are advised to put it in the box, and for me that advice still 
stands. BUT this is completely optional, in fact such DoC copies really have no 
legal significance. The only valid DoC is the signed original, which is what 
you have to produce in a reasonable time to the regulatory authority ON REQUEST.
--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk When I turn 
my back on the sun, it's to look for a rainbow John Woodgate, J M Woodgate and 
Associates, Rayleigh, Essex UK

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Re: [PSES] D of C and product safety warnings and caution markings

[Scott Aldous]

On Thu, May 28, 2015 at 2:37 PM, John Woodgate  wrote:

> In message <
> camjgkmyz2lsiuypaqmgod9lfbl86yy1sxw3uaxbtonqgq_6...@mail.gmail.com>,
> dated Thu, 28 May 2015, Scott Aldous <
> 0220f70c299a-dmarc-requ...@ieee.org> writes:
>
>  There is guidance in the R&TTE Directive (see Article 6, 3rd indent) as
>> well as the Guide to the R&TTE Directive (see section 7.2). The Directive
>> requires a DoC to be provided to the user.
>>
>
> Is this carried over into the RED? Since copy DoCs have no legal validity,
> it seems strange that a Directive should may their supply mandatory.


Indeed it is. Here is the text from the RED:

"9. Manufacturers shall ensure that each item of radio equipment is
accompanied by a copy of the EU declaration of conformity or by a
simplified EU declaration of conformity. Where a simplified EU declaration
of conformity is provided, it shall contain the exact internet address
where the full text of the EU declaration of conformity can be obtained."

Also from the RED, here is the explanation given for why they did that:

"(31) The requirement laid down in Directive 1999/5/EC to include an EU
declaration of conformity with equipment has been found to simplify and to
enhance the information and the efficiency of market surveillance. The
possibility to provide a simplified EU declaration of conformity has
allowed the burden associated with this requirement to be reduced without
reduction of its effectiveness, and should therefore be provided for within
this Directive. Furthermore, in order to ensure easy and efficient access
to an EU declaration of conformity, including a simplified EU declaration
of conformity, it should be possible to affix it to the packaging of the
radio equipment concerned."

-- 
Scott Aldous
Compliance Engineer
Google
650-253-1994
scottald...@google.com

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Re: [PSES] D of C and product safety warnings and caution markings

[Crane, Lauren]

Be sure to take a look at the new version of the LVD directive 2014/35/EU 
effective April 2016.

There is significant new content about such administrative issues ("formal 
non-compliance").

Regards,
Lauren Crane
KLA-Tencor

From: Ron Baugh [mailto:ron...@verifone.com]
Sent: Thursday, May 28, 2015 3:43 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] D of C and product safety warnings and caution markings

I have a question that has been presented to me for several years now and I 
need this groups help.

When we ship our products to the end user and our products meets all of the LVD 
requirements (per IEC/EN 60950), we place a physical copy of our D of C with 
EACH terminal.

I have been ask if we could put our D of C on our company web site and make 
reference,  physically  on the shipping box to the web address where our D of C 
would be posted.

The issue I need help with is this. does the D of C have to be shipped 
physically with EACH product in the shipping box OR can the shipping box have a 
web address printed on it to direct the end user to our D of C?

Also, if the D of C is NOT physically in the shipping box, how does the country 
customs inspector know if we meet the required EU LVD requirements?

Thanks

Ron Baugh

This electronic message, including attachments, is intended only for the use of 
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Re: [PSES] D of C and product safety warnings and caution markings

[John Woodgate]

In message 
, 
dated Thu, 28 May 2015, Scott Aldous 
<0220f70c299a-dmarc-requ...@ieee.org> writes:


There is guidance in the R&TTE Directive (see Article 6, 3rd indent) as 
well as the Guide to the R&TTE Directive (see section 7.2). The 
Directive requires a DoC to be provided to the user.


Is this carried over into the RED? Since copy DoCs have no legal 
validity, it seems strange that a Directive should may their supply 
mandatory.

--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk
When I turn my back on the sun, it's to look for a rainbow
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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Re: [PSES] D of C and product safety warnings and caution markings

[Nick Williams]

Neither the LVD nor the EMC Directive require the Declaration to accompany the 
product so all you are legally obliged to do is to make it available to the 
authorities on request. Making it available via a web site is (in my view) a 
good idea. 

Some of the directives (e.g. Machinery, ATEX, R+TTE) require the declaration to 
accompany the product when it is shipped to the end user and so for products 
within the scope of these directives, paper copy is a mandatory requirement. 

The answer to your final question is that, strictly, if product carries the CE 
logo, the authorities are required to assume that it complies with the 
directive unless they can prove otherwise. In practice, of course, they have 
powers to demand information which in effect places the burden of proof on the 
manufacturer. If you think there is a possibility that customs will holsd up 
the shipment the supplying a Declaration witht he product seems like a simple 
measure to minimise the likelihood of this happening. 

Nick. 



> On 28 May 2015, at 21:43, Ron Baugh  wrote:
> 
> I have a question that has been presented to me for several years now and I 
> need this groups help.
>  
> When we ship our products to the end user and our products meets all of the 
> LVD requirements (per IEC/EN 60950), we place a physical copy of our D of C 
> with EACH terminal. 
>  
> I have been ask if we could put our D of C on our company web site and make 
> reference,  physically  on the shipping box to the web address where our D of 
> C would be posted. 
>  
> The issue I need help with is this….. does the D of C have to be shipped 
> physically with EACH product in the shipping box OR can the shipping box have 
> a web address printed on it to direct the end user to our D of C?
>  
> Also, if the D of C is NOT physically in the shipping box, how does the 
> country customs inspector know if we meet the required EU LVD requirements?
>  
> Thanks
>  
> Ron Baugh


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Re: [PSES] D of C and product safety warnings and caution markings

[Scott Aldous]

Hi Ron,

Your devices don't fall under the R&TTE Directive?

There is guidance in the R&TTE Directive
 (see
Article 6, 3rd indent) as well as the Guide to the R&TTE Directive
 (see
section 7.2). The Directive requires a DoC to be provided to the user. The
guide indicates that this can be satisfied by including a short statement
of compliance in the user info, together with an address or e-mail site
where the full DoC can be obtained.

On Thu, May 28, 2015 at 1:43 PM, Ron Baugh  wrote:

>  I have a question that has been presented to me for several years now
> and I need this groups help.
>
>
>
> When we ship our products to the end user and our products meets all of
> the LVD requirements (per IEC/EN 60950), we place a physical copy of our D
> of C with EACH terminal.
>
>
>
> I have been ask if we could put our D of C on our company web site and
> make reference,  physically  on the shipping box to the web address where
> our D of C would be posted.
>
>
>
> The issue I need help with is this….. does the D of C have to be shipped
> physically with EACH product in the shipping box OR can the shipping box
> have a web address printed on it to direct the end user to our D of C?
>
>
>
> Also, if the D of C is NOT physically in the shipping box, how does the
> country customs inspector know if we meet the required EU LVD requirements?
>
>
>
> Thanks
>
>
>
> Ron Baugh
>  --
> This electronic message, including attachments, is intended only for the
> use of the individual or company named above or to which it is addressed.
> The information contained in this message shall be considered confidential
> and proprietary, and may include confidential work product. If you are not
> the intended recipient, please be aware that any unauthorized use,
> dissemination, distribution or copying of this message is strictly
> prohibited. If you have received this email in error, please notify the
> sender by replying to this message and deleting this email immediately.
> -
> 
>
> 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:
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>
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>
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> David Heald 
>



-- 
Scott Aldous
Compliance Engineer
Google
650-253-1994
scottald...@google.com

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Re: [PSES] D of C and product safety warnings and caution markings

[John Woodgate]

In message 
<0d0d5aa1cae3104f96217cad19023ec8fbf35...@vf2wdexmb2.verifone.com>, 
dated Thu, 28 May 2015, Ron Baugh  writes:


Also, if the D of C is NOT physically in the shipping box, how does the 
country customs inspector know if we meet the required EU LVD 
requirements?


That is why you are advised to put it in the box, and for me that advice 
still stands. BUT this is completely optional, in fact such DoC copies 
really have no legal significance. The only valid DoC is the signed 
original, which is what you have to produce in a reasonable time to the 
regulatory authority ON REQUEST.

--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk
When I turn my back on the sun, it's to look for a rainbow
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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[PSES] D of C and product safety warnings and caution markings

[Ron Baugh]

I have a question that has been presented to me for several years now and I 
need this groups help.

When we ship our products to the end user and our products meets all of the LVD 
requirements (per IEC/EN 60950), we place a physical copy of our D of C with 
EACH terminal.

I have been ask if we could put our D of C on our company web site and make 
reference,  physically  on the shipping box to the web address where our D of C 
would be posted.

The issue I need help with is this. does the D of C have to be shipped 
physically with EACH product in the shipping box OR can the shipping box have a 
web address printed on it to direct the end user to our D of C?

Also, if the D of C is NOT physically in the shipping box, how does the country 
customs inspector know if we meet the required EU LVD requirements?

Thanks

Ron Baugh

This electronic message, including attachments, is intended only for the use of 
the individual or company named above or to which it is addressed. The 
information contained in this message shall be considered confidential and 
proprietary, and may include confidential work product. If you are not the 
intended recipient, please be aware that any unauthorized use, dissemination, 
distribution or copying of this message is strictly prohibited. If you have 
received this email in error, please notify the sender by replying to this 
message and deleting this email immediately.

-

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Re: [PSES] Radio in class A product

[John Woodgate]

In message , 
dated Thu, 28 May 2015, Alexandru Guidea  
writes:


The EUT can be tested for emissions using the ?relevant product 
standard? or ?the most appropriate harmonized standard? according to 
301 489-1 V1.9.2, Req. 8.2 and ETSI EN 300 328 V1.8.1 (2012-06) Req. 
5.1.5.2.2.3.


If the product meets the requirements of the clauses identified above, 
the EUT can be tested for EMC to ITE standards, Class A limits.  


 

The EUT (combined ITE and wifi) still needs to be tested for 301 328 
V1.8.1, even  if  the wifi component is certified to ETSI 300 328.


That seems to settle the issue. but it's a pity it needs so much 
searching.

--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk
When I turn my back on the sun, it's to look for a rainbow
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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Re: [PSES] Radio in class A product

[Alexandru Guidea]

Came across this issue a few months ago, and here is the outcome of searching 
within applicable ETSI standards.

The EUT can be tested for emissions using the "relevant product standard" or 
"the most appropriate harmonized standard" according to 301 489-1 V1.9.2, Req. 
8.2 and ETSI EN 300 328 V1.8.1 (2012-06) Req. 5.1.5.2.2.3.
If the product meets the requirements of the clauses identified above, the EUT 
can be tested for EMC to ITE standards, Class A limits.

The EUT (combined ITE and wifi) still needs to be tested for 301 328 V1.8.1, 
even  if  the wifi component is certified to ETSI 300 328.
Obviously, a Notified Body for the RTTE directive can be consulted for an 
unequivocal certification plan.



Alexandru Guidea
CAE Inc.

From: Paasche, Dieter [mailto:dieter.paas...@christiedigital.com]
Sent: 27 May 2015 16:29
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Radio in class A product

Dear members,

I am adding a radio (WiFi module)  to an ITE class A product. The product is 
tested under CISPR 22/24. I was told now that, because of the radio, the 
standard to apply is EN 301489-1, and therefore my product has to meet the 
class B of EN 55022 for emissions.

My opinion is that product and radio have to be tested separately and test the 
product to EN 55022/24 (without radio, or with the 2.4 GHz transmission 
frequency filtered), and the radio or radio module by itself under EN 31489-1. 
Is that correct? Where can I find the right interpretation?



Sincerely,

Dieter Paasche
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Re: [PSES] Radio in class A product

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

EN 301 489-x series is Definitely NOT for radio. It's listed under the
EMC directive, and the test suite is typically as in IT equipment

(but no class A) with added tests for automotive sets.

 

The different approaches of mixed function equipment under the RTTE
directive is defined

by the way the products can operate independently of each other.

So the separate testing approach is good for a USB plugin WiFi module,
but not for a soldered

WiFi module, as part of its wireless properties is defined by the
ancillary equipment. (it programs and controls the module and output
power for example)

 

In the soldered case the whole of the setup with the transmitter
switched off will be tested for EN 301489-x  (x depends of technology)

and the module to its appropriate radio standard such as EN 300328 EN
300440 or EN 300220 and others.

 

Gert

 

 

From: Paasche, Dieter [mailto:dieter.paas...@christiedigital.com] 
Sent: Wednesday, May 27, 2015 9:30 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Radio in class A product

 

In my interpretation, the main product is not an ancillary equipment
from EN 301 489-1 point of view. The main function has nothing to do
with radio. The product uses data from the internet and process it into
any display. The Wifi, is now an add on so you can also get the
information wireless. Hence I think that EN 301 489 would not apply, or
maybe just for the radio module. 

 

Reading through EN 300328 and under section 5.1.5 ( or better say
5.1.5.2.2.3) it looks to me that I can have host equipment and radio
tested separately, and therefore have a class A for the host equipment
and  class B for the radio.  Even if the radio is part of the host
equipment, it looks to me that I can test the host equipment with the
radio in standby mode or receiving mode. 

 

Any comments? 

 

Sincerely, 

 

Dieter Paasche

Advanced Product Developer, Electrical

CHRISTIE

809 Wellington Street North

Kitchener, Ontario  N2G 4Y7

Phone: +1 519-744-8005 Ext 7211

www.christiedigital.com  

 

This e-mail message (including attachments, if any), is confidential.
Any unauthorized use, distribution or disclosure is prohibited.  If you
have received this e-mail message in error, please notify the sender by
reply e-mail or telephone and delete it and any attachments from your
computer system and records.

 

From: Michael Derby [mailto:micha...@acbcert.com] 
Sent: Wednesday, May 27, 2015 2:06 PM
To: Paasche, Dieter; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] Radio in class A product

 

Hello Dieter,

 

In addition to the responses you already received (which I like), I
would ask you to check that your host ITE product is really 'ancillary
equipment', as defined in EN 301 489-1.

 

I think that as others have pointed out, your host product will most
likely continue to need to meet EN 55022 Class A, whilst you should
check that the emissions from your WiFi operation meets the emissions
limits of EN 300 328 (and/or EN 301 893).

 

 

Thanks,   Michael.

 

 

 

From: Paasche, Dieter [mailto:dieter.paas...@christiedigital.com] 
Sent: 27 May 2015 16:29
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Radio in class A product

 

Dear members, 

 

I am adding a radio (WiFi module)  to an ITE class A product. The
product is tested under CISPR 22/24. I was told now that, because of the
radio, the standard to apply is EN 301489-1, and therefore my product
has to meet the class B of EN 55022 for emissions. 

 

My opinion is that product and radio have to be tested separately and
test the product to EN 55022/24 (without radio, or with the 2.4 GHz
transmission frequency filtered), and the radio or radio module by
itself under EN 31489-1. Is that correct? Where can I find the right
interpretation? 

 

 

 

Sincerely, 

 

Dieter Paasche

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