Re: [PSES] Challenge a Notified Body decision

2024-09-13 Thread Charlie Blackham
Amund

There are methods under the Directive for The Commission to have the status of 
a Notified Body revoked, but there's not a higher authority to go to on 
technical matters and I would suggest it is better to confirm your approach is 
technically correct.

You don't mention the standard, or the mask, but the methods in ETSI standards 
are typically clear.

Since you're using a NB, you're not obliged to use a published standard and may 
wish to refer to ERC Recommendation 74-01

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
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From: Amund Westin 
Sent: 13 September 2024 14:26
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Challenge a Notified Body decision

Is it possible to challenge a EU Notified Body decision ? Bringing the case to 
a superior body that can decide as a independent third party?

There is disagreement about how to design a spectrum mask, in connection with 
radio spur testing according to a non-harmonized standard. The test itself is 
either passed or failed, depending on how the mask is designed.


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Re: [PSES] CE marking for avionic in-flight entertainment equipment

2024-09-11 Thread Charlie Blackham
David

Given that you can only CE Mark a product when it is in the scope of, and 
compliant with, one or more Directives that require/allow for CE Marking, you 
need to explain to your customers why your products are out of scope - I would 
recommend citing the applicable Articles and Annexes in the Directives that 
would otherwise be applicable.

There may well be other requirements that you need to comply with that are 
outside the scope of these Directives.

If you sell these items for use other than on aircraft, they would of course 
need to be CE marked

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
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From: David Gelfand 
Sent: 11 September 2024 16:40
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] CE marking for avionic in-flight entertainment equipment

Hello to all,

What CE directives and which standards would apply to electronic equipment to 
be installed in an aircraft?  LVD, EMCD and RED do not seem to apply.

We design and manufacture servers with satellite and LTE modems, for in-flight 
wifi access and entertainment.  Some of our clients are asking for CE marking.  
Any guidance would be most appreciated.

Thanks,

David

David Gelfand, Ing. P.Eng.
Spécialiste en conformité / Conformity Specialist

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Re: [PSES] : IEC 61000-2-4 scope

2024-09-07 Thread Charlie Blackham
This standard has nothing to do with generating AC power from an isolated 
source on a vehicle as that is not an “Industrial Location”

Some more information in the preview, 
webstore.iec.ch/en/iec_catalog/product/preview/?id=L3B1Yi9wZGYvcHJldmlldy9pbmZvX2llYzYxMDAwLTItNHtlZDMuMC5STFZ9ZW4ucGRm<https://webstore.iec.ch/en/iec_catalog/product/preview/?id=L3B1Yi9wZGYvcHJldmlldy9pbmZvX2llYzYxMDAwLTItNHtlZDMuMC5STFZ9ZW4ucGRm>
And in this article 
https://comsys.se/our-adf-technology/power-quality-iec-61000/

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
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From: Ken Javor 
Sent: 06 September 2024 22:47
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] : IEC 61000-2-4 scope

Don’t have the standard but excerpted the following off a site describing the 
standard.  Pertinent portion underlined.


IEC 61000-2-4:2024
Electromagnetic compatibility (EMC) - Part 2-4: Environment - Compatibility 
levels in power distribution systems in industrial locations for low-frequency 
conducted disturbances

Standard Details
IEC 61000-2-4:2024 is available as IEC 61000-2-4:2024 RLV which contains the 
International Standard and its Redline version, showing all changes of the 
technical content compared to the previous edition.

IEC 61000-2-4:2024 is related to conducted disturbances in the frequency range 
from 0 kHz to 150 kHz. It gives compatibility levels in differential mode (L-L 
and L-N) for industrial locations, with a nominal voltage up to 35 kV and a 
nominal frequency of 50 Hz or 60 Hz.
NOTE 1 Industrial locations are defined in 3.1.8.
Power distribution systems on ships, aircraft, offshore platforms and railways 
are not included.


--

Ken Javor
Ph: (256) 650-5261


From: Ralph McDiarmid mailto:rmm.priv...@gmail.com>>
Reply-To: mailto:rmm.priv...@gmail.com>>
Date: Friday, September 6, 2024 at 1:15 PM
To: mailto:EMC-PSTC@LISTSERV.IEEE.ORG>>
Subject: Re: [PSES] : IEC 61000-2-4 scope

My turn to ask a question to the group of experts.

Reference:
IEC 61000-2-4:2024
Electromagnetic compatibility (EMC) - Part 2-4: Environment - Compatibility 
levels in power distribution systems in industrial locations for low-frequency 
conducted disturbances

My client would like to know if standard IEC 61000-2-4 is applicable to an 
inverter that is intended for permanent installation in a motor vehicle.  The 
inverter has no connection to a.c. mains and does not have an a.c. input power 
port.  It’s merely a 24Vdc to 230Vac/50Hz inverter.

I think this IEC standard is clearly out of scope for this class of equipment, 
but if client’s customer insists (a big automotive manufacturer) I’d like to be 
able craft a technical justification to waive application of the standard.

The standard appears only to address conducted disturbances which may be 
present on non-public (industrial) a.c. power networks and the EMC immunity of 
equipment connected to those networks.

Thank you,


Ralph



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Re: [PSES] Machinery Regulation - safety components

2024-08-10 Thread Charlie Blackham
Peter

As you note, the term "independently placed on the market" is in the Machinery 
Directive, so appears unchanged in concept in the MR
At the moment I think Machinery Guide §42 Safety components is still the most 
useful guidance, along

At the beginning of July, The EU Commission has issued Draft standardisation 
request to CENELEC and CEN support of Regulation (EU) 2023/1230
- 5 new standards
- updates to a number of other standards
- To be completed within 18 months !!

https://ec.europa.eu/docsroom/documents/60695?locale=en


Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
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Web: https://sulisconsultants.com/
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From: Peter Tarver 
Sent: Saturday, August 10, 2024 12:06 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Machinery Regulation - safety components

In reviewing the Machinery Regulation, Article 3 defines a safety component as

"...means a physical or digital component, including software, of a product 
within the scope of this Regulation, which is designed or intended to fulfil 
(sic) a safety function and which is independently placed on the market, the 
failure or malfunction of which endanger the safety of persons, but which is 
not necessary in order for that product to function or for which normal 
components may be substituted in order for that product to function;
(emphasis added.)
The component falls under Annex I, Part, B but is only sold to OEMs
1) whose equipment would clearly fall under the Regulation, and
2) who integrate the component into other equipment before that other equipment 
is placed on the market, but
3) is not "independently placed on the market," for general sale,
is there any reason to conclude that the Regulation does not apply to the 
component?
The product is sold into the EU for applications other than those that would be 
subject to the Regulation, so it seems that applicability could depend on the 
interpretation of "independently" in the context of the regulation. Or is the  
use of "independently" intended to mean "not manufactured by the OEM for their 
own use?"
I note that similar language existed in the Machinery Directive.
My approach is to apply an abundance of caution and presume the Regulation 
applies, but I'd appreciate the input of the group.
A final couple of questions: should it be assumed that the same standards 
published in the EU OJ for the Machinery Directive will satisfy the Regulation 
until a separate list of standards is published and linked to the Regulation? 
Also, is there a view on when such a list will be published?
Regards,
Peter Tarver


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Re: [PSES] "Significant Thickness"

2024-07-01 Thread Charlie Blackham
James

My understanding off this phrase is "The material flammability class is checked 
at the thinnest part of the material that is relied upon as a Fire Enclosure"

62368-1 allows different methods of compliance with clause 6.4 within the same 
product - for example, parts of the product that are PS1 or PS2 don't need a 
Fire Enclosure but might share an outer enclosure with parts that are PS3 and 
require a Fire Enclosure for that portion of the product.

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
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From: James Pawson (U3C) 
Sent: Monday, July 1, 2024 10:02 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] "Significant Thickness"

Hello again,

IEC 62368-1
6.4.8 Fire Enclosures
6.4.8.2.3 Compliance criteria
Compliance is checked by inspection of applicable data sheets or test.
The material flammability class is checked for the thinnest significant 
thickness used.

There's not a definition of "significant thickness" in the standard. Given that 
openings in a fire enclosure have controlled maximum dimensions I'm going to 
read "significant thickness" as "thickness of an area of material that is 
larger than the maximum permitted opening in that face of the fire enclosure"

Thoughts welcomed!

All the best
James

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Re: [PSES] EU DoC

2024-06-10 Thread Charlie Blackham
Amund

Generally yes - specific requirements contained in an Annex of the relevant 
Directive(s), for example  RED Annex VI

7. Where applicable, the notified body ... (name, number) ... performed ... 
(description of intervention) ... and issued the EU-type examination 
certificate: ...(certificate number)

Best regards
Charlie

Charlie Blackham
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From: Amund Westin 
Sent: Monday, June 10, 2024 5:53 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] EU DoC

If you have to consult an EU Notified Body for CE marking a product, must the 
EU DoC include information that Notified Body?

 Best regards
Amund


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Re: [PSES] Declaration of Conformity

2024-06-01 Thread Charlie Blackham
Scott

The Ecodesign Directive applies to products within scope of a Commission 
Regulation implementing Directive 2009/125/EC

These products must then be labelled in accordance with the relevant Commission 
Delegated Regulation on how to energy label that product.

You don’t declare compliance with a labelling method, you just label in 
accordance with it.

Lists of relevant Regulations at
https://energy.ec.europa.eu/topics/energy-efficiency/energy-label-and-ecodesign/list-energy-efficient-products-regulations-product-group_en

Best regards
Charlie

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From: Scott Xe 
Sent: Saturday, June 1, 2024 2:33 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Declaration of Conformity

Hello Experts,

According to the Ecodesign Directive (EU) 2009/125, manufacturers must draw up 
a declaration of conformity for covered products. However, the Energy Labelling 
Regulation (EU) 2017/1369 does not explicitly mention this requirement.

Is a declaration of conformity also mandatory for products covered under the 
Energy Labelling Regulation (EU) 2017/1369 as part of the compliance process?

Cheers,

Scott


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Re: [PSES] DoC - reference to ROHS directive

2024-04-21 Thread Charlie Blackham
I wouldn’t say that it was “wrong” to add the amendment, though I don’t 
recommend adding it, but since the amendment applies whether you like it or 
not, you don’t need to declare that you have applied it as it’s inherent in a 
declaration to 2011/65/EU.

The same goes for any exemptions you may have applied, or indeed have 
previously applied but have now expired.

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: MIKE SHERMAN 
Sent: Monday, April 22, 2024 2:43 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] DoC - reference to ROHS directive

What I've seen is language like
"2011/65/EU RoHS directive with amendment 2015/863/EU"
or
"2011/65/EU RoHS directive as amended by 2015/863/EU"

The 2015 amendment adds four substances to the original six, so you should 
mention both it and the 2011 directive.

Mike Sherman
Sherman PSC LLC
On 04/21/2024 12:52 PM CDT Amund Westin 
mailto:am...@westin-emission.no>> wrote:


I have the last 10+ years made reference to ROHS directive 2011/65/EU in the 
DoC.
Now, I have been told to switch to 2015/863/EU? Is that correct?

From what I see on the EU web site, 2015/863 is a Commission Delegated 
Directive, amending Annex II to Directive 2011/65/EU
As I understand, 2011/65/EU is still in charge, and is the directive to be 
listed in the DoC.

Comments?

BR Amund




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Re: [PSES] DoC - reference to ROHS directive

2024-04-21 Thread Charlie Blackham
Agreed, if you look at 
https://environment.ec.europa.eu/topics/waste-and-recycling/rohs-directive_en 
you see there have been many Commission Delegated Directives of which 2015/863 
is just one.
And also, 
https://single-market-economy.ec.europa.eu/single-market/european-standards/harmonised-standards/restriction-use-certain-hazardous-substances-rohs_en
 cites only 2011/65/EU as the Directive for RoHS


Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: Tom Smith 
Sent: Sunday, April 21, 2024 7:39 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] DoC - reference to ROHS directive

The proper directive reference remains 2011/65/EU. If you look at the current 
version of that directive, it incorporates all of the modification, so there is 
no need to separately reference the amending documents.
Regards
Tom Smith, P.Eng
Principal Engineer
TJS Technical Services Inc.
Tel: +1 403-612-6664
Email: tsm...@tjstechnical.com<mailto:tsm...@tjstechnical.com>
http://tjstechnical.com<http://tjstechnical.com/>
Compliance News Updates: https://corp.social/@TJS_Technical

From: Amund Westin mailto:am...@westin-emission.no>>
Sent: Sunday, April 21, 2024 11:52 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: [PSES] DoC - reference to ROHS directive

I have the last 10+ years made reference to ROHS directive 2011/65/EU in the 
DoC.
Now, I have been told to switch to 2015/863/EU? Is that correct?

>From what I see on the EU web site, 2015/863 is a Commission Delegated 
>Directive, amending Annex II to Directive 2011/65/EU
As I understand, 2011/65/EU is still in charge, and is the directive to be 
listed in the DoC.

Comments?

BR Amund




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[PSES] UK The Product Safety and Metrology etc. (Amendment) Regulations 2024

2024-04-19 Thread Charlie Blackham
UK has published draft legislation to allow continued acceptance of CE Marking 
past the end of 2024 in the "The Product Safety and Metrology etc. (Amendment) 
Regulations 2024" along with an explanatory memorandum.
The law is due to come into force on 1st October ahead of the current 31 
December deadline.

The Product Safety and Metrology etc. (Amendment) Regulations 2024 
(legislation.gov.uk)<https://www.legislation.gov.uk/ukdsi/2024/9780348260311/resources>

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Mead House
Longwater Road
Eversley
RG27 0NW
UK
Tel: +44 (0)7946 624317
Email: char...@sulisconsultants.com<mailto:char...@sulisconsultants.com>
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247


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[PSES] UK

2024-04-19 Thread Charlie Blackham


Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Mead House
Longwater Road
Eversley
RG27 0NW
UK
Tel: +44 (0)7946 624317
Email: char...@sulisconsultants.com<mailto:char...@sulisconsultants.com>
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247


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Re: [PSES] OJEC list of harmonised standards

2024-04-17 Thread Charlie Blackham
Ralph

If you want to search EUR-Lex for other publications against a Directive, or 
earlier HS listings then a search such as 
https://eur-lex.europa.eu/search.html?lang=en&text=2014%2F53%2FEU&qid=1504346404330&type=quick&scope=EURLEX&sortOne=DD&sortOneOrder=desc
 could work for you (just replace "2014/53/EU" with the required Directive

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: bart.de.gee...@telenet.be 
Sent: Wednesday, April 17, 2024 6:06 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] OJEC list of harmonised standards

Hi Ralph,

Is this what you are looking for?

https://single-market-economy.ec.europa.eu/single-market/european-standards/harmonised-standards_en

Greetings,
Bart

From: Ralph McDiarmid mailto:rmm.priv...@gmail.com>>
Sent: woensdag 17 april 2024 19:04
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: Re: [PSES] OJEC list of harmonised standards

Can someone provide a link to this list.  I have searched eur-lex.europa.eu 
website without success.

Ralph



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Re: [PSES] IEC 61000-6-5 vs. IEC 61000-6-2

2024-04-17 Thread Charlie Blackham
Amund

There are a number of differences including:

  *   Zoning of different areas which then require different levels of tests 
against 61000-4-4; 61000-4-16 and 61000-4-18
  *   61000-4-8 Mag Field is 100 A/m continuous and 1000 A/m for 1 s (but only 
for equipment containing magnetically sensitive components)


You can read more for a few Euro at https://www.evs.ee/en/evs-en-61000-6-5-2015

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: Amund Westin 
Sent: Wednesday, April 17, 2024 5:34 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] IEC 61000-6-5 vs. IEC 61000-6-2


IEC EN 61000-6-2, Electromagnetic compatibility (EMC) - Part 6-2: Generic 
standards - Immunity for industrial environments

IEC EN 61000-6-5, Electromagnetic compatibility (EMC) - Part 6-5: Generic 
standards - Immunity for equipment used in power station and substation 
environment





I'm quite familiar with IEC EN 61000-6-2 but have never tested or looked into 
IEC EN 61000-6-5.

If anyone who have knowledge about both standards and could shorty tell the 
main differences between these two?





Best regards

Amund







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Re: [PSES] German Required on Product Label to Match China and Nordic for (GS) ?

2024-04-10 Thread Charlie Blackham
Rick

I’m not expert on GS certification but Low Voltage Directive Article 6 required 
safety instructions to be in a suitable language

7. Manufacturers shall ensure that the electrical equipment is accompanied by 
instructions and safety information in a language which can be easily 
understood by consumers and other end-users, as determined by the Member State 
concerned. Such instructions and safety information, as well as any labelling, 
shall be clear, understandable and intelligible.

There’s a similar requirement in RED article 10 and I’m not sure whether this 
document has been published for other Directives, but ADCO RED have published 
“National language requirements of the national implementation of the Radio 
Equipment Directive (RED 2014/53/EU)” , 
https://ec.europa.eu/docsroom/documents/46453

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: Rick Linford 
Sent: Wednesday, April 10, 2024 3:53 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] German Required on Product Label to Match China and Nordic for 
(GS) ?

Dear EMC-PSTC Pros,

Specific to ITE IEC 62368-1 type standards and German GS certification. (many 
power supplies and ITE product carry GS mark)
Is German language required on products to match the text of other countries 
requirement to obtain German GS?
And (not or) add a statement that non-German text is not important to Germany?

China elevation and humidity waring is written into law and is very clear. Is 
there an equivalent German law and or specific German text?
仅适用于海拔2000米以下地区安全使用
仅适用于在非热带气候条件下安全使用

Nordic countries grounded plug warning, is specific to national differences in 
IEC 62368-1. I cannot find German equivalent in IEC 62368-1:2014, is it there?
Apparaten skall anslutas till jordat uttag.
Apparatet må tilkoples jordet stikkontakt.
Laite on liitettävä suojamaadoituskoskettimilla varustettuun pistorasiaan.

Standard does state to provide safety information and instruction in language 
of use and there is German law it must be in German. This has been the case for 
decades.

A recent GS certification was held up until compliance with adding text.  They 
are marking other countries requirements de facto German GS requirement. 
Already aware German GS is not a legal requirement and there many GS issuers. I 
would have expected PSTC to be lit up already, if this was a requirement 
applied to every manufacturer of ITE and AV with GS. Starts now, I guess.

I am representing myself. I am not asking for any past, current or future 
employer.
Linford@IEEE


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Re: [PSES] EN 300 220 - TX duty cycle for SDR

2024-02-22 Thread Charlie Blackham
Amund

That's a term often used for this type of operation, but it has to meet the 
requirements referenced in clause 4.5

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/ 
Registered in England and Wales, number 05466247

-Original Message-
From: Amund Westin  
Sent: Thursday, February 22, 2024 6:20 AM
To: Charlie Blackham ; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: SV: [PSES] EN 300 220 - TX duty cycle for SDR

Thanks Charlie

Would you accept "Listen-before-talk" as "polite spectrum access"?

Best regards Amund

-Opprinnelig melding-----
Fra: Charlie Blackham
Sendt: 20. februar 2024 10:38
Til: Amund Westin ; EMC-PSTC@LISTSERV.IEEE.ORG
Emne: RE: [PSES] EN 300 220 - TX duty cycle for SDR

Amund

The product has to meet the Spectrum Access requirements for the chosen band 
and transmit power - these are specified in Commission Decision 2013/752/EU and 
summarised in Annex C.

Some bands allow only a low duty cycle, other allow a maximum duty cycle or 
"polite spectrum access", and if following the later, the relevant clauses must 
be met, which are summarised in Annex A.

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

-Original Message-
From: Amund Westin 
Sent: Tuesday, February 20, 2024 8:10 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] EN 300 220 - TX duty cycle for SDR

The Duty Cycle at the operating frequency shall not be greater than values in 
annex B or any NRI for the chosen operational frequency band(s).

 From Annex B, table B.1:
Channel access and occupation rules (e.g. Duty cycle or LBT + AFA) Duty cycle 
can be 10%, 1% or 0.1%, depending on the channels inside the different 
Operational Frequency Band


Question:
Is it possible to increase TX transmission above the allowed duty cycle limit, 
if the transmission includes LBT (Listen-Before-Talk)?
Or are other techniques required?


Best regards Amund

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Re: [PSES] EN 300 220 - TX duty cycle for SDR

2024-02-20 Thread Charlie Blackham
Amund

The product has to meet the Spectrum Access requirements for the chosen band 
and transmit power - these are specified in Commission Decision 2013/752/EU and 
summarised in Annex C.

Some bands allow only a low duty cycle, other allow a maximum duty cycle or 
"polite spectrum access", and if following the later, the relevant clauses must 
be met, which are summarised in Annex A.

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/ 
Registered in England and Wales, number 05466247

-Original Message-
From: Amund Westin  
Sent: Tuesday, February 20, 2024 8:10 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] EN 300 220 - TX duty cycle for SDR

The Duty Cycle at the operating frequency shall not be greater than values in 
annex B or any NRI for the chosen operational frequency band(s).

 From Annex B, table B.1:
Channel access and occupation rules (e.g. Duty cycle or LBT + AFA) Duty cycle 
can be 10%, 1% or 0.1%, depending on the channels inside the different 
Operational Frequency Band


Question:
Is it possible to increase TX transmission above the allowed duty cycle 
limit, if the transmission includes LBT (Listen-Before-Talk)?
Or are other techniques required?


Best regards Amund

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Re: [PSES] 61010-1 Stability test, Para 7.4 Stability

2024-02-13 Thread Charlie Blackham
My 2p / 2c

You’re presumably asking an NRTL to list your product so it can be a bit of a 
“their bat, their ball”, but I would ask them at what height are they applying 
the horizontal force as in my view it is unreasonable to do this above shoulder 
height, and even that is unrealistic for how people push things.

If I understand correctly, the top of the robot is 70” above the floor – that 
is a very high height to push anything.

SEMI-S8-1116 (2016)  states that 95th Percentile Male (US) standing shoulder 
height is 61.9 inches (citing Pheasant (1998), MIL-STD-1472D(1994) and SAE 
J833(1989)).

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: Steve Brody 
Sent: Tuesday, February 13, 2024 5:37 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] 61010-1 Stability test, Para 7.4 Stability

Experts:

I need your opinions on the following.

I am having a 'discussion' with an NRTL on a product that I can't show you a 
picture of but here is a description:

  *   the base of the unit is 20" w x 26" l x 29" hf
  *   the base of the unit is mounted on caster/leveling feet devices that when 
positioned for use, the leveling feet are lowered and the casters come off the 
ground, and the leveling feet are sufficiently rated for more than 4x the load 
of each corner
  *   in the middle of the top of the base there is a robot mast for the Z 
axis, and it measures roughly 4" square and is 41" tall
  *   the whole product weighs 220 lbs
The stability requirements in 61010-1 are as follows, and I highlighted the 
text of interest:

Equipment and assemblies of equipment not secured to the building structure 
before operation shall be physically stable.

If means are provided to ensure that stability is maintained after the opening 
of drawers, etc. by an OPERATOR, either these means shall be automatic or there 
shall be a warning marking to apply the means.

Each castor and support foot shall be RATED to support a load of at least 4 
times its normal load, or the castors and support feet shall be tested 
according to d) and e), below.

Conformity is checked by inspection and by carrying out each of the following 
tests, if applicable, to ensure that the equipment will not overbalance. 
Containers contain the RATED amount of substance which provides the least 
favourable conditions of NORMAL USE. Castors are in their least favourable 
position of NORMAL USE. Doors, drawers, etc. are closed unless otherwise 
specified below.

  1.

 *   Equipment other than HAND-HELD EQUIPMENT is tilted in each direction 
to an angle of 10° from its normal
 *   Equipment which has both a height of 1 m or more and a mass of 25 kg 
or more, and all floor-standing equipment, has a force applied at its top, or 
at a height of 2 m if the equipment has a height of more than 2 The force is 
250 N, or 20 % of the weight of the equipment, whichever is less, and is 
applied to all surfaces in directions which could cause the equipment to 
topple. Stabilizers used in NORMAL USE, and doors, drawers, etc., intended to 
be opened by an OPERATOR, are in their least favourable positions.
 *   Floor-standing equipment has a force of 800 N applied downwards at the 
point of maximum moment to:

*   all horizontal working surfaces;
*   other surfaces providing an obvious ledge and which are not more 
than 1 m above floor
 Doors, drawers, etc. are closed, except that those intended to be opened by an 
OPERATOR are in their least favourable positions.

When the force was applied at the top of the robot mast, it unit started to 
topple at 38 lbs, which is less than the required 44 lb force according to the 
standard.

The case I presented why this test was not applicable was:

  *   because the robot mast is located in the center of of the unit, and not 
flush with the sides, that it did not represent the same situation as a 
bookcase, filing cabinet, or other product which if someone were to bump into 
it, they would not be contacting the robot mast to due to the location in the 
center of the top.
  *   the robot mast is part of a component and not part of the structure of 
the product, and so the test should be done at the top of the base unit, and no 
higher.
  *   there is text in the user manual that says not to push on the robot mast 
when moving the product to new location
  *   and, if absolutely necessary, we an add do not push labels at the top 
sides of the robot mast
The NRTL rejected my rationale so I am looking to you to get your thoughts on 
this before I press on with them.

Do you think the test is applicable?

You can respond here publicly or privately, or at 
stev...@productehsconsulting.com<mailto:stevenb@prduct>

Thanks in advance,

Steve Brody
sgbr...@comcast.net<mailto:sgbr...@comcast.net>
C - 603 617 9116
__

Re: [PSES] Test lab in Germany - LVD testing

2024-01-23 Thread Charlie Blackham
Amund

Try Accredited Bodies - DAkkS - German Accreditation 
Body<https://www.dakks.de/en/accredited-bodies-search.html> with Search term 
"62368" and Conformity Assessment Activity "Testing Laboratory"

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: Amund Westin 
Sent: Tuesday, January 23, 2024 2:22 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Test lab in Germany - LVD testing


On behalf of a local company, I'm looking for a German test lab within LVD 
testing (EN 62368-1).

I have a listing of all CB scheme labs in Germany but would appreciate 
suggestions of other labs.

Thanks!

Best regards / Mit freundlichen Grüßen / Mvh
Amund Westin
**
Cell: (+47) 920 17 031
E-mail: am...@westin-emission.no<mailto:am...@westin-emission.no>
**












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Re: [PSES] UKCA Extension .... again

2024-01-13 Thread Charlie Blackham
Lauren

Just to confirm - the extension to 2027 is only for how the product must be 
labelled to show compliance with UKCA, and not whether it must comply with UKCA 
- i.e. they're allowing manufacturers and extra 3 years to update product 
labels, artwork and rating plates.

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: Lauren Crane <1afd08519f18-dmarc-requ...@listserv.ieee.org>
Sent: Friday, January 12, 2024 11:53 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] UKCA Extension  again

Thanks for this Dean,

In part it, pointed me towards the current UK incarnation of the LVD - that is 
to say, I had not noticed until now that the LVEESR (Low Voltage Electrical 
Equipment Safety Regulations) SI 1989 No. 728 had been replaced by the EESR 
(Electrical Equipment Safety Regulations) SI 2016 No. 1101.

The delays built into the EESR and the SoMSR (Supply of Machinery Safety 
Regulations) SI 2008 No. 1597 seem to be similar - which is to be expected  
neither of them last indefinitely, so I guess we will have to wait and see if 
that promise is fulfilled.

Instrument
Allowing CE processes (incl. DoC) to stand (conditionally) for UKCA
Allowing UKCA mark to be in product documentation rather than on the product.
SoMSR SI 2008 No.1597 consolidated doc generated 15nov2023 incorporating F50 
(SI 2022 No.1393)
Allowed in regulation 12A
The expiry of regulation 12A is defined in regulation 12B as "regulation 12A 
ceases to have effect at the end of the period of [F50 four years] beginning 
with IP completion day." - which equates to Dec 31, 2024
In regulation 7 point (2A) - "[F36(2A) For a period of [F37seven years] 
beginning with IP completion day, the UK marking may be affixed to-
(a) a label affixed to the machinery; or
(b) a document accompanying the machinery.]"- which equates to Dec 31, 2027.
EESR SI 2016 No. 1101 consolidated doc generated 15nov2023 incorporating F54 
(SI 2022 No.1393)
Allowed in regulation 34A.
The expiry of regulation 34A is defined in regulation 34B as "regulation 34A 
ceases to have effect at the end of the period of [F54 four years] beginning 
with IP completion day." - which equates to Dec 31, 2024.
In regulation 39 point (1A) - "[F66(1A) For a period of [F67seven years] 
beginning with IP completion day, the UK marking maybe affixed to-
(a) a label affixed to the electrical equipment; or
(b) to a document accompanying the electrical equipment;]" - which equates to 
Dec 31, 2027

But note there is a further provision that kicks in following the expiry of the 
above and allows the UKCA mark in a document+package if the equipment is too 
small (or other issues) - and this provision does not expire.
"(2) Where [F68paragraph (1A) does not apply and] it is not possible or 
warranted, on account of the nature of the electrical equipment, to affix the 
[F69UK] marking in accordance with paragraph (1),the [F69UK] marking must be 
affixed to-
(a) the packaging; and
(b) the accompanying documents."

Best Regards,
-Lauren

From: Jurgensen, Dean mailto:djurgen...@delta-q.com>>
Sent: Thursday, January 11, 2024 9:18 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: Re: [PSES] UKCA Extension  again

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Hello Colleagues,

RE: Electrical Equipment (Safety) Regulations 2016

Here is what I was able to find:

General guidance site: On this site page:   
https://www.gov.uk/guidance/using-the-ukca-marking
"The government intends to introduce legislation to extend recognition of goods 
that meet EU requirements, including the CE marking, indefinitely, beyond 31 
December 2024 for many products. This will mean that certain goods that meet EU 
requirements can be placed on the GB market. These updates apply to the 18 
regulations that fall under the Department for Business and Trade (DBT).  
Manufacturers will have the choice to use either the CE marking or other 
recognised EU markings (where permitted), or the UKCA marking to supply 
products to Great Britain in the following areas: ..."
===
The UK regulation Section 34A - seems to allow for CE Marking: 
https://www.legislation.gov.uk/uksi/2016/1101/regulation/34A

And

The UK regulation Section 34B - seems to allow for CE Marking for an extended 
period of time after the expiry of Section 34A: 
https://www.legislation.gov.uk/uksi/2016/1101/regulation/34

Re: [PSES] UKCA Extension .... again

2024-01-11 Thread Charlie Blackham
Lauren

"The Government intends to introduce" Is as much as we have so far.
It's a press release / announcement from one Government department that does 
not have responsibilities for all UK regulations (for example, it doesn't 
enforce RoHS which is applicable to lots of products covered by other 
regulations they are responsible for)

It is also worth noting that there will be a general election in the UK in 
2024, so quite how focused the government will be on bringing out this 
extension I leave as an exercise for the reader.

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: Lauren Crane <1afd08519f18-dmarc-requ...@listserv.ieee.org>
Sent: Thursday, January 11, 2024 6:02 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] UKCA Extension  again

Hello Experts,

In Nov 22 we (this listserve) were discussing the UKCA extension aiming to 
allow CE marking to stand in for UKCA for a longer period. We were tracking a 
related statutory instrument, which I believe has been released as SI 2022 No. 
1393 (https://www.legislation.gov.uk/uksi/2022/1393/contents/made).

This SI 1393, however, does not appear to extend the deadline indefinitely.  
According to a accompanying explanatory memorandum 
(https://www.legislation.gov.uk/uksi/2022/1393/memorandum/contents) ... "the 
instrument makes only the necessary changes to extend the time period for 
recognition of products meeting EU requirements and markings until 31 December 
2024, to extend existing labelling easements until 31 December 2027, and 
extending the time period to allow any steps taken under EU conformity 
procedures before 31 December 2024 to be considered valid to demonstrate 
compliance with UKCA, for the duration of the certificates issued or until 31 
December 2027, whichever is the sooner."

Nonetheless, a couple official uk.gov webpages  (e.g., 
https://www.gov.uk/guidance/using-the-ukca-marking) say "The government intends 
to introduce legislation to extend recognition of goods that meet EU 
requirements, including the CE marking, indefinitely, beyond 31 December 2024 
for many products."

I cannot identify any SI in the works that will provide the alleged indefinite 
extension.

Does anyone on the list have more certain information about the indefinite 
extension they could share?

Best Regards,
-Lauren


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Re: [PSES] FCC label for White Labeled products

2023-12-13 Thread Charlie Blackham
Brian

If you have integrated a FCC module, with modular certification, your product 
label should state "contains FCC ID:XX" where XX is the FCC ID 
of the module.

Unless you have separately certified your product as a radio transmitter, 
there's no other FCC ID label for you to apply and your strategic partner would 
apply the same label.

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: Brian Gregory 
Sent: Tuesday, December 12, 2023 10:06 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] FCC label for White Labeled products


 Hello experts,

Our existing product label has our FCC ID, just under the FCC logo in the 
classic form:x-y,  where

x =  the FCC ID of the imbedded, compliant WiFi model ("Grantee Code" in 
FCC lingo), and
y = our product name, per the UL label. ("Product Code" ).

We're trying to offer a label to our strategic partner who is selling the same 
product under their product name:   z.

So, it seemed obvious to label that product's FCC ID as  x-z.

I'm trying to confirm this from FCC on this, and can't find much in the way of 
official guidance, nor any response from the help ticket I pulled nor on our 
FRN registration page.
Anybody else have experience with alternate product codes on FCC labelling?

Colorado Brian


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Re: [PSES] EU Cyber Resilience Act

2023-11-28 Thread Charlie Blackham
Amund

It's very likely to be in scope for that reason.

The Commission are writing a guide for this which will be published next year

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: Amund Westin 
Sent: Tuesday, November 28, 2023 1:03 PM
To: Charlie Blackham ; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: SV: [PSES] EU Cyber Resilience Act

I guess such "in house temp sensor" is within the Cyber security scope ...

https://eur-lex.europa.eu/resource.html?uri=cellar:864f472b-34e9-11ed-9c68-01aa75ed71a1.0001.02/DOC_1&format=PDF
Article 2
Scope 1. This Regulation applies to products with digital elements whose 
intended or reasonably foreseeable use includes a direct or indirect logical or 
physical data connection to a device or network.


  *   The wording  means devices where the wireless data trafic must 
pass other devices before it's on the Internet ... ?


BR
Amund



Fra: Amund Westin
Sendt: 28. november 2023 13:43
Til: 'Charlie Blackham' 
mailto:char...@sulisconsultants.com>>; 
'EMC-PSTC@LISTSERV.IEEE.ORG' 
mailto:EMC-PSTC@LISTSERV.IEEE.ORG>>
Emne: SV: [PSES] EU Cyber Resilience Act

Great Information, Charlie.

One thing ...
Let's say a temperature sensor on NB-IoT (sim card) is definitely a radio 
product which is connected to the internet.
But what about the same temperature sensor when using BLE, Zigbee or other 
typical smart house protocols, not directly connected to the Internet, but to a 
local in-house gateway, which the gateway itself is connected to Internet by 
wire or radio.

Will that "in house temp sensor" be classified as "connected to Internet", so 
the Cyber Resilience Act will apply even for such sensors?

BR
Amund


Fra: Charlie Blackham
Sendt: 28. november 2023 09:32
Til: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Emne: Re: [PSES] EU Cyber Resilience Act

Amund

The RED has requirements that are separate, but aligned with, the Cyber 
Resilience Act

Delegated Regulation (EU) 2022/30 which relates to Articles 3.3(d), 3.3(e), and 
3.3(f) of the Radio Equipment Directive (RED), which is now applicable from 1st 
August 2025 as per Delegated Regulation (EU) 2023/2444.
Applicable sections of Article 3.3:
d) No harm to network - any radio that communicates over the internet
e) Privacy of the user - any radio processing personal data, traffic data, 
location
f) Protection from Fraud - any radio enabling money transfer

CENELEC are developing three Article 3.3 standards, one for each of these parts:

  *   EN 18031-1: Common security requirements for radio equipment Part 1: 
Internet connected radio equipment
  *   EN 18031-2: Common security requirements for radio equipment Part 2: 
radio equipment processing data, namely Internet connected radio equipment, 
childcare radio equipment, toys radio equipment and wearable radio equipment
  *   EN 18031-3: Common security requirements for radio equipment Part 3: 
Internet connected radio equipment processing virtual money or monetary value

The plan is that these will be published by CENELEC but 30th June 2024 and that 
these will be listed in the OJ by the EU Commission and become "Harmonised 
Standards listed in the Official Journal"

If they are accepted by the EU and listed, then manufacturers will be able to 
apply them and self-declare.
If they aren't, manufacturers will have to use a Notified Body

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: Amund Westin mailto:am...@westin-emission.no>>
Sent: Tuesday, November 28, 2023 7:48 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: [PSES] EU Cyber Resilience Act

I have heard rumors about August 01, 2025, from that date the EU Cyber 
Resilience Act is mandatory and part of the CE marking (for relevant RED/radio 
products)
Is it correct rumors?

BR
Amund



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Re: [PSES] EU Cyber Resilience Act

2023-11-28 Thread Charlie Blackham
Amund

The RED has requirements that are separate, but aligned with, the Cyber 
Resilience Act

Delegated Regulation (EU) 2022/30 which relates to Articles 3.3(d), 3.3(e), and 
3.3(f) of the Radio Equipment Directive (RED), which is now applicable from 1st 
August 2025 as per Delegated Regulation (EU) 2023/2444.
Applicable sections of Article 3.3:
d) No harm to network - any radio that communicates over the internet
e) Privacy of the user - any radio processing personal data, traffic data, 
location
f) Protection from Fraud - any radio enabling money transfer

CENELEC are developing three Article 3.3 standards, one for each of these parts:

  *   EN 18031-1: Common security requirements for radio equipment Part 1: 
Internet connected radio equipment
  *   EN 18031-2: Common security requirements for radio equipment Part 2: 
radio equipment processing data, namely Internet connected radio equipment, 
childcare radio equipment, toys radio equipment and wearable radio equipment
  *   EN 18031-3: Common security requirements for radio equipment Part 3: 
Internet connected radio equipment processing virtual money or monetary value

The plan is that these will be published by CENELEC but 30th June 2024 and that 
these will be listed in the OJ by the EU Commission and become "Harmonised 
Standards listed in the Official Journal"

If they are accepted by the EU and listed, then manufacturers will be able to 
apply them and self-declare.
If they aren't, manufacturers will have to use a Notified Body

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: Amund Westin 
Sent: Tuesday, November 28, 2023 7:48 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] EU Cyber Resilience Act

I have heard rumors about August 01, 2025, from that date the EU Cyber 
Resilience Act is mandatory and part of the CE marking (for relevant RED/radio 
products)
Is it correct rumors?

BR
Amund



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Re: [PSES] SV: [PSES] EN 62368-1 : 2014

2023-11-01 Thread Charlie Blackham
Amund

If a standard is listed in the OJ, it continues to provide a “presumption of 
conformity” even it has been “withdrawn” by the standards committee.

The 2020 version of 62368-1 will not be listed in  the OJ

The 2023 version of 62368-1 was rejected by the EU Commission but it looks as 
though CENELEC voting will see it published anyway.

IEC test reports  and CB certificates are not required for CE marking and they 
remain valid in other countries until those national authorities have withdrawn 
them

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: Amund Westin 
Sent: Wednesday, November 1, 2023 7:08 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] SV: [PSES] EN 62368-1 : 2014

Hi all

Any news about the future standing for the EN62368-1 : 2014?

My understanding is that EN62368-1 : 2020 is still not listed in OJ, even 
though it should replace EN62368-1 : 2014 in June 2024.
In parallel, EN62368-1 : 2023 is still under work and what do we expect as a 
date to replace 2014 and 2020 version?

In our case, we have a CB test certificate & report according to EN62368-1 : 
2014 and would hope it would be valid at least a year or two more.


BR
Amund


Fra: Scott Xe
Sendt: 8. desember 2022 10:12
Til: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Emne: Re: [PSES] EN 62368-1 : 2014

Dear All,

Thanks for your comments!  It said version 4 will be issued in 2023 and hope 
there is less chance to have amendments during the extension period.

Best regards,

Scott

On Thu, 8 Dec 2022 at 00:42, Scott Xe 
mailto:scott...@gmail.com>> wrote:
CENELEC recently extended DoW for 18 months from 06/01/2023 to 06/07/2024.  
What are the impacts on importers/manufacturers, test houses and market 
surveillances?

EN 62368-1 : 2014 is still valid for LVD/RED in EUOJ.  All the relevant 
products should follow this version for EU markets.  What is the point of this 
change to them?

In general the test houses give unclear interpretations to their clients in 
this aspect.  Sometimes, they follow EUOJ requirements but sometimes CENELEC.  
Some importers/manufacturers also confuse which requirements to follow.  Some 
countries also may not adopt the latest IEC/EN standard as their national 
standards.  Can't withdrawn standards be used?

Thanks and best regards,

Scott
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Re: [PSES] SV: [EXTERNAL] [PSES] General Product Safety Directive (GPSD)

2023-11-01 Thread Charlie Blackham
Amund

The difficult part is ensuring "which can't be bought or even used by 
consumers" - even if it is only sold or supplied on a B2B basis, is it the type 
of product and employee could take home with them for personal use or whilst 
"working from home".

Most national legislation requires equipment used in the workplace to be safe, 
so whether you could sell B2B equipment without any safety related tests would 
need to be considered and in any case, reasons should be considered as part of 
product compliance risk assessment

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: Amund Westin 
Sent: Wednesday, November 1, 2023 7:41 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] SV: [EXTERNAL] [PSES] General Product Safety Directive (GPSD)

Thanks Ted,

As I read your comments and take they into an example - ... consider a 
professional electronic product, which can't be bought or even used by 
consumers, will not under any circumstances be covered by GPSD/GPSR. Right?
And if product is low powered (not within LVD), then maybe only EMC apply. Then 
the product could be put on the market without any safety related tests  Is 
that correct?


BR
Amund


Fra: Ted Eckert
Sendt: 31. oktober 2023 16:10
Til: Amund Westin mailto:am...@westin-emission.no>>; 
EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Emne: RE: [EXTERNAL] [PSES] General Product Safety Directive (GPSD)


Hello Amund,



The GPSR has these definitions. I recommend you use them as the basis to 
determine if you are providing "consumer products" as covered by the scope of 
the GPSR.



"'product' means any item, whether or not it is interconnected to other items, 
supplied or made available, whether for consideration or not, including in the 
context of providing a service, which is intended for consumers or is likely, 
under reasonably foreseeable conditions, to be used by consumers even if not 
intended for them".



"'consumer' means any natural person who acts for purposes which are outside 
that person's trade, bushiness, craft or profession".



There is no clear line drawn between consumer and professional equipment, and 
the GPSR is intended to cover professional equipment that is likely to be 
purchased for personal use by some consumers. Products that fall into this grey 
area may need to be reviewed on a case-by-case basis. I would recommend that if 
you determine a product is not within the scope, your technical file include a 
clear explanation of why it is out of scope.

Best regard,
Ted Eckert

The opinions expressed are my own and do not necessarily reflect those of my 
employer.






-Original Message-
From: Amund Westin mailto:am...@westin-emission.no>>
Sent: Tuesday, October 31, 2023 7:54 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: [EXTERNAL] [PSES] General Product Safety Directive (GPSD)



General Product Safety Directive ... Do I interpret correct that GPSD only 
apply to consumer products? Not for any professional products?

And the new General Product Safety Regulation (GPSR) do the same?





BR

Amund



-



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Re: [PSES] [PSES] IEC/EN62368-1 includes requirements (Annex M) to IEC/EN 62133-2

2023-10-17 Thread Charlie Blackham
Amund

If the battery manufacturer knows what they are doing you may well find that 
the battery has been “designed to comply” with IEC 62133-2 but that particular 
variant has not been subjected to certification testing as they were waiting on 
a minimum order, or a customer who needed it.

A competent battery manufacturer should be able to arrange this for you as a 
matter of routine for a fee.

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: Chris Wordley <251cd282cc37-dmarc-requ...@listserv.ieee.org>
Sent: Tuesday, October 17, 2023 9:26 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [PSES] IEC/EN62368-1 includes requirements (Annex M) to 
IEC/EN 62133-2

Hi Amund

UN38.3 only addresses battery transportation, covering both expected conditions 
and likely mishandling / abuse situations, to demonstrate that they are safe to 
transport. The battery isn’t usually operational during this phase of its life.

So although some tests are similar, UN38.3 cannot be considered an alternative 
to IEC 62133-2.

Chris




On 16 Oct 2023, at 19:31, Amund Westin 
mailto:am...@westin-emission.no>> wrote:

Thanks, James!

Seems we might have an issue here since the cells are not IEC62133-2 approved.

But the cells are UN38.3 certified. And we are now running UN38.3 on the 
complete product (product and cells includes).
Do you know if such UN38.3 tests will be good as IEC62133-2 compliance?

BR
Amund






-Opprinnelig melding-
Fra: James Pawson (U3C)
Sendt: 16. oktober 2023 16:39
Til: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Emne: Re: [PSES] IEC/EN62368-1 includes requirements (Annex M) to IEC/EN 62133-2

Hi Amund,

Annex M (batteries) is normative = shall comply. You only get to comply with 
Annex M if you pass M.2.1 which requires that cells comply with the relevant 
IEC standard.

IEC 62133 (all parts) are in Annex ZA as an undated reference meaning you 
should be looking to use the latest one - this is currently IEC 
62133-2:2017+A1:2021.

Many (reputable) battery manufacturers will be aware of this and will have 
battery packs that are pre-certified to the latest standard.

All the best
James

James Pawson
Managing Director & EMC Problem Solver

Unit 3 Compliance Ltd
EMC : Environmental & Vibration : Electrical Safety : CE & UKCA : Consultancy

www.unit3compliance.co.uk<http://www.unit3compliance.co.uk> | 
ja...@unit3compliance.co.uk<mailto:ja...@unit3compliance.co.uk>
+44(0)1274 911747  |  +44(0)7811 139957
2 Wellington Business Park, New Lane, Bradford, BD4 8AL Registered in England 
and Wales # 10574298




-Original Message-
From: Amund Westin mailto:am...@westin-emission.no>>
Sent: Monday, October 16, 2023 3:27 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: [PSES] IEC/EN62368-1 includes requirements (Annex M) to IEC/EN 62133-2

An IT product must comply to EN62368-1. It contains Lithium LiPo batter.
According to EN/IEC62368-1-1:2020, § M.2 Safety of batteries and their cells, 
the standard IEC 62133-2 is listed, and batteries and cells shall comply 
according to that standard.

Could this be interpreted as an invariable requirement, that if you are to 
fulfill EN62368-1 and have LiPo cells in your product, then the cells must 
comply with this standard IEC 62133-2?
How well known is IEC 62133-2?



Thanks!

BR
Amund

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Re: [PSES] AW: [PSES] Directives that require the CE Marking

2023-10-10 Thread Charlie Blackham
Me again 😊

The opening sentence tells you to tread carefully:

The CE mark is a certification mark that indicates conformity with health, 
safety, and environmental protection standards for products sold within the 
European Economic Area (EEA


  *   It’s not a “certification” mark
  *   Not all CE marking Directives cover safety or health
  *   There are no CE marking Directives that cover environmental protection
  *   The rules don’t apply to products “sold”, they apply to products “placed 
on the market” – there doesn’t need to be a monetary exchange, and the lack of 
one does not put you out of scope

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: rmm.priv...@gmail.com 
Sent: Sunday, October 8, 2023 4:56 PM
To: Charlie Blackham 
Cc: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] AW: [PSES] Directives that require the CE Marking

I agree that tools like ChatGPT have a long way to go before their response can 
be trusted without question, but the response below is from the free version.  
The $20 a month version might provide a clearer answer.  I use ChatGPT as a 
starting point for topics I have some familiarity with, then I drill down on 
the details.

I asked ChatGPT “under what conditions should I not apply the CE Mark ?”, and 
it answered:

=
The CE mark is a certification mark that indicates conformity with health, 
safety, and environmental protection standards for products sold within the 
European Economic Area (EEA).  It demonstrates that a product complies with the 
relevant EU directives and regulations. However, there are certain conditions 
or situations where you should not apply the CE mark:

  1.  Non-conforming products: If your product does not meet the essential 
requirements or standards specified by the relevant EU directives or 
regulations, you should not apply the CE mark. It is essential to ensure that 
your product complies with all applicable requirements before affixing the CE 
mark.
  2.  Non-covered products: Some products or product categories may not be 
covered by specific EU directives or regulations, and therefore, the CE mark 
may not be applicable to them. Always check whether your product falls under 
any relevant EU legislation before considering the CE mark.
  3.  Self-declaration without applicable legislation: In some cases, a 
manufacturer may incorrectly self-declare conformity and affix the CE mark to a 
product without any applicable EU directive or regulation. This is not allowed, 
and the CE mark should only be applied when there is clear and relevant 
legislation to comply with.
  4.  Non-EEA sales: The CE mark is primarily intended for products intended 
for sale within the EEA. If your product is not intended for the EEA market, 
applying the CE mark may not be necessary. However, you should comply with the 
regulatory requirements of the specific market where you intend to sell your 
product.
  5.  Unauthorized use: The CE mark should only be applied by manufacturers or 
authorized representatives who have fulfilled the necessary conformity 
assessment procedures and legal obligations. Unauthorized use of the CE mark is 
not allowed and can result in legal consequences.
  6.  False or misleading information: Providing false or misleading 
information, documentation, or test results to obtain the CE mark is illegal 
and should not be done under any circumstances.

It's crucial to consult with regulatory authorities, experts, or legal counsel 
knowledgeable about the specific product and its applicable regulations to 
ensure compliance with CE marking requirements. Incorrectly applying the CE 
mark can lead to legal consequences, including fines and product recalls.
==

Ralph

From: Charlie Blackham 
mailto:char...@sulisconsultants.com>>
Sent: Saturday, October 7, 2023 1:17 AM
To: rmm.priv...@gmail.com<mailto:rmm.priv...@gmail.com>; 
EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: RE: [PSES] AW: [PSES] Directives that require the CE Marking

A nice example of why ChatGPT won’t put us all out of a job just yet 😊

Point 9 is wrong – you may not use the CE mark to demonstrate compliance with a 
“non CE marking” Directive, that is one that does not contain the provision for 
CE marking within its Articles or Annexes

Point 3 does not make it clear that the Directive also includes products that 
are “likely, under reasonably foreseeable conditions, to be used by consumers 
even if not intended for them” – an example of this would be something like a 
corporate branded battery pack phone charger which is supplied only on a B2B 
basis, but is likely to be taken home by the recipient

Best regards
Charlie

Charlie Blackha

Re: [PSES] AW: [PSES] Directives that require the CE Marking

2023-10-07 Thread Charlie Blackham
A nice example of why ChatGPT won’t put us all out of a job just yet 😊

Point 9 is wrong – you may not use the CE mark to demonstrate compliance with a 
“non CE marking” Directive, that is one that does not contain the provision for 
CE marking within its Articles or Annexes

Point 3 does not make it clear that the Directive also includes products that 
are “likely, under reasonably foreseeable conditions, to be used by consumers 
even if not intended for them” – an example of this would be something like a 
corporate branded battery pack phone charger which is supplied only on a B2B 
basis, but is likely to be taken home by the recipient

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: Ralph McDiarmid 
Sent: Friday, October 6, 2023 10:59 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] AW: [PSES] Directives that require the CE Marking

Here’s what ChatGPT told me about this directive:

The General Product Safety Directive (2001/95/EC) in the European Union (EU) is 
a legal framework designed to ensure the safety of consumer products placed on 
the EU market. It sets out general requirements for the safety of products, 
regardless of whether specific product safety regulations exist for them. Here 
are key aspects of the General Product Safety Directive (GPSD):

  1.  Scope: The GPSD applies to all consumer products, excluding food, 
pharmaceuticals, medical devices, cosmetics, and chemicals, which are covered 
by other specific regulations.
  2.  Safety Requirement: The primary objective of the GPSD is to ensure that 
products placed on the market are safe for consumers when used under normal or 
reasonably foreseeable conditions. Manufacturers and distributors have an 
obligation to provide safe products.
  3.  Definition of Consumer Products: The directive defines "consumer 
products" broadly to encompass any product intended for consumers, including 
both new and second-hand products.
  4.  Obligations of Economic Operators: Economic operators, including 
manufacturers, importers, and distributors, must ensure that products they 
place on the market are safe. They are responsible for assessing and managing 
risks, monitoring product safety, and taking corrective actions if safety 
issues arise.
  5.  Traceability: Economic operators must be able to trace the origin of the 
products they handle and, if necessary, inform the relevant authorities and 
consumers about safety issues or recalls.
  6.  Rapid Alert System: The GPSD establishes a Rapid Alert System for 
Non-Food (RAPEX) to facilitate the rapid exchange of information about 
dangerous products among EU member states and the European Commission. This 
system helps to ensure that dangerous products are quickly removed from the 
market.
  7.  Market Surveillance: EU member states are responsible for carrying out 
market surveillance activities to ensure compliance with the GPSD. They can 
take measures such as conducting inspections, ordering recalls, or imposing 
fines for non-compliance.
  8.  Cooperation with Other EU Legislation: The GPSD complements other EU 
product safety regulations, such as the Toy Safety Directive or the Machinery 
Directive. In cases where specific product safety legislation exists, that 
legislation takes precedence.
  9.  CE Marking: While the GPSD does not require products to bear the CE 
marking (a conformity marking indicating compliance with EU safety standards), 
manufacturers may choose to use it to demonstrate compliance with the directive.
  10. Harmonized Standards: Manufacturers can use harmonized European standards 
to demonstrate compliance with the GPSD's safety requirements.
The General Product Safety Directive plays a crucial role in protecting 
consumers within the EU by establishing a baseline level of safety for a wide 
range of consumer products. It encourages manufacturers and other economic 
operators to ensure that their products are safe for use and allows for swift 
action in the event of safety concerns. It is important to note that the GPSD 
is subject to updates and amendments to align with changing safety requirements 
and technological advancements.

Ralph

From: Dürrer Bernd mailto:bernd.duer...@wilo.com>>
Sent: Tuesday, September 19, 2023 6:44 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: [PSES] AW: [PSES] Directives that require the CE Marking

Hello Brian,

in lack of any more specific EU Directive, a product will be in the scope of 
the General Product Safety Directive 2001/95/EC (Consolidated TEXT: 32001L0095 
— EN — 01.01.2010 
(europa.eu)<https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:02001L0095-20100101#tocId3>)
 that covers any product intended for consumers. As far as I know, the GPSD 
does neither require a CE Declaration of Conformity, nor CE marking on the 
prod

Re: [PSES] Labelling in Canada

2023-10-06 Thread Charlie Blackham
Niels

The applicable standard is ICES-003 issue 7.

This standard allows one of 2 test methods to be used, CAN/CSA-CISPR 32:17 or 
ANSI C63.4, but the standard you are stating compliance to is ICES-003.

If you follow the CAN/CSA-CISPR 32 test method this is detailed in the report 
but no reference is made to it on the label or in the user manual

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: Niels Hougaard <27ee5df789dc-dmarc-requ...@listserv.ieee.org>
Sent: Friday, October 6, 2023 3:03 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Labelling in Canada

Hi Bart,
Thanks for answering. I have looked into pages like this, and I think that my 
question actually can be turned into:
Does Canada accept CISPR 32?
If so it must be this standard that has to be mentioned on the label.


Mvh./Regards,
Niels Hougaard
Bolls ApS
Denmark
Tlf. 4818 3566
Direkte 5379 6991
www.bolls.dk<http://www.bolls.dk>


Fra: "bart de geeter" 
mailto:bart.de.gee...@telenet.be>>
Til: "Niels Hougaard" mailto:n...@bolls.dk>>, "EMC-PSTC" 
mailto:EMC-PSTC@LISTSERV.IEEE.ORG>>
Sendt: fredag, 6. oktober 2023 12:13:27
Emne: RE: [PSES] Labelling in Canada

Hi Niels,

Did you look into the below webpage?

https://ised-isde.canada.ca/site/spectrum-management-telecommunications/en/devices-and-equipment/interference-causing-equipment-standards-ices/ices-gen-general-requirements-compliance-interference-causing-equipment#s5.3

Greetings,
Bart

From: Niels Hougaard 
<27ee5df789dc-dmarc-requ...@listserv.ieee.org<mailto:27ee5df789dc-dmarc-requ...@listserv.ieee.org>>
Sent: vrijdag 6 oktober 2023 10:03
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: [PSES] Labelling in Canada

Hello,
Product in question is a loudspeaker for commercial marked.
It is going to be sold in Canada and question is, if the labelling concerning 
EMC should be


This Class B apparatus complies with Canadian ICES-003.

Cet appareil de la classe B est conforme à la norme NMB-003 du Canada.



or if Canada accept CISPR 32 so that the labelling should be



This apparatus complies with Can/CSA CISPR 32-17 (B)

Cet appareil est conforme à la norme NMB-CISPR 32-17 du Canada.




Mvh./Regards,
Niels Hougaard
Bolls ApS
Denmark
Tlf. 4818 3566
Direkte 5379 6991
www.bolls.dk<http://www.bolls.dk>


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Re: [PSES] SV: [PSES] Radio receivers under RED? Yes

2023-10-05 Thread Charlie Blackham
Television and radio receivers are within scope of RED 😊 (they weren’t under 
R&TTE)

@Amund Westin<mailto:am...@westin-emission.no> – you should be careful 
determining whether your item is “test equipment” or “radio equipment” – 
wideband spectrum monitoring equipment which can receive and determine some 
information from the received signal then it would be “radio equipment” under 
RED

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: Ralph McDiarmid 
Sent: Thursday, October 5, 2023 12:23 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] SV: [PSES] Radio receivers under RED? Yes

Given the reasoning you propose, your spectrum analyser, as an unintentional 
radiator, should be out of scope of the RED.  If it were, then all television 
and radio receivers would also fall under the RED.


From: Amund Westin mailto:am...@westin-emission.no>>
Sent: Wednesday, October 4, 2023 10:51 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: [PSES] SV: [PSES] Radio receivers under RED? Yes

Hi Charlie

I was made aware that in the RED Guide, there is something about equipment that 
does not fall under the RED.



1.6.3.3 Products that use electromagnetic waves exclusively for other purposes 
than radio communication and/or radiodetermination

Products and applications that use electromagnetic waves exclusively for other 
purposes than radio communication and/or radiodetermination (products that 
propagate electromagnetic waves in space, but this propagation is not intended 
and not used for the purpose of radio communication or radiodetermination.) are 
not covered by the RED, for example:

 inductive warming and heating appliances;

 pure wireless power transfer (without any communication or 
radiodetermination);

 high frequency surgical equipment and systems;

 cookware suitable for inductive heating appliances;

 test equipment if intended to use radio waves, exclusively, for testing other 
devices (18)  Footnote 18: Needs to be assessed on a case-by-case basis, in 
order to determine if a specific type of test equipment is covered (or not 
covered) by the RED.


The product in this case is a receiver-only product (with an external antenna 
connected) and its main purpose is to analyze a received signal from another 
radio (VHF/UHF) product. So, it is a professional test / analyze radio receiver 
equipment.

It can be compared to a portable spectrum analyzer with an external dipole 
antenna connected.


With this additional information, do you think we are still within RED or are 
we now outside RED? …..


Best regards Amund





Fra: Charlie Blackham
Sendt: 5. september 2023 09:35
Til: Amund Westin mailto:am...@westin-emission.no>>; 
EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Emne: RE: [PSES] Radio receivers under RED? Yes

Amund

Yes, receivers are within scope of RED as they meet the definition of “radio 
equipment” in article 2:

‘radio equipment’ means an electrical or electronic product, which 
intentionally emits and/or receives radio waves for the purpose of radio 
communication and/or radiodetermination, or an electrical or electronic product 
which must be completed with an accessory, such as antenna, so as to 
intentionally emit and/or receive radio waves for the purpose of radio 
communication and/or radiodetermination;

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: Amund Westin mailto:am...@westin-emission.no>>
Sent: Tuesday, September 5, 2023 7:17 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: [PSES] Radio receivers under RED? Yes


I think we have discussed this topic previous, but I can’t find the email tread.

But I assume it is the fact the equipment that even only receive, will anyway 
be included under RED. In this case, it’s a radio receiver measurement device 
with whip antenna mounted and that receives in the VHF/UHF range.



From RED text, page 2:

(11) Although receivers do not themselves cause harmful interference, reception 
capabilities are an increasingly important factor in ensuring the efficient use 
of radio spectrum by way of an increased resilience of receivers against 
harmful interference and unwanted signals on the basis of the relevant 
essential requirements of Union harmonisation legislation.



Thanks!

BR

Amund



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Website

Re: [PSES] 50Hz Product and the EMC Directive

2023-09-27 Thread Charlie Blackham
Scott

If you read the Guide to the EMC Directive, specifically section 1.4.4 
Inherently benign equipment you will find multiple references to certain 
product categories being exempt only if they are “without active electronic 
parts or active components;”

A transistor is an active component.

So whilst you are very likely to have no EMC emissions or immunity issues, I 
would not be able to write an argument that exempts your product from the 
Directive.

You EMC assessment against Harmonised Standards does not mandate testing 
against all aspects of them, but I would imagine that at least some radiated 
and conducted emissions would be diligent.

In the absence of a product standard, the Generic Standards, EN 61000-6-x are 
the appropriate route and the ones you should assess against and list on the 
DoC.

As an aside, a Notified Body cannot state that a product is inside or outside 
the scope of the Directive as that is outside of their remit under the 
Directive and their accreditation.

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: Scott Douglas 
Sent: Wednesday, September 27, 2023 2:35 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] 50Hz Product and the EMC Directive

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


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Re: [PSES] RED certificate - validity period

2023-09-22 Thread Charlie Blackham
Amund

There’s no explicit validity date in the Directive and I’ve seen different NBs 
use different expiration dates, however, RED Annex III, Module B, para 7 states:

The notified body shall keep itself apprised of any changes in the generally 
acknowledged state of the art which indicate that the approved type may no 
longer comply with the applicable requirements of this Directive, and shall 
determine whether such changes require further investigation. If so, the 
notified body shall inform the manufacturer accordingly.

The manufacturer shall inform the notified body that holds the technical 
documentation relating to the EU-type examination certificate of all 
modifications to the approved type that may affect the conformity of the radio 
equipment with the essential requirements of this Directive or the conditions 
for validity of that certificate. Such modifications shall require additional 
approval in the form of an addition to the original EU-type examination 
certificate.

The RED certificate is never “irrevecoably valid” until the expiration date as 
the state of the art may have changed, including Harmonised Standards being 
superceded and, of course, the product may have changed to an extent that the 
original assessment needs to be reviewed

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: Amund Westin 
Sent: Friday, September 22, 2023 5:56 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] RED certificate - validity period

The RED EU-Type Examination Certificates I have seen, are valid for 4 years.
Is the validity period something regulated by the EU or is it up to the 
Notified Body to set the period on the RED certificate?


Best regards
Amund


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Re: [PSES] UK extends CE mark recognition indefinitely

2023-09-19 Thread Charlie Blackham
Sam

Those directives are enforced by a different UK government department that 
didn’t put out a press release.

There’s been no further communication on this issue so we’re really waiting to 
see what the draft legislation says when that’s published (whenever that may be)

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: Sam Davis <163be7cdf3a8-dmarc-requ...@listserv.ieee.org>
Sent: Wednesday, September 20, 2023 6:10 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] UK extends CE mark recognition indefinitely

In reviewing this, I don’t see that it addresses RoHS and Ecodesign directives. 
 Would products in scope of these directives still require the UKCA mark by 
December 2024?

SAM Davis
Sr. Regulatory Engineering Manager
Customer Engineering Services
www.jabil.com<https://www.jabil.com/>

From: Matthew Wilson | GBE 
mailto:matthew.wil...@gbelectronics.com>>
Sent: Tuesday, August 1, 2023 4:41 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: [PSES] UK extends CE mark recognition indefinitely

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https://www.gov.uk/guidance/ukca-marking-conformity-assessment-and-documentation

Reporting:  
https://www.theguardian.com/politics/2023/aug/01/uk-eu-safety-mark-brexit-climbdown
 - the funny bit here is that the original article was accompanied by a picture 
of a non-compliant CE logo, as per the final note “The image accompanying this 
article was changed on 1 August 2023, to one of a CE mark that adheres more 
closely to EU guidance on how it should be reproduced”

The [UK] government intends to extend recognition of the CE marking for placing 
most goods on the market in Great Britain, indefinitely, beyond December 2024. 
These updates apply to the 18 regulations that fall under the Department for 
Business and Trade (DBT). These are:

  *   toys
  *   pyrotechnics
  *   recreational craft and personal watercraft
  *   simple pressure vessels
  *   electromagnetic compatibility
  *   non-automatic weighing instruments
  *   measuring instruments
  *   measuring container bottles
  *   lifts
  *   equipment for potentially explosive atmospheres (ATEX)
  *   radio equipment
  *   pressure equipment
  *   personal protective equipment (PPE)
  *   gas appliances
  *   machinery
  *   equipment for use outdoors
  *   aerosols
  *   low voltage electrical equipment
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Re: [PSES] Radio receivers under RED? Yes

2023-09-05 Thread Charlie Blackham
Amund

Yes, receivers are within scope of RED as they meet the definition of “radio 
equipment” in article 2:

‘radio equipment’ means an electrical or electronic product, which 
intentionally emits and/or receives radio waves for the purpose of radio 
communication and/or radiodetermination, or an electrical or electronic product 
which must be completed with an accessory, such as antenna, so as to 
intentionally emit and/or receive radio waves for the purpose of radio 
communication and/or radiodetermination;

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: Amund Westin 
Sent: Tuesday, September 5, 2023 7:17 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Radio receivers under RED? Yes


I think we have discussed this topic previous, but I can’t find the email tread.

But I assume it is the fact the equipment that even only receive, will anyway 
be included under RED. In this case, it’s a radio receiver measurement device 
with whip antenna mounted and that receives in the VHF/UHF range.



From RED text, page 2:

(11) Although receivers do not themselves cause harmful interference, reception 
capabilities are an increasingly important factor in ensuring the efficient use 
of radio spectrum by way of an increased resilience of receivers against 
harmful interference and unwanted signals on the basis of the relevant 
essential requirements of Union harmonisation legislation.



Thanks!

BR

Amund



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Re: [PSES] Fw: FCC/ISED file change update

2023-08-29 Thread Charlie Blackham
Brian

 > I can't find the legal language in Part 15 that spells this out;  does 
anyone know?

It’s not in part 15 😊

Part 2.1043<https://www.ecfr.gov/current/title-47/section-2.1043> and FCC KDB 
178919


Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: Brian Gregory 
Sent: Tuesday, August 29, 2023 11:13 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Fw: FCC/ISED file change update


Good afternoon,

I'll repeat my earlier story and give the group an update.

We have made some small changes to our product (prominently to Y-caps, and some 
beads) which unfortunately did not increase our margin vs EMC limits, but the 
product still passes FCC and ISED.  Engineering wanted to use the 
self-declaration process to document these changes, including passing test 
results w/o going through the TCB and re-file process.  The changes do appear 
to classify for what CFR 47, Part 15 § 2.1043  call a class II permissive 
change, but it's just as certain that the original FCC and ISED ID's are still 
valid as the product is roughly the same, still passes emission limits and made 
no changes to the WiFi system (same chip, location, antenna, and firmware).

I've been told - by (a) an engineer from a well-known EMC/TCB, and (b) an 
engineer at a local EMC test lab -  that Class II permissive change only 
applies to intentional radiators.   I can't find the legal language in Part 15 
that spells this out;  does anyone know?

Does anyone want to confirm Engineering's assertion that SDoC will suffice?

Thanks,

Colorado Brian


Please note: forwarded message attached

From: David Schaefer 
mailto:david.schae...@element.com>>
To: Brian Gregory 
mailto:brian_greg...@netzero.net>>, 
"EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>" 
mailto:EMC-PSTC@LISTSERV.IEEE.ORG>>
Subject: RE: [PSES] Necessary Lab accreditations, class 2 permissible change
Date: Thu, 10 Aug 2023 15:42:24 +


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Re: [PSES] AW: [PSES] SV: [PSES] User manual by accompanying documents or via affixed QR

2023-08-14 Thread Charlie Blackham
Scott

Requirements on instructions to be in printed format are often included/implied 
in safety standards – for example EN 62368-1:2014:

F.4 Instructions
When information with regard to safety is required according to this standard, 
this information
shall be given in an instruction for installation or instruction for initial 
use. This information
shall be available prior to installation and initial use of the equipment.

The final sentence precludes safety instructions being embedded on the device

Article 10(8) of the RED states:

Manufacturers shall ensure that the radio equipment is accompanied by 
instructions and safety information in a language which can be easily 
understood by consumers and other end-users, as determined by the Member State 
concerned.

Section 2.6(j) of the RED Guide states:

The Blue Guide, in Chapter 3.1.4, provides more details on how the instructions 
and safety information need to be provided. According to the Blue Guide, whilst 
the safety information needs to be provided on paper, it is not required that 
all the set of instructions is also provided on paper but they can also be on 
electronic or other data storage format, however a paper version should always 
be available free of charge for the consumers who request it. It is noted that 
the information in Article 10.8 (second sub-paragraph) and Article 10.10, as is 
specifically required by the RED and not directly related with the general 
instructions of use, shall be provided in paper.

The practical application of this is a short printed guide shipped with the 
product.

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: Scott Xe 
Sent: Tuesday, August 15, 2023 6:27 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] AW: [PSES] SV: [PSES] User manual by accompanying documents 
or via affixed QR

Dear Bernd,

Thanks for your good references!  The LVD and RED do not decline the 
instructions in electronic format.  What about those instructions embedded in 
the ROM as the memory is not expensive as before?  For example, mobile phones, 
TVs, etc.

Regards,

Scott



On Mon, 14 Aug 2023 at 15:14, Dürrer Bernd 
mailto:bernd.duer...@wilo.com>> wrote:
Hi Amund,

In the European Union, it depends on the Directive that is applicable for your 
product. Both the Low Voltage Directive 2014/35/EU (L_2014096EN.01035701.xml 
(europa.eu)<https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32014L0035#d1e32-371-1>,
 Article 6, Point 7, Article 8, Point 4, and Article 9, Point 2) and the Radio 
Directive 2014/53/EU (Consolidated TEXT: 32014L0053 — EN — 27.12.2022 
(europa.eu)<https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:02014L0053-20221227#tocId84>,
 Article 10, Point 8, Article 12, Point 4, and Article 13, Point 2) require 
that manufacturers, importers, and distributors ensure that the product is 
accompanied by instructions and safety information. Only new regulation (EU) 
2023/1230 that will replace Machinery Directive in January 2027 allows to 
provide instructions in digital format (L_2023165EN.01000101.xml 
(europa.eu)<https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32023R1230&qid=1688119698228#d1e1695-1-1>,
 Article 10, Point 7).

Kind regards,

Bernd

Von: John Woodgate mailto:j...@woodjohn.uk>>
Gesendet: Sonntag, 13. August 2023 19:14
An: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Betreff: Re: [PSES] SV: [PSES] User manual by accompanying documents or via 
affixed QR

[EXTERNAL E-MAIL] This email originated from outside of the organization. Do 
not click links or open attachments unless you recognize the sender.

No. I don't see so many EU documents as others here do, and it is very 
difficult, as you know, to find a document when you don't know a document title 
to look for. I am remembering information posted here quite a long time ago.
On 2023-08-13 17:56, Amund Westin wrote:
Yes, I was thinking that a short paper guide would help. URL link is important 
as you say, and QR are actually for advanced mobile users.

Have you seen this issue been discussed in “Blue Guide” or other EU documents?




Fra: John Woodgate
Sendt: 13. august 2023 18:43
Til: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Emne: Re: [PSES] User manual by accompanying documents or via affixed QR


I believe that in Europe, it is not allowed. Current practice seems to be to 
include with the product a short  'User Guide' or similar, which includes the 
safety information required by the relevant safety standard, and the DOC(s), 
together with a text link of the URL of the full User Manual. You could include 
a QR code in addition, but not instead of the text link, because about 15 % of 
people don't have a smart phone or don't know much about using it for anything 
but call

Re: [PSES] Hazard warning labels on panel doors where COTS UPS installed?

2023-08-02 Thread Charlie Blackham
Doug

In the past I’ve worked on control cabinets used in Semi-Conductor plant 
equipment and this is an extract from an earlier version of SEMI S2 I have:

13.5 Uninterruptable Power Supplies (UPSs) — This section applies to UPSs with 
outputs greater than: 30 volts rms, 42.4 volts peak; 60 volts DC; or 240 
volt-amps.
13.5.1 Whenever a UPS is provided with the equipment, its location and wiring 
should be clearly described within the installation and maintenance manual.
13.5.2 Power from the UPS should be interrupted when any of the following 
events occur:
 the emergency off actuator (button) is pushed; or
 the main equipment disconnect is opened; or
 the main circuit breaker is opened.
EXCEPTION: Upon EMO activation, the UPS may supply power to the EMO circuit, 
safety related devices, and data/alarm logging computer systems as described in 
the exception clauses of § 12.2.
13.5.3 The UPS may be physically located within the footprint of the equipment 
provided that the UPS is within its own enclosure and is clearly identified.
13.5.4 The UPS should be certified by an accredited testing laboratory and be 
suitable for its intended environment (e.g., damp location, exposure to 
corrosives).
13.5.5 The UPS wiring should be identified as ‘UPS Supply Output’ or equivalent 
at each termination point where the UPS wiring can be disconnected.

We never put warning signs for UPS on the outside of the cabinet, but there 
were high voltage warning signs and detailed explanation within the manual.

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: Doug Nix 
Sent: Wednesday, August 2, 2023 10:24 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Hazard warning labels on panel doors where COTS UPS installed?

Colleagues,

I have a client who has installed a COTS UPS in an industrial control panel. 
The UPS is being used to keep the HMI alive in a power outage or if the 
disconnecting device is switched off.

I have scoured the resources that I have, and I can find nothing that requires 
a label on the outside of the panel to indicate that there is a UPS inside. EN 
60204-1:2018 does not address this. I have a copy of EN IEC 62040-1, and it 
does not require a hazard warning label anywhere.

Any guidance you might offer is appreciated.

Doug Nix
d...@ieee.org<mailto:d...@ieee.org>
+1 (519) 729-5704



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Re: [PSES] BBC news article re Li-ion batteries...

2023-07-28 Thread Charlie Blackham
Matthew

I think the issue is, again, one of enforcement – the UK General Product Safety 
Regulations impose requirements on both manufacturers and importers, so there 
is existing legislation that could be used.

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: Matthew Wilson | GBE 
Sent: Friday, July 28, 2023 10:11 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] BBC news article re Li-ion batteries...

I thought this news article that was on the BBC TV broadcast bulletins 27th 
July might be of interest.

“Batteries for e-bikes should be regulated in the same way as fireworks, heavy 
machinery or medical devices because of the fire risk they pose, a charity [UK 
based Electrical Safety First] has said”

https://www.bbc.co.uk/news/technology-66304564


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Re: [PSES] Woodgate's reply on residential Immunity field strength

2023-07-25 Thread Charlie Blackham
The residential level of 3m V/m was in IEC 1000-4-3 predates portable phones, 
WiFi, Bluetooth and all the other mobile and portable transmitters widely in 
use today.

The 20+ V/m field strengths in these standards are what is obtained from a 
cellular phone at maximum power, or WiFi device, at approximately 0.3 m / 1 ft.

Now, on live networks the 99% percentile transmit power of a cell phone is 
around 1% of maximum power, but that's not considered in safety standards such 
as SAR testing

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: Brian Gregory 
Sent: Monday, July 24, 2023 10:49 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Woodgate's reply on residential Immunity field strength


The reference for 20 V/m to EV chargers comes from UL 2231-2.  This is not a 
medical standard, but Annex A does call out the medical standard 60601-1-2 as a 
reference, as well as CENELEC 50204.  We can't figure out why;  cell phones 
produce less than half that, and our WiFi transmitter is probably 
representative, and is rated well under 1 W.  I could see a higher immunity 
standard as needed for commercial environments, say in a bank of 4-5 chargers.

Following along in 61000-4-3, we agree with John that residential applications 
are clearly best matched to the definition for Class 2 environment, and the 
table in Clause 5 says the limits for Class 2 equipment is 3 V/m.  20 V/m does 
not show up in Clause 5 of 61000-4-3 for any class.

So, I've should to reach out to a UL standards group and find out if this is 
really necessary for residential applications.   Our local lab can't do more 
than 10, and an overseas affiliated lab is similarly limited.  I'd like to know 
were this requirement comes from.   This is more a question for EV Charging 
safety than a mainstream EMC question.

As a backup, I could request a comment to Ken's point is if they define the 
peak of the modulation as 20 V/m.  I don't know where these are defined.

Thanks for all the detailed replies!

Colorado Brian
720-450-4933


-- Original Message --
From: John Woodgate mailto:j...@woodjohn.uk>>
To: Brian Gregory mailto:brian_greg...@netzero.net>>
Subject: Re: [PSES] Immunity test field strength, residential setting
Date: Fri, 21 Jul 2023 18:05:59 +0100

61000-4-3 is a Basic Standard. It does not specify test levels but indicates 
possible test levels. You need to look in detail at Clause 5, but look at these 
words:

 Product committees shall select the appropriate test level for each frequency 
range needing to be tested as well as the frequency ranges.

The residential environment is usually designated Class 2 (see Annex E of the 
standard), which calls for 3 V/m.
==
Best wishes John Woodgate OOO-Own Opinions Only
www.woodjohn.uk<http://www.woodjohn.uk>
Rayleigh, Essex UK

I hear, and I forget. I see, and I remember. I do, and I understand. Xunzi (340 
- 245 BC)
On 2023-07-21 17:44, Brian Gregory wrote:
 Hello colleagues,

We are building EV Chargers for residential markets (not just US) and one of 
the safety applicable standards is UL 2231-2.  It calls out  IEC 61000-4-3 for 
immunity testing parameters, which states a requirement for a field strength of 
20V/m.  Our EMC expert says typically testing is "done at 3 Vrms, which is 
standard for most products in residential environments."   He can only test up 
to 10V, and we're hearing the same from an overseas lab to whom our 
manufacturer refers.

Does FCC Part B have guidelines for field strength we can cite?   Can some 
offer this "DC guy" (aka, 60 Hz) a quick definition of what the 20V/m 
represents?

I'm guessing 20 V/m is for higher density commercial applications, aka charging 
stations, so we probably need an exception for residential.

Thank you!

Colorado Brian
720-450-4933


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To u

Re: [PSES] Stability

2023-07-23 Thread Charlie Blackham
Steve

Have a look at EN 61010-1 covers laboratory equipment and includes stability 
requirements.

EN 60204-1 only really covers electrical risks – so unless the equipment falls 
under the Machinery Directive, you should consider other standards to ensure 
requirements of LVD Annex I are met.

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: Steve Brody 
Sent: Saturday, July 22, 2023 8:52 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Stability

A client has a product which is a mobile cart intended for a laboratory setting 
in which it can be moved to whatever lab station it is needed at.  It is on 
casters and when wheeled to the working location, leveling feet which are 
located in the center of the castor mount, are lowered and locked into position 
to keep the cart from moving and to ensure it is level.

The product will be evaluated to EN 60204-1, but there is no reference to 
stability in this standard.

First question is should EN 61010-1, 7.4, be used to evaluate stability, and if 
not then what?

Assuming yes, the first sentence of 7.4 says; 'Equipment and assemblies of 
equipment not secured to the building structure before operation should be 
physically stable.'

Second question is does this section apply to the cart only when in position 
for use, or also when being moved from location to location?

Because when in use the cart is supported by [properly rated] feet, then the 
tests for castors should no longer apply?.

That is the third question.

Your thoughts and comments are requested and appreciated, as always.

Thanks,

Steve Brody
sgbr...@comcast.net<mailto:sgbr...@comcast.net>
C - 603 617 9116


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Re: [PSES] EU Machinery Regulation official version

2023-07-01 Thread Charlie Blackham
Brian

If you’ve not come across it already, I recommend joining the LinkedIn group 
“Machinery Safety, Regulations and Standards for CE/UKCA”   
https://www.linkedin.com/groups/3995029/

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: Brian Kunde 
Sent: Friday, June 30, 2023 6:54 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EU Machinery Regulation official version

Is there a good source of information on the application of this new directive? 
 Are there any good articles or summaries comparing the new directive to the 
old?  Are there implementation dates? Can we declare compliance to the new 
directive now, or are their other hurdles that need to be put into place?

Is there a source for good comments and discussion on this?  I have only just 
started to dig into it.

Thanks to all.
The Other Brian



On Thu, Jun 29, 2023 at 2:12 PM Lauren Crane 
<1afd08519f18-dmarc-requ...@listserv.ieee.org<mailto:1afd08519f18-dmarc-requ...@listserv.ieee.org>>
 wrote:
FYI – now published in the OJ -- 
https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32023R1230

Best Regards,
-Lauren


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Re: [PSES] Generic radio standard for aeronautical service

2023-06-14 Thread Charlie Blackham
Amund

Have a look at:
ETSI EN 302 617 V2.3.1 
ETSI EN 301 842-5 V2.1.1
ETSI EN 301 489-22 V2.1.1

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/ 
Registered in England and Wales, number 05466247

-Original Message-
From: Amund Westin  
Sent: Wednesday, June 14, 2023 2:03 PM
To: Charlie Blackham ; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: SV: [PSES] Generic radio standard for aeronautical service

Thanks Charlie

It's an ILS system. https://en.wikipedia.org/wiki/Instrument_landing_system
Currently, there are no existing ETSI/EN/IEC standards covering radio tests.

Only these German standards are in place:
https://www.bundesnetzagentur.de/SharedDocs/Downloads/DE/Sachgebiete/Telekommunikation/Unternehmen_Institutionen/Technik/InverkehrbringenvonProdukten/Schnittstellenbeschreibungen/FlugfunkFL/RegTPSSBFL012Id1461pdf.pdf;jsessionid=63D4A874EE9637C9B4A25A6C70EB23FF?__blob=publicationFile&v=4


Seems to a Technical File / Notified Body case ...

BR
Amund


-Opprinnelig melding-----
Fra: Charlie Blackham 
Sendt: 13. juni 2023 21:24
Til: EMC-PSTC@LISTSERV.IEEE.ORG
Emne: Re: [PSES] Generic radio standard for aeronautical service

Amund

The only "generic" radio standards are the ones for "short range devices", EN 
300 330, EN 300 220 and EN 300 440 and newer versions of those standards under 
development

A full list of all ETSI RED published and work-in-progress standards is 
available at

https://portal.etsi.org/webapp/WorkProgram/WorkItemPlan.asp?titleType=all&qSORT=HIGHVERSION&qETSI_ALL=&SearchPage=TRUE&qDIRECTIVE=2014%2F53%2FEU&qINCLUDE_SUB_TB=True&qINCLUDE_MOVED_ON=&qSTOP_FLG=N&qKEYWORD_BOOLEAN=OR&qCLUSTER_BOOLEAN=OR&qFREQUENCIES_BOOLEAN=OR&qSTOPPING_OUTDATED=&butExpertSearch=Search&includeNonActiveTB=FALSE&includeSubProjectCode=FALSE&qREPORT_TYPE=RPLAN&optDisplay=ALL

Note, this would only cover products using Civilian frequency bands.

It would be a bit surprising if there wasn't a standards either published ,or 
at least under development, for radio technology deployed on any real scale.

If there really isn't a Harmonised Standard available, you'll need to develop a 
compliance argument in a Technical File and use a Notified Body

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

-Original Message-
From: Amund Westin 
Sent: Tuesday, June 13, 2023 4:44 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Generic radio standard for aeronautical service

After some searching, we see that there is a lack of radio standards that cover 
an important ground-based product / system within aeronautical services.
How should we proceed with finding relevant test requirements? Are there any 
generic radio requirements that can be used as a basis?


BR
Amund

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Re: [PSES] Generic radio standard for aeronautical service

2023-06-13 Thread Charlie Blackham
Amund

The only "generic" radio standards are the ones for "short range devices", EN 
300 330, EN 300 220 and EN 300 440 and newer versions of those standards under 
development

A full list of all ETSI RED published and work-in-progress standards is 
available at

https://portal.etsi.org/webapp/WorkProgram/WorkItemPlan.asp?titleType=all&qSORT=HIGHVERSION&qETSI_ALL=&SearchPage=TRUE&qDIRECTIVE=2014%2F53%2FEU&qINCLUDE_SUB_TB=True&qINCLUDE_MOVED_ON=&qSTOP_FLG=N&qKEYWORD_BOOLEAN=OR&qCLUSTER_BOOLEAN=OR&qFREQUENCIES_BOOLEAN=OR&qSTOPPING_OUTDATED=&butExpertSearch=Search&includeNonActiveTB=FALSE&includeSubProjectCode=FALSE&qREPORT_TYPE=RPLAN&optDisplay=ALL

Note, this would only cover products using Civilian frequency bands.

It would be a bit surprising if there wasn't a standards either published ,or 
at least under development, for radio technology deployed on any real scale.

If there really isn't a Harmonised Standard available, you'll need to develop a 
compliance argument in a Technical File and use a Notified Body

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/ 
Registered in England and Wales, number 05466247

-Original Message-
From: Amund Westin  
Sent: Tuesday, June 13, 2023 4:44 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Generic radio standard for aeronautical service

After some searching, we see that there is a lack of radio standards that cover 
an important ground-based product / system within aeronautical services.
How should we proceed with finding relevant test requirements? Are there any 
generic radio requirements that can be used as a basis?


BR
Amund

-

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Re: [PSES] PLC password

2023-06-02 Thread Charlie Blackham
Lauren

The Right to Repair legislation only covers certain consumer products as per 
Annex II and doesn't cover machinery such as this.

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: Lauren Crane <1afd08519f18-dmarc-requ...@listserv.ieee.org>
Sent: Friday, June 2, 2023 5:33 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] PLC password

Hi Steve,

My Friday 2c...

There is a trend of "right to repair" legislation that might contraindicate 
that position to some extent. See e.g.  
https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52023PC0155

It seems odd that the approval of a product would depend on the whether the end 
user can modify the product or not. There isn't a certified item I have that I 
can't modify in some dangerous way. There is an important difference between 
de-certification of a product unit because it has been modified vs. 
de-certification of a product line because it can be modified.

Best Regards,
-Lauren

From: sgbrody mailto:sgbr...@comcast.net>>
Sent: Thursday, June 1, 2023 5:51 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: [PSES] PLC password



External Email: Do NOT reply, click on links, or open attachments unless you 
recognize the sender and know the content is safe. If you believe this email 
may be unsafe, please click on the "Report Phishing" button on the top right of 
Outlook.


I have been asked if there is a standard, or comments within s standard, that 
discusses giving a customer the password to allow them to reprogram the PLC 
when they remove a device and the light curtain that protected it.

I believe, that other than it being a terrible idea, that it would probably 
invalidate any approvals the end product had.

The customer is asking for a document that supports my opinion.

I dud suggest that we send a service person to do the change, and not give up 
the pw.

Thoughts?



Sent from my T-Mobile 5G Device

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Re: [PSES] EMC directive - does not apply ...

2023-05-30 Thread Charlie Blackham
Amund

My understanding is that "custom built evaluation kit" can be sold to an end 
customer - it doesn't sound like you are proposing this.

Article 17 of the EMCD requires that CE marking is affixed before it is placed 
on the market.

Article 2.3 of The Blue Guide covers your scenario which doesn't require CE 
marking:


Placing on the market is considered not to take place where a product is:

- transferred for testing or validating pre-production units considered still 
in the stage of manufacture;

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: Amund Westin 
Sent: Wednesday, May 31, 2023 7:10 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] EMC directive - does not apply ...


2014/30EU, article 2, This Directive shall not apply to:
(e) custom built evaluation kits destined for professionals to be used solely 
at research and development facilities for such purposes.


Does the statement accept that a manufacturer ship the product ( a prototype) 
to a professional partner, who will test the product within its own premises?


BR regards
Amund

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[PSES] US requirements for Electric Vehicle Chargers

2023-05-03 Thread Charlie Blackham
A client, who's an independent product design house, has been asked to assist a 
client to expand their product range into the US market and they are looking 
for "Insight into US technical/regulatory requirements around EV charging, 
smart consumer units/distribution boards, and other domestic electrical 
including regulations, certification processes, distribution channels for 
electrical equipment, install types and diversity in specific or across 
regions".

Is anyone on the list able to assist, or recommend someone who can?

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Mead House
Longwater Road
Eversley
RG27 0NW
UK
Tel: +44 (0)7946 624317
Email: char...@sulisconsultants.com<mailto:char...@sulisconsultants.com>
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247


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Re: [PSES] ESD standards for testing remotes

2023-04-27 Thread Charlie Blackham
Charles

Assuming it’s infrared only, EN 55035 would be a suitable product standard 
(Infrared remote controls are referenced as ancillary/support equipment for TVs 
in the informative Annex J)

A wireless remote would additionally be tested to EN 301 489-x, but the test 
levels are the same

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: Chas Grasso 
Sent: Thursday, April 27, 2023 11:24 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] ESD standards for testing remotes

Hello gurus!

Does anyone know of an official standard for ESD testing remotes used for TVs 
/STBs etc?

Thanking you in advance!!


--
Charles Grasso
Dish Technologies
 (c) 303-204-2974
(w) 303-706-5467
(h) 303-317-5530
(e ) charles.gra...@dish.com<mailto:charles.gra...@dish.com>
(e2) chasgra...@gmail.com<mailto:chasgra...@gmail.com>
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Re: [PSES] Safety shutters in BS 13A socket

2023-04-23 Thread Charlie Blackham
I don’t have a copy of the standard, but I’m fairly sure this is all detailed 
in:

BS 1363-2:2016+A1:2018
13 A plugs, socket-outlets, adaptors and connection units - Specification for 
13 A switched and unswitched socket-outlets

It’s a BSI standard, so it’s expensive !

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: Scott Xe 
Sent: Friday, April 21, 2023 3:09 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Safety shutters in BS 13A socket

BS 13A sockets are designed with a safety shutter to prevent accidental contact 
with live electrical contacts. According to the BS standard, the shutters for 
the live (L) and neutral (N) apertures must block securely. Is there any 
verification test available to ensure that the shutters for the L and N 
apertures meet this required safety standard?

Thanks and regards,

Scott
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Re: [PSES] [EXTERNAL] Re: [PSES] EU and UK DoC

2023-03-01 Thread Charlie Blackham
Dan

You might not have had it rejected, but there’s no way to be 100% sure that it 
has been, and always will be excepted – it could just be because no one has 
taken a detailed look.

Some market enforcement agencies have rejected DoCs for, in their view, 
incorrect spaces – a specific example:


EN 60335-1:2012+A11:2014+A13:2017+A1:2019+A2:2019+A14:2019 was accepted by a 
German Regulator.
But EN 60335-1:2012 + A11:2014 + A13:2017 + A1:2019 + A2:2019 + A14:2019 was 
not.

I would normally say “you couldn’t make this up” – you can’t – it’s true !!

As others have noted, the declaration phrase on the CE and UKCA DoCs are 
different, so I would recommend against combining them as it gives a market 
regulator an angle to attack your DoC, and an “administrative non-compliance” 
opens you up to impounding and/or audit testing at your expense.

I would suggest a better alternative would be to have one PDF document, that 
contained several pages, each one with a DoC for a separate jurisdiction, such 
as 3 pages for example, one each for EU, UK and Aus.


Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: Dan Roman <0d75e04ed751-dmarc-requ...@listserv.ieee.org>
Sent: 01 March 2023 21:09
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [EXTERNAL] Re: [PSES] EU and UK DoC

We’ve been combining both onto one document.  It sometimes makes the document 
go to a second page because of the extra information.  We include Australia and 
anywhere else that will take a DoC into one document as well.  Haven’t had it 
rejected by anyone yet.

Dan


From: Andres Waszczenko 
[mailto:1fcfb5f9b1f4-dmarc-requ...@listserv.ieee.org]
Sent: Wednesday, March 1, 2023 3:31 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: Re: [PSES] [EXTERNAL] Re: [PSES] EU and UK DoC

Hello Peter,

I have been working with Mike and I too concur with his answer. The EU and the 
UKCA are not the same entities. At a minimum, two different addresses are 
needed to identify the authorize representatives, hence the cleanest approach 
is two different declarations of conformity (DoC). Just a thought.

Also note due to the short timeline that was provided by the Brexit separation. 
The UKCA authorities chose to initially use the same set of harmonized 
standards that the EU is using but that is more that likely to change. Also, as 
Mike mentions, the terminology in the body of the DoCs does vary. The 
references used are different between the UKCA and the EU.

Regards,
  Andres

Andres Waszczenko
Sr. Product Safety & Compliance Specialist
Entrust Datacard
1187 Park Place
Shakopee MN, 55379
952-933-0768
andres.waszcze...@entrust.com<mailto:andres.waszcze...@entrust.com>

[cid:image001.png@01D94C8B.25868BC0]


From: MIKE SHERMAN mailto:msherma...@comcast.net>>
Sent: Wednesday, 1 March, 2023 2:18 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: [EXTERNAL] Re: [PSES] EU and UK DoC

WARNING: This email originated outside of Entrust.
DO NOT CLICK links or attachments unless you trust the sender and know the 
content is safe.

Yes, that is what we concluded.
In addition, there is some other terminology that differs between the two that 
your client might have to deal with.
Mike
Sherman PSC LLC
On 03/01/2023 1:29 PM 
06cee064502d-dmarc-requ...@listserv.ieee.org<mailto:06cee064502d-dmarc-requ...@listserv.ieee.org>
 wrote:


Hello Group,

I have a client that wishes to use a single DoC for both EU (CE) and UK (UKCA). 
He has figured out everything except one area and that is the address/location 
for signature. Does he have to have two addresses shown on the DoC for 
signature? One in EU and one in UK?


Thanks
Peter























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Re: [PSES] Non-NRTL Field Inspection Service Provider in the Michigan / Midwest Region

2023-02-23 Thread Charlie Blackham
Rich

I’m looking at a similar project myself

>The FEB must be acceptable to the AHJ in the region where the equipment is to 
>be installed.

Are there published lists anywhere, or is it a case of asking the relevant AHJ?

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: Richard Nute 
Sent: 22 February 2023 23:33
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Non-NRTL Field Inspection Service Provider in the Michigan 
/ Midwest Region


Hi Carl:

I’m not able to identify candidate FEBs as you requested.  Most NRTLs, small to 
large, also are FEBs.  I only found one accredited FEB who wasn’t an NRTL, SGS 
in Switzerland (a very big company).

Here is a good and complete (straight-forward) explanation of the field 
inspection service in the USA and Canada:

https://metlabs.com/services/on-site-field-testing-and-evaluation/field-inspection-frequently-asked-questions/

Here is one of the field evaluation body, FEB, accreditation schemes:

https://www.iasonline.org/services/field-evaluation-bodies/

The FEB must be acceptable to the AHJ in the region where the equipment is to 
be installed.

Rich


From: emcl...@gmail.com<mailto:emcl...@gmail.com> 
mailto:emcl...@gmail.com>>
Sent: Wednesday, February 22, 2023 2:16 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: [PSES] Non-NRTL Field Inspection Service Provider in the Michigan / 
Midwest Region

A friend asked me if I could refer him to a field inspection service provider 
for computer/ITE products intended for use within factory environments.  I'm 
aware that the major NRTLs offer this service apart from their NRTL 
accreditation, so I'm asking for other referrals for smaller service providers.

The scope is for USA and Canadian installations and this company would like 
that source to provide engineering review of the product in question in advance 
of the inspection, as well as the inspection itself and tag as needed.

Thanks in advance,

Carl
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Re: [PSES] Adding more than one EUT

2023-02-19 Thread Charlie Blackham
Derek

The EMC Directive requires the manufacturer to perform an "an adequate analysis 
and assessment of the risk(s)." (Annex II, module A, para 3)

That risk assessment has to consider foreseeable use.

It's for the manufacturer to decide, but if I was advising them, then I would 
suggest that maybe testing 3 combinations would cover it:
- minimum number of supported lights
- maximum number
- approx. 50% load

So, in this example, 1, 8 and 4 or 5.

Ultimately though, It's the manufacturer's responsibility to make the call.

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/ 
Registered in England and Wales, number 05466247

-Original Message-
From: Lfresearch <00734758d943-dmarc-requ...@listserv.ieee.org> 
Sent: 17 February 2023 20:21
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Adding more than one EUT

Hi folks,

I’ve been asked to test a light fixture that has the ability to be daisy 
chained up to 8 units.

When I run conducted emissions, I’m wondering if I need to insist on having 8 
units plugged in at once i.e. fully populated, OR, can I just test one fixture 
at a time since that’s how the system is likely to be used also..

Is there a legal requirement or precedent on how this should be tested as I’m 
going round in circles arguing with myself here.

Thanks,

Derek.

SSCLabs,
Reno, NV.
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Re: [PSES] Egypt Customs Requirements for Electronic Equipment

2023-02-15 Thread Charlie Blackham
Brian

The manufacturer can sign the DoC, but I think they are looking for the 2nd 
point in MD Annex II:

The EC declaration of conformity must contain the following particulars:
1. business name and full address of the manufacturer and, where appropriate, 
his authorised representative;
2. name and address of the person authorised to compile the technical file, who 
must be established in the Community;

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: Brian Kunde 
Sent: 14 February 2023 21:55
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Egypt Customs Requirements for Electronic Equipment


I have a piece of Electronic Equipment (laboratory equipment declared under the 
Machinery Directive) being held up in Egypt Customs. They say they accept the 
CE marking and EU-DoC but the DoC has to be signed by some authority other than 
the Manufacturer.  What does that mean?

Does anyone know what I have to do?

Thanks,
The Other Brian
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Re: [PSES] USB Type C requirements for the EU

2023-02-14 Thread Charlie Blackham
Cecil

The Regulation contains a list of products within scope.

The EU has moved away from publishing formal guidance on interpretation of 
Directives and Regulations, so it’s up to the manufacturer to determine whether 
or not a particular product is in or out of scope.

My recommendation is to document that decision process so you can fall back on 
it if challenged and review it at a future date in case any new information 
comes to light

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: cgitt...@rochester.rr.com 
Sent: 14 February 2023 16:54
To: Charlie Blackham 
Cc: 'EMC-PSTC@LISTSERV.IEEE.ORG' 
Subject: Re: [PSES] USB Type C requirements for the EU

Hi Charlie,

 Does head worn display falls into the following categories or classes of 
radio equipment in the Directive (EU) 2022/2380?

I appreciate any input.

Best Regards

Cecil

-----
From: "Charlie Blackham"
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Cc:
Sent: Monday February 13 2023 3:41:54AM
Subject: Re: [PSES] USB Type C requirements for the EU
Cecil

Directive (EU) 2022/2380<https://eur-lex.europa.eu/eli/dir/2022/2380> amending 
the RED with the "common charger" published on 7th December 2022

Applies to all products in scope placed on the market after 28 December 2024 
except for laptops, where the date is 28 April 2026

EU Directive and Regulations apply to each and every individual product, so 
there is no grandfathering for existing designs.


Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: cgitt...@rochester.rr.com<mailto:cgitt...@rochester.rr.com> 
mailto:cgitt...@rochester.rr.com>>
Sent: 13 February 2023 01:13
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: [PSES] USB Type C requirements for the EU

What is the implementation date for USB Type C that products need to comply 
with the Directive?

Is there any exemption or grandfathering for current products that are used 
already in the market?

I appreciate any input.

Thank you.

Cecil Gittens
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Re: [PSES] USB Type C requirements for the EU

2023-02-13 Thread Charlie Blackham
Cecil

Directive (EU) 2022/2380<https://eur-lex.europa.eu/eli/dir/2022/2380> amending 
the RED with the "common charger" published on 7th December 2022

Applies to all products in scope placed on the market after 28 December 2024 
except for laptops, where the date is 28 April 2026

EU Directive and Regulations apply to each and every individual product, so 
there is no grandfathering for existing designs.


Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: cgitt...@rochester.rr.com 
Sent: 13 February 2023 01:13
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] USB Type C requirements for the EU

What is the implementation date for USB Type C that products need to comply 
with the Directive?

Is there any exemption or grandfathering for current products that are used 
already in the market?

I appreciate any input.

Thank you.

Cecil Gittens
-


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Re: [PSES] Appropriate reference for EN standard within CB Report

2023-02-06 Thread Charlie Blackham
Carl

The OJ summary lists amendments separately, as published, it does not list 
“standard plus amendment(s)” as you typically write on a DoC

The relevant legislation for this change EN 61010-1 is Commission Implementing 
Decision (EU) 
2020/1779<https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=uriserv%3AOJ.L_.2020.399.01.0006.01.ENG&toc=OJ%3AL%3A2020%3A399%3ATOC>
 of 27 November 2020

EN 61010-1:2010 ceased to provide a presumption of conformity on 30th May 2022

In order to maintain presumption of conformity, A1:2019 must also be applied 
(along with AC:2019, but that doesn’t need to be listed on the DoC)

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: emcl...@gmail.com 
Sent: 06 February 2023 14:18
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Appropriate reference for EN standard within CB Report

Hello All,

I've included a snip here and I don't recall whether the list server will allow 
that so I'll also include the text.

I checked on the revision status of EN 61010-1 within the OJ and I'm confused 
because the current reference includes the withdrawn revision.  EN 61010-1:2010 
was withdrawn as of 30/11/2020 but it's also included within the current 
reference as follows:

EN 61010-1:2010,
EN 61010-
1:2010/A1:2019/AC:2019-04,
EN 61010-1:2010/A1:2019

[cid:image001.png@01D93A58.94420CF0]

Is this due to the long-standing CENELEC confusion?
Does this mean that all of these references belong on a manufacturers DoC?  Or 
any one of them?  (e.g. EN 61010-1:2010/A1:2019/AC:2019-04)  Does this mean 
that the original EN 61010-1:2010 is still allowed without the addition of 
A1:2019?

I'm reviewing a draft CB report and I want to get the "EN" reference within the 
report to line-up with this requirement if possible.

Thanks,

Carl
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Re: [PSES] EN 62368-1 : 2014

2022-12-07 Thread Charlie Blackham
Scott

My understanding is that the extension is purely so that there is not an 
expired standard listed in the OJ for the LVD – that’s all

There is no legal link between the dates in a standard and compliance with a 
Directive

A manufacturer is free to use whatever standards they wish for compliance with 
LVD and article 3.1(a) of the RED, but only Harmonised Standards currently 
listed in the OJ provide a Presumption of Conformity

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: Scott Xe 
Sent: 07 December 2022 16:43
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] EN 62368-1 : 2014

CENELEC recently extended DoW for 18 months from 06/01/2023 to 06/07/2024.  
What are the impacts on importers/manufacturers, test houses and market 
surveillances?

EN 62368-1 : 2014 is still valid for LVD/RED in EUOJ.  All the relevant 
products should follow this version for EU markets.  What is the point of this 
change to them?

In general the test houses give unclear interpretations to their clients in 
this aspect.  Sometimes, they follow EUOJ requirements but sometimes CENELEC.  
Some importers/manufacturers also confuse which requirements to follow.  Some 
countries also may not adopt the latest IEC/EN standard as their national 
standards.  Can't withdrawn standards be used?

Thanks and best regards,

Scott
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Re: [PSES] Regulation vs Directive

2022-12-06 Thread Charlie Blackham
Scott

A Directive has to be transposed into the law of each member state

A Regulation applies without the need to do this

Types of legislation 
(europa.eu)<https://european-union.europa.eu/institutions-law-budget/law/types-legislation_en>

The EU is moving towards Regulations as they are binding without member states 
needing to implement national law

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: Scott Xe 
Sent: 06 December 2022 15:51
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Regulation vs Directive

Dear All,

Some of the new proposals of Directive change the Directive to Regulation such 
as General Product Safety Regulation, Packaging and Packaging Waste Regulation, 
Portable battery regulation, etc, .  What are the key differences between 
Regulation and Directive?

Thanks and regards,

Scott
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Re: [PSES] SV: [PSES] Link to secondary legislation draft RE: [PSES] SI amendment providing UKCA label deadline extension.

2022-11-25 Thread Charlie Blackham
Amund

At the bottom of this page https://www.gov.uk/guidance/using-the-ukca-marking

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: Amund Westin 
Sent: 25 November 2022 08:02
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] SV: [PSES] Link to secondary legislation draft RE: [PSES] SI 
amendment providing UKCA label deadline extension.

Sorry if I have missed that information, but where can I find requirements for 
the UKCA logo which shall be affixed to the product. Need the check out the 
shape, minimum size, etc. Just like the CE logo has requirements.

Thanks!

BR
Amund



Fra: Lauren Crane
Sendt: 16. november 2022 16:41
Til: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Emne: [PSES] Link to secondary legislation draft RE: [PSES] SI amendment 
providing UKCA label deadline extension.

Hello All,

In case you are interested in seeing it is more concretely true, here is a link 
to the secondary legislation laid before parliament that is a proposal to 
modify many (most/all) of the UKCA SI's with the extended date. Click on "full 
wording" top left, to see the draft.

https://statutoryinstruments.parliament.uk/instrument/Iej3CpFt/

Best Regards,
-Lauren

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Re: [PSES] EN 62368-1 Ed 3 2020 + A11 : 2020 for GPSD

2022-11-21 Thread Charlie Blackham
Richard

My understanding is that CENELEC have just voted and decided to extend the DOW 
of EN 62368-1:2020 to 2024-07-06

As an aside, when selecting standards for CE/UKCA marking (as opposed to IEC CB 
scheme or similar), it is the manufacturer's responsibility to decide what 
version of the standard to test and not the labs - the lab may of course 
advise, but it remains the manufacturer's responsibility and the rationale 
should be documented in their risk assessment

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: Richard Georgerian 
Sent: 21 November 2022 18:01
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] EN 62368-1 Ed 3 2020 + A11 : 2020 for GPSD

Greeting everyone,

To continue this thread -

At the CENELEC website: 
https://standards.cencenelec.eu/dyn/www/f?p=CENELEC:110:FSP_PROJECT,FSP_ORG_ID:66779,1257189&cs=11C3AC4F515A1C6989CA85C0ED445BC0B,
 it has the schedule for the adoption of EN IEC 62368-1:2020/A11:2020 3rd 
Edition. However, it is not in the latest OJ, only EN 62368-1:2014. My 
estimation, is that test labs will use EN IEC 62368-1:2020/A11:2020 after 
January 6, 2023 in their test reports. And EN 62368-1:2014 remains valid until 
the product changes such that the safety report is to be updated with an 
alternate construction. Not sure how this will affect current products using EN 
62368-1:2014 2nd Edition after January 6, 2023. There is still indications that 
the 3rd Edition will not be adopted and Europe will go straight to the 4th 
Edition. My presumption is that when the EN 62368-1:2014 is superseded by EN 
IEC 62368-1:2020/A11:2020, but the OJ has not been updated, there is going to 
be a some confusion.

In short, if test labs are going to test to EN IEC 62368-1:2020/A11:2020 3rd 
Edition and EN 62368-1:2014 2nd Edition is still the listed in the OJ and EN 
IEC 62368-1:2020/A11:2020 3rd Edition is not listed in the OJ, do we need to 
write a risk assessment? The EU DoC would still use EN 62368-1:2014 2nd Edition 
and also have EN IEC 62368-1:2020/A11:2020 3rd Edition. Can the safety report 
also state in addition to meeting EN IEC 62368-1:2020/A11:2020 3rd Edition, the 
product still complies to EN 62368-1:2014 2nd Edition. Having both in the test 
report and certificate will be for those countries that have not yet adopted 
3rd Edition and still want to see a valid report/certificate with EN 
62368-1:2014 2nd Edition.

Is there a URL to find the Implementing Decisions regarding EN 62368-1?

As always, guidance and assistance is most appreciated.

Thank-you,

...Richard Georgerian
Compliance Engineer
HID Global

From: Charlie Blackham 
mailto:char...@sulisconsultants.com>>
Sent: Thursday, September 1, 2022 3:26 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: Re: [PSES] EN 62368-1 Ed 3 2020 + A11 : 2020 for GPSD

Dan

Just a reminder that the Summary Lists are not "formal listings" - there have 
been mistakes in some of them, so whilst they are useful, it is important to 
check the referenced Implementing Decisions

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: Dan Roman 
<0d75e04ed751-dmarc-requ...@listserv.ieee.org<mailto:0d75e04ed751-dmarc-requ...@listserv.ieee.org>>
Sent: 01 September 2022 20:46
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: Re: [PSES] EN 62368-1 Ed 3 2020 + A11 : 2020 for GPSD

Hi Bostjan,

That is the older one without the new standards added recently.  But yes, I am 
looking for that but the up to date version!

Dan


From: Boštjan Glavič [mailto:bostjan.gla...@siq.si]
Sent: Thursday, September 01, 2022 1:11 PM
To: Dan Roman mailto:danp...@verizon.net>>; 
EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: Re: [PSES] EN 62368-1 Ed 3 2020 + A11 : 2020 for GPSD

Hi Dan


Are you looking for this?

Best regards
Bostjan
SIQ Ljubljana


https://ec.europa.eu/docsroom/documents/43968/attachments/1/translations/en/renditions/native

Dobite Outlook za Android<https://aka.ms/AAb9ysg>

From: Dan Roman 
<0d75e04ed751-dmarc-requ...@listserv.ieee.org<mailto:0d75e04ed751-dmarc-requ...@listserv.ieee.org>>
Sent: Thursday, September 1, 2022 6:34:33 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
mailto:EMC-PSTC@LISTSERV.IEEE.ORG>>
Subject: Re: [PSES] EN 62368-1 Ed 3 2020 + A11 : 2020 for GPSD


CAUTION: This email originated from outside of our organisation. Do not click 
links or open attachments unless you recognise the sender and know the content 
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Anyone know if (and where) the consolidated GPSD list of harmonized standards 
is published?  When I look all

Re: [PSES] SI amendment providing UKCA label deadline extension.

2022-11-14 Thread Charlie Blackham
All

This relaxation has been trailed / announced, but it is not law until the 
Statutory Instrument has been published on https://www.legislation.gov.uk/ 
(it’s not there at time of typing)

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: Tom Smith 
Sent: 14 November 2022 17:37
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] SI amendment providing UKCA label deadline extension.

An announcement was made this morning extending allowance for using the CE 
marking for an additional 2 years until Dec 31, 2024.
https://www.gov.uk/government/news/businesses-to-be-given-uk-product-marking-flexibility
Regards,
Tom Smith, P.Eng
Principal Engineer
TJS Technical Services Inc.
Tel: +1 403-612-6664
Email: tsm...@tjstechnical.com<mailto:tsm...@tjstechnical.com>
http://tjstechnical.com<http://tjstechnical.com/>
Follow us on Twitter: TJS_Technical

From: Scott Xe mailto:scott...@gmail.com>>
Sent: November 14, 2022 9:30 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: Re: [PSES] SI amendment providing UKCA label deadline extension.

Dear Scott & Lauren,

Today, I received the following info to supplement the above development.

"Some news from the Department for Business, Energy and Industrial Strategy 
(BEIS):-

HMG intends to introduce legislation to continue recognition of the CE marking 
and reversed epsilon marking until 31 December 2024 for most goods being placed 
on the market or put into service in Great Britain as part of new ministers’ 
commitment to reduce burdens for industry.

This package of measures is intended to provide businesses with more 
flexibility and reduce burdens for businesses. We will use our regulatory 
autonomy to help businesses navigate the current global economic and supply 
chain challenges whilst prioritising growth.
 In parallel, we will also consider how we could reduce costs and burdens 
associated with the UK regulatory framework in the longer-term, including 
opportunities under the Product Safety Review.

We also intend to introduce legislation to give effect to the measures 
previously announced in June 2022 with amended timescales, in line with the 
extension.  These measures intend to:

• Reduce labelling costs by continuing to allow businesses to affix 
the UKCA marking, and to include importer information for products from EEA 
countries (and in some cases, Switzerland) on an accompanying document or a 
label until 31 December 2027.

• Reduce re-testing costs for UKCA certification by allowing 
conformity assessment activities for CE marking undertaken by 31 December 2024 
to be used by manufacturers as the basis for UKCA marking, until the expiry of 
the certificate or until 31 December 2027, whichever is sooner."

Cheers,

Scott

On Sat, 12 Nov 2022 at 05:55, Scott Aldous 
<0220f70c299a-dmarc-requ...@listserv.ieee.org<mailto:0220f70c299a-dmarc-requ...@listserv.ieee.org>>
 wrote:
Hi Lauren,

It's a good question. A draft amendment was published on 6 September to effect 
the extension, but the draft was withdrawn on 10 October, stating that "a new 
version will be published in due course". More information 
here<https://www.gov.uk/eu-withdrawal-act-2018-statutory-instruments/the-product-safety-and-metrology-amendment-regulations-2022>.

ExVeritas published an article on this on 3 November (in the context of ATEX 
Directive but generally applicable). You can find that article 
here<https://www.exveritas.com/2022/11/03/proposed-ukca-ex-atex-legislation-changes-withdrawn/>.
 Unfortunately the article doesn't give much more information.

On Wed, Nov 9, 2022 at 11:14 AM Lauren Crane 
<1afd08519f18-dmarc-requ...@listserv.ieee.org<mailto:1afd08519f18-dmarc-requ...@listserv.ieee.org>>
 wrote:
Hello All,

Among all the UKCA discussion I have not noticed information on whether the 
promised no-label extension to 2026, though promised on government websites, is 
actually in the works with hope of becoming law before Jan 1, 2023.

Does anyone have information on this point?

Best Regards,
-Lauren


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Re: [PSES] EU harmonised standard of EN 62368-1 Ed3 : 2020 for General Product Safety Directive

2022-11-01 Thread Charlie Blackham
Scott

I’m fairly certain that EN 62368-1:2014 was never listed under the GPSD – only 
the LVD – 60065 and 60950 remained listed.

The listing of the 2020 version of 62368-1 is accompanied by the following 
“whereas”:

By letter M/452 of 28 September 2009, the Commission made a request to the 
European Committee for Electrotechnical Standardization (‘Cenelec’) to draw up 
European standards for personal music players. On the basis of this request, 
Cenelec adopted standard EN IEC 62368-1:2020 on ‘Audio/video, information and 
communication technology equipment – Part 1: Safety requirements’ and, further 
to that, the amendment EN IEC 62368-1:2020/A11:2020. EN IEC 62368-1:2020 is 
proposed with its amendment A11:2020, which complies with the general safety 
requirement set out in Directive 2001/95/EC. Its reference should be published 
in the Official Journal of the European Union replacing the references EN 
60065:2002 ‘Audio, video and similar electronic apparatus – Safety 
requirements’ and EN 60950-1:2006 ‘Information technology equipment – Safety -- 
Part 1: General requirements’. However, the publication of those references 
should be limited to the clauses 3.3.19 ‘Sound exposure’ and 10.6 ‘Safeguard 
against acoustic energy sources’, given that the purpose of Commission Decision 
2009/490/EC is limited to ensuring that exposure to sound from personal music 
players does not pose a risk to hearing.

And the listing states
Notice: this publication concerns only clauses 3.3.19 “Sound exposure” and 10.6 
“Safeguard against acoustic energy sources” of EN IEC 62368-1:2020/A11:2020.

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: Scott Xe 
Sent: 01 November 2022 14:45
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] EU harmonised standard of EN 62368-1 Ed3 : 2020 for General 
Product Safety Directive

Dear All,

On 16 Aug 2022, OJEU listed EN 62368-1 2020 without a deadline of an 
enforcement date.  Normally it will have a transitional period of 18 or 24 
months.  Does it mean to take effect immediately without a transitional period 
from EN 62368-1 Ed2 : 2014 to EN 62368-1 Ed 3 : 2020?



Thanks and regards,

Scott
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Re: [PSES] List of Common Misuses

2022-10-05 Thread Charlie Blackham
I’m not a lawyer, or from the USA, but in Europe the term “misuse” has been 
discussed in various REDCA (Radio Equipment Directive Compliance Association) 
Meetings with Notified Bodies and The EU Commission, and their view is that 
there’s no such thing as “misuse”, it’s just “use”.

Drawing up a list of possible “misuses” is ultimately futile, as where do you 
draw the line – user manuals instructions telling you not to use a telephone in 
the bath morph into statements telling you not to use a PBX in the bath.

My suspicion as an Engineer, is that some companies want great long lists of 
“do not do X” in the manual as some form of defence against mitigation by 
Darwin Awards nominees – but then you finish up with a manual so big that no 
one reads it anyway

Just my 2p / 2c

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: MIKE SHERMAN 
Sent: 05 October 2022 19:09
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] List of Common Misuses

Brian --

Good to hear from you!

Re your question, it is not clear who the "they" is who is requesting a list of 
misuses.

From my working experience, we (on advice of Legal) usually did not try to 
compile a list of misuses in the operating manual, on the theory that if a 
creative user found another (dangerous) misuse that was not on our list, they 
might conclude that it must be safe because it wasn't on our misuse list. We 
emphasized how to use our equipment correctly, and what the scope of its 
applications were.

However, we would clearly identify in some warnings what not to do where we 
perceived that to be a foreseeable misuse.

Hope this helps!

Mike Sherman
Sherman PSC LLC
On 10/05/2022 1:01 PM Brian Kunde 
mailto:bkundew...@gmail.com>> wrote:


My company manufactures Laboratory Equipment such as analyzers and 
determinators. They are highly specialized equipment, yet have an infinite 
range of uses.

Even though all known residual risks are documented in the Safety Warning 
section of the manual, they will commonly request a list of Misuses.  There are 
no buttons, or settings that can be changed by the User that can cause a 
hazard.  The operational environment is clearly defined. So in most all cases, 
I am not aware of any "Misuse" that can cause a hazard. For some reason, this 
answer is not acceptable.  We are expected to come up with something.

Is there a standard or common list of MisUses that seem to satisfy this 
requirement?

How crazy are we to get with this?, e.g., don't use the 400lb analyzer while 
taking a bath?  Don't use it to mow your lawn?  Common

I used to work for a computer company and I couldn't believe the stupid 
warnings we had to put in the manual.

Thanks to all.

The Other Brian
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All e

Re: [PSES] Wearables and UL 62368 vs UL 964 Electrically Heated Bedding

2022-10-05 Thread Charlie Blackham
John

The device might use a battery, but I would have thought that IEC 60335-1 and 
IEC 60335-2-17 would be better standards to apply considering their scope:

IEC 60335-2-17:2012+A1:2015+A2:2019 deals with the safety of electric blankets, 
pads, clothing and other flexible appliances that heat the bed or human body, 
for household and similar purposes, their rated voltage being not more than 250 
V. This standard also applies to control units supplied with the appliance. 
Appliances not intended for normal household use but which nevertheless may be 
a source of danger to the public, such as appliances intended to be used in 
beauty parlours or by persons in cold ambient temperatures, are within the 
scope of this standard…

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: John Allen 
Sent: 05 October 2022 16:18
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Wearables and UL 62368 vs UL 964 Electrically Heated Bedding

Hi,

I hope everyone is well and happy 😊.

I’m hoping I can get some input on my thinking for a heated garment powered by 
a battery pack.


  1.  The heater is insulated.
  2.  The fabric it is in contact with is combustible.
  3.  The circuit is PS2 – 16W
  4.  I read UL 62368 Clause 6.4.5.2 as the fabric must not ignite under a 
single fault and it must be UL 94VTM.  Am I correct?

Also, in researching other “fabric” products, I found UL 964 Electrically 
Heated Bedding.  Following is a summary of how they manage fabric and heating 
elements –


  1.  Sec. 6 Covering of Electrical Parts – All electrical parts shall be 
covered (except the connector attached to the bedding) with a “shell” or other 
fabric with no openings.
  2.  The heating element shall not be in direct contact with the shell.  It 
shall be insulated with UL AWM.
  3.  There shall not be any sharp edges in contact with the shell.
  4.  There is a very elaborate flammability test on the shell.  Wash it in 
special soap, let it dry then flame test it.  It does not seem equivalent to UL 
94 testing.
  5.  There’s also an “Ease of Ignition” test with a hot plate.

Is UL 62368 missing some requirements in regard to Wearables that are made of 
fabric??
Wearable Technology Standards:

  *   Wellness or Non-Medical Wearable: IEC/UL 62368-1
https://www.ul.com/services/wearable-technology-testing-and-certification

I would appreciate any input you can provide.

Best Regards and Be Safe,

John


John Allen | President & CEO | Product Safety Consulting, Inc.
Your Outsourced Compliance Department®
630-238-0188, Cell: 630-330-3145
[1496245974387_PSC]
www.productsafetyinc.com<http://www.productsafetyinc.com/>


John Allen | IEEE Product Safety Engineering Society
President 2016-2019, Past President 2020-2021, BoG Director at Large 2020-2023
Chairman – Compliance 101 Technical Committee
IEEE Senior Member

Keeping our members informed and educated on Product Safety and Certifications
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Re: [PSES] Cybersecurity?

2022-10-03 Thread Charlie Blackham
Some more information on Commission Delegated Regulation (EU) 
2022/30,<https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=uriserv%3AOJ.L_.2022.007.01.0006.01.ENG&toc=OJ%3AL%3A2022%3A007%3ATOC>:


European Standards Organisations (ESOs) are proposing to create 3 harmonised 
standards to meet the new EU RE-Direct Cybersecurity requirements under Art 3.3 
d), e) f):



· Common security requirements for internet connected radio 
equipment



· Common security requirements for equipment processing 
data (internet connected radio equipment, childcare radio equipment, toys radio 
equipment and wearable radio equipment)



· Common security requirements for internet connected radio 
equipment processing virtual money/monetary value



These new standards will be based on the applicable parts of the following 
existing standards:

  *   EN 303 645 (consumer)
  *   IEC 62443-4-2 (industrial)

These new requirements will become mandatory from 1st August 2024

The timescales are such that these is insufficient time for standards to be 
written and published in the EU OJ, so a Notified Body will be mandatory for 
any radio equipment within scope.

There are a number of sources of additional information, but there is more 
information in this article Delegated Regulation Cybersecurity RED Article 3.3 
| Element<https://www.element.com/nucleus/2022/cybersecurity-and-the-red>, and 
in a webinar recording that can be watched after free registration 
https://register.gotowebinar.com/register/2306105117227103244


Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: MIKE SHERMAN 
Sent: 03 October 2022 21:28
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Cybersecurity?

Oh, I just learned something about that:

Requirements coming in under Article 3.3 (d) (e) and (f) of RED (Radio 
Equipment Directive), and effective August 1, 2024.  See EU Delegated 
Regulation 2022/30.

Mike Sherman
Sherman PSC LLC
On 10/03/2022 3:24 PM Chris Brown 
<1ca53b7356f5-dmarc-requ...@listserv.ieee.org<mailto:1ca53b7356f5-dmarc-requ...@listserv.ieee.org>>
 wrote:


Doug,

Yes, the EU has a new cybersecurity requirement for IoT devices (WiFi, 
Bluetooth, etc.) – basically anything wireless.  This is probably why you are 
being peppered with emails.

I would expect to see a lot more about this topic as implementation dates get 
closer.

Chris


Chris Brown
Team Lead Compliance
t   800-265-1844 - Ext 1380
t   519-455-9675 - Ext 1380

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From: Douglas E Powell mailto:doug...@gmail.com>>
Sent: Monday, October 03, 2022 4:10 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: [PSES] Cybersecurity?

All,

In the last few months, I've received a number of inquiries from recruiters 
thinking I have an interest in Cybersecurity.  Many of these come to me via 
LinkedIn and I realize the word "compliance" shows up in many disciplines such 
as legal, financial, medical, etc.  But now it seems all the recent hype into 
Cybersecurity and I.T. Compliance has created a fair bit of "noise"; and in my 
case as it is never related to EMC or Product Safety.  Although I suppose 
Regulatory Compliance could be construed...

I am curious to know if others on this forum are seeing a similar increase in 
inquiries, or is it just me?

Thanks,  Doug

Douglas E Powell
Laporte, Colorado USA
doug...@gmail.com<mailto:doug...@gmail.com>
LinkedIn<https://can01.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.linkedin.com%2Fin%2Fcoloradocomplianceguy%2F&data=05%7C01%7CChris.Brown%40startech.com%7Cf07d4ff668b746a743d108daa57b51ab%7C0bf3d7afc3864a2b87b016e76addfb23%7C0%7C0%7C638004246350695221%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C3000%7C%7C%7C&sdata=ccRg86UxBR57bOgDpVBe8e5aXovN5YZ8EUOAyx%2B7oGs%3D&reserved=0>

(UTC -06:00) Mountain Time (

Re: [PSES] EN 62368-1 Ed 3 2020 + A11 : 2020 for GPSD

2022-09-01 Thread Charlie Blackham
Dan

Just a reminder that the Summary Lists are not "formal listings" - there have 
been mistakes in some of them, so whilst they are useful, it is important to 
check the referenced Implementing Decisions

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: Dan Roman <0d75e04ed751-dmarc-requ...@listserv.ieee.org>
Sent: 01 September 2022 20:46
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EN 62368-1 Ed 3 2020 + A11 : 2020 for GPSD

Hi Bostjan,

That is the older one without the new standards added recently.  But yes, I am 
looking for that but the up to date version!

Dan


From: Boštjan Glavič [mailto:bostjan.gla...@siq.si]
Sent: Thursday, September 01, 2022 1:11 PM
To: Dan Roman mailto:danp...@verizon.net>>; 
EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: Re: [PSES] EN 62368-1 Ed 3 2020 + A11 : 2020 for GPSD

Hi Dan


Are you looking for this?

Best regards
Bostjan
SIQ Ljubljana


https://ec.europa.eu/docsroom/documents/43968/attachments/1/translations/en/renditions/native

Dobite Outlook za Android<https://aka.ms/AAb9ysg>

From: Dan Roman 
<0d75e04ed751-dmarc-requ...@listserv.ieee.org<mailto:0d75e04ed751-dmarc-requ...@listserv.ieee.org>>
Sent: Thursday, September 1, 2022 6:34:33 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
mailto:EMC-PSTC@LISTSERV.IEEE.ORG>>
Subject: Re: [PSES] EN 62368-1 Ed 3 2020 + A11 : 2020 for GPSD


CAUTION: This email originated from outside of our organisation. Do not click 
links or open attachments unless you recognise the sender and know the content 
is safe.


Anyone know if (and where) the consolidated GPSD list of harmonized standards 
is published?  When I look all I see is an amendment listing the changes and 
not an updated downloadable PDF with all current standards listed.



Dan





From: Scott Xe [mailto:scott...@gmail.com]
Sent: Tuesday, August 30, 2022 9:28 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: Re: [PSES] EN 62368-1 Ed 3 2020 + A11 : 2020 for GPSD



Hi Gert,



Unlike LVD & RED, there is no transitional date in GPSD HS table.   If there is 
no transitional period, how can the manufacturers handle the goods in the 
warehouse of the market and manufacturing plants to upgrade to new standards?  
Besides, what are the arrangements of goods in the water and recent imported 
goods at customs and market surveillance with old standard compliance?



Regards,



Scott



On Wed, 31 Aug 2022 at 01:03, Gert Gremmen 
mailto:g.grem...@cetest.nl>> wrote:

Hi Scott

The OJ itself lists the required dates in he table of publication.

Gert Gremmen

On 30-8-2022 15:41, Scott Xe wrote:

On 16 Aug, the captioned HS was listed in OJ.  Does it replace the previous 
version immediately or is there a transitional period?



Thanks and regards,



Scott

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Re: [PSES] Country Requirements -EMC Safety

2022-08-19 Thread Charlie Blackham
Ryan / all
Just to add to Brian's comments
> One would think if manufacturers are required to meet country requirements it 
> would be public knowledge.
In many cases it is - but information may be contained across more than one 
website and only in the language of the country.
There are a number of companies, either independent Global Market Access 
consultancies or teams within international test labs who "do this for a 
living" and keep up to date.
Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: Brian Ceresney 
Sent: 19 August 2022 00:22
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Country Requirements -EMC Safety

Hi Ryan, All.
After years in this predicament, I've defaulted to using the agencies to 
research the requirements for me.  I also list the countries needed and submit 
for a quote to an agency with an international GMAP group. For a reasonable 
fee, they will research and provide the information. This may take months to 
complete, however because it's not easy.
In addition, the agencies often send out emails touting their appointment as 
the agency favoured to perform specific country approvals. I've found often 
that the agency personnel are not aware of how to perform this approval, and 
sometimes no one in the agency knows either - even in-country staff!
Another good one I've found is that some of the requests from customers contain 
tiny jurisdictions where almost no one lives. Good times!

Best Of Luck.
Best Regards,
Brian C.




[https://connect.delta-q.com/hubfs/Logos%20(Delta-Q)/25-06-2012_Delta_Q_Corporate_Grey_Mango_Vertical.png]
Brian Ceresney
Regulatory Lead
Delta-Q Technologies Corp.
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From: Ryan Jazz 
mailto:rjayasin...@yamahaguitargroup.com>>
Sent: Thursday, August 18, 2022 12:08 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: [PSES] Country Requirements -EMC Safety

CAUTION: This email originated from outside of the organization. Do not click 
links or open attachments unless you recognize the sender and know the content 
is safe.

Dear Members,
I am trying to create a list of country requirement as it relates to EMC and 
Safety requirements.
However I have not been successful-These requirements appear to be a mystery.
One would think if manufacturers are required to meet country requirements it 
would be public knowledge.
I have checked trade.gov and other searches with no luck.
If anyone can please share this secret it would be much appreciated.
Perhaps you can share how you go about finding these requirements.
If one has to use a subscription service to get the answers I would like to 
hear any recommendations.
Sincerely,
Ryan Jazz
Ryan Jayasinghe
Regulatory Compliance Engineer
rjayasin...@line6.com<mailto:rjayasin...@line6.com>

"After silence, that which best expresses the inexpressible, is music" - Aldous 
Huxley

LINE6
26580 Agoura Road
Calabasas CA 91302
818.575.3711
line6.com
ampeg.com

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Re: [PSES] RF exposure minimum exclusion distance

2022-07-11 Thread Charlie Blackham
Daniel

AS a manufacturer, you are bound by the Radio Equipment Directive (and UK Radio 
Equipment Regulations)

These require you to conduct an EMF assessment.

Your risk assessment confirms that an EMF calculation would be appropriate and 
that SAR test/evaluation is not required, but an EMF calculation is needed.

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: Rodriguez, Daniel (ESP) <123de38bd494-dmarc-requ...@listserv.ieee.org>
Sent: 12 July 2022 06:50
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] RF exposure minimum exclusion distance

Good morning, all
We have a router that is installed in industrial environment in a production 
line where normally there are not workers close only for maintenance
According to EU EMF exposure for workers, is there any distance limit that we 
don't need to do an assessment like EN 62311?
I mean, if we can assess in our Risk Assessment that because in normal 
conditions a operator is not close to the unit (approx. 3 meters) we don't need 
to assess for EN 62311?

Thank you very much for your always great answers

Kind Regards / Saludos cordiales / Mit freundlichen Grüßen
Daniel Rodríguez

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Re: [PSES] UKCA

2022-06-27 Thread Charlie Blackham
Amund

There's not really been any change in what a UKCA Conformity Assessment Body 
(CAB) must do and what a EU Notified Body must do

Furthermore, the technical requirements of the UK regulations have not changed 
since Brexit, so are same as EMCD, LVD, RED

The product might be unchanged in 10 years, but "state of the art" the EMC has 
changed, so depending on the product, and the EMC environment it is used in, 
some updated assessment may be required.


Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: Amund Westin 
Sent: 28 June 2022 07:11
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] UKCA


What is your experience:

  *   Will a UKCA Notified Body normally approve the use of old test results 
(approx. 10 years old EMC report) under a conformity assessment today? We are 
preparing for some EMC testing, but wanted to re-use some results, to keep down 
the scope as much as possible.

The product is unmodified since last test, even some uncritical components 
(passive) have been changed during the years. I realize that re-use of 10 years 
old test results sounds on the edge of what is reasonable, but I'm mostly 
interested in the UKCA procedure regarding use of past results, no matter how 
old they are.

Thanks!

BR
Amund




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Re: [PSES] AW: [PSES] EN Standard amendments

2022-04-13 Thread Charlie Blackham
Scott

The A11 amendments to EN 55032 and 55035 do not make any technical changes to 
the standard, so a test report without them can be used to support a DoC that 
lists them – you should just add a covering comment in your Technical File

As to your point about which version a lab tests against – they should test 
against the version that you ask them to – it’s your responsibility as the 
manufacturer which standard you apply, not the test labs – their responsibility 
is to perform the required tests correctly

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: Scott Xe 
Sent: 13 April 2022 16:16
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] AW: [PSES] EN Standard amendments

Hi Bernd,

Many thanks for your comments.  Can we consider IEC amendment as non-EN 
amendment and it should be applied by non-EU countries.

I have a recent case on a conformity test report that adopts A1 amendment only. 
 However in OJEU it states A11.  There is a risk for the market surveillance to 
challenge the missing A11 amendment.  I am unsure if both A1 and A11 refer to 
the same topic or different one.

In the similar case, the public test house will do the conformity test using 
the latest version of standard.  If OJEU does not or has not adopted the latest 
version of a standard as harmonised standard, it may bring us unnecessary 
frustration about invalid standard applied when we deal with market 
surveillance.  Of course, we can adopt whatever standards apart from harmonised 
standards but need to convene the market surveillance in agreement.

Best regards,

Scott


On Wed, 13 Apr 2022 at 19:17, Dürrer Bernd 
mailto:bernd.duer...@wilo.com>> wrote:
Hi Scott,

all amendments published by CENELEC are applicable. You may check on published 
amendments using the standards search provided by CENELEC (for EN 55032 
https://standards.cencenelec.eu/dyn/www/f?p=205:105:0:). Typically, an 
amendment A11 is published by CENELEC to establish the correspondence between 
the standard and the essential requirements of the applicable EU directive. 
This may also include modifications to the standard (for example in EN 
55032/A11: “With respect to Clause 11 (Measurement uncertainty), the following 
shall not be applied, if Clause 5 (Requirements) is applied for the purposes of 
the presumption of conformity: 'Refer to CISPR TR 16-4-3 for guidance on the 
applicability of the limits to a series production MME'.”). Such an amendment 
A11 is now a legal prerequisite of having the standard listed in the Official 
Journal of the EU. The OJEU may not list all amendments (for EN 55032, the 
amendment A1 is not listed, cf. https://ec.europa.eu/docsroom/documents/45365). 
Nevertheless, you are free to reference standards in your Declaration of 
Conformity that are not listed in the OJEU (even non-EN standards), and if your 
DoC resp. your test report is based on an unlisted standard or amendment (e.g. 
EN 55032/A1), I recommend to reference it in the DoC.

Kind regards,

Bernd

Von: Scott Xe mailto:scott...@gmail.com>>
Gesendet: Mittwoch, 13. April 2022 12:53
An: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Betreff: [PSES] EN Standard amendments

EN standards have two types of amendment: A1 - A9 and/or A11 - A19.  As far as 
I know, A1 - A9 come from IEC/CISPR standard whereas A11 - A19 from CENELEC EN 
standard.  For products to EU markets, does the product comply with A11 - A19 
only?

For example, EN 55032 : 2015 has both A1 : 2020 and + A11 : 2020.  Is A1 : 2020 
only applied for markets outside the EU?

Thanks and regards,

Scott
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Re: [PSES] RED DoC and ETSI EN 301 489-1

2022-03-26 Thread Charlie Blackham
Gert




Indeed, but it implies that for the RED another compliance route need to be 
choosen (see annexes to the RED)

I’m not sure what you mean by this statement – the manufacturer can follow 
Annex II and self declare where HS have been applied for article 3.2 (and 3.3 
if applicable) irrespective of whether HS have been applied for Article 3.1(a) 
and (b) – this is laid out in Article 17.

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: Gert Gremmen 
Sent: 26 March 2022 10:02
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] RED DoC and ETSI EN 301 489-1






The trend is to not harmonise the -1 version of this (and other series) in the 
future,

the -1 instead will be normatively referenced in any of the applied subparts, 
that WILL be harmonised (once approved).

By normatively referencing, the referenced clauses from the -1 will be part of 
the "text with legal effect" in the subpart.









This implies that you will need a third party to prove your compliance status 
i.e. a Notified Body for 2014/53/EU (art 3.2)









Indeed, but it implies that for the RED another compliance route need to be 
choosen (see annexes to the RED)



The many subparts of EN 301 489 are on their way to harmonisation.

However the process of creating standards (= adapting to EU requirements) is 
slow, and many stakeholders are involved.

Since to-be-listed standards need up to 4 HAS-assessments each followed by a 
round of modifications at ETSI,

each taking 3-9 months, the delays can be huge.



(HAS is the EU-process where candidate HS are being scrutinized for their 
suitability to be listed. To a great part this comes down

 on verifying if the presented requirements can stand up in a legal sense, are 
exhaustive and precise,

contain no duplicates to EU legislation, and are to the state of the art.

In some cases a normatively referenced standard can block harmonisation if the 
referenced standard has severe deficiencies.)





Gert Gremmen


On 26-3-2022 9:21, T.Sato wrote:

Although non-harmonised standards will not give presumption of conformity,

--

Independent Expert on CE marking

EMC Consultant

Electrical Safety Consultant
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Re: [PSES] RED DoC and ETSI EN 301 489-1

2022-03-26 Thread Charlie Blackham
Ryan
EN 301 489-1 V1.9.2 is in the EMC OJ to be used alongside EN 301 489-34 for 
phone chargers. EN 301 489-1 V1.9.2 is quite old and I would argue does not 
represent "state of the art".
EMC Directive Harmonised Standards (HS) are useful when considering EMC aspects 
of non-radio functions for radio equipment (for example EN 61326 series of 
standards for radio enabled measurement and laboratory equipment)
EN 55037:2017 is only relevant under the RED to Broadcast Receivers (as per 
Annex ZZB),  and should not be applied to other equipment out of scope.
There is no requirement to use HS for EMC requirements under the RED (and it is 
impossible to do so, as non of the 301 489 series are yet listed)
Manufacturers must document a Risk Assessment that details rationale for 
standards that have been applied to demonstrate compliance with all relevant 
articles and I recommend that this includes application of the latest versions 
of EN 301 489 standards as published by ETSI which is likely to require some 
additional testing
Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
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From: Ryan Jazz 
Sent: 25 March 2022 21:29
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] RED DoC and ETSI EN 301 489-1

Dear members,
We have a Short Range Device transmitter and corresponding receivers we install 
in various enclosures for which we have test reports from different US labs.
Transmitter power is less than 10mW and uses the 2.4GHz band.
The various reports issued show the ETSI EN 301 489-1 V1.9.2 as one of the 
standards to which they were tested. The other is EN 300 440 V2.1.1.

  *   My question is how do we show this ETSI standard in the RED Declaration 
of Conformity when this standard is listed only in the OJEC under the EMC 
Directive?
Many RED guidance articles mention the EMC Directive should not be identified 
in the RED DoC.
Is it OK to list this ETSI standard under the RED Directive-I am afraid it 
would be misleading or raise a red flag. (pun unintended).
Instead of this ETSI standard, should we list the EN 55035:2017 standard 
instead, which is published in the OJEC under the RED?
I would appreciate your valuable advice.
Sincerely Yours,
Ryan Jazz
Ryan Jayasinghe
Regulatory Compliance Engineer
rjayasin...@line6.com<mailto:rjayasin...@line6.com>

"After silence, that which best expresses the inexpressible, is music" - Aldous 
Huxley

LINE6
26580 Agoura Road
Calabasas CA 91302
818.575.3711
line6.com
ampeg.com

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Re: [PSES] RFID Reader Integration

2022-02-23 Thread Charlie Blackham
Brian

A radio transmitter that is certified for USA and Canada probably does not need 
any further certification (subject to Grant Notes and EMF) but does require 
testing - see FCC KDB 996369 
https://apps.fcc.gov/oetcf/kdb/forms/FTSSearchResultPage.cfm?id=44637&switch=P

For Europe, a full "assessment" against the Radio Equipment Directive is 
required, which will almost certainly include some testing - further guidance 
in 
http://redca.eu/Unrestricted%20Documents/TGN/REDCA%20TGN%2001%20RED%20Radio%20equipment%20modules%20V1.2a%20March%202020.pdf

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: David Shidlovsky 
Sent: 23 February 2022 05:39
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] RFID Reader Integration

Hi
As someone who works in a test lab my recommendation is that if you are not 
manufacturing a radio device (designing and manufacturing the 
transmitter/receiver and the whole product), you should by a module that has 
both CE mark and FCC/ISED modular approval.
If the module has FCC/ISED modular approval, as long as you maintain the grant 
conditions no further radio testing is required for FCC/ISED. When in doubt, 
contact a TCB.
If you plan to sell your product in Europe, then if the module has CE, minimum 
testing should be performed on the whole device to make sure the electronics of 
your device do not affect the module. If all is ok, you can issue a DOC for 
Europe.

Best Regards,
David Shidlowsky
Technical Reviewer
[cid:image001.jpg@01D82949.F3D2A790]
Address 1 Bat-Sheva St. POB 6117, LOD7120101   Israel
Tel: 972-8-9186100 Ext. 213 Direct: 972-8-9186113   Fax: 972-8-9153101
Mail: dav...@itlglobal.org<mailto:dav...@itlglobal.org>
Web www.itlglobal.org<http://www.itlglobal.org/>

[cid:image002.png@01D82949.F3D2A790]Waze ITL: https://waze.com/ul/hsv8vccn2j
[cid:image003.jpg@01D82949.F3D2A790]<https://www.linkedin.com/company/itl-israel-testing-laboratories/>
 https://www.linkedin.com/company/itl-israel-testing-laboratories/
[cid:image004.jpg@01D82949.F3D2A790][cid:image005.jpg@01D82949.F3D2A790]
[cid:image006.jpg@01D82949.F3D2A790]




From: MIKE SHERMAN mailto:msherma...@comcast.net>>
Sent: Wednesday, February 23, 2022 2:21 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: Re: [PSES] RFID Reader Integration

Brian -
Be careful! Although very low powered, regulators still want to regulate!
We bought an RFID chip and created the antenna via a trace on the board. Guess 
what-that meant there was no modular approval=we got to do lots of testing!
Next time we'll choose differently.
Mike Sherman
On 02/22/2022 11:36 AM Brian Kunde 
mailto:bkundew...@gmail.com>> wrote:



I know nothing about the regulatory requirements of an RFID Reader but I assume 
it has a transceiver so it is considered an Intentional Radiator.

If I buy a reader over-the-counter in one country, can I use it in another 
country? Or, like WiFi and Bluetooth, do I have to have a Reader that is 
Certified for every country/market?

If I want to integrate an RFID reader into an electronic device or machine, can 
I buy pre-certified modules for a worldwide market?  Or will I have to have the 
entire electronic device certified?

What are my options?  Any insight would be helpful and appreciated.

Thanks,
The Other Brian


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Re: [PSES] IP Code Question

2022-02-14 Thread Charlie Blackham
I generally see outdoor telecoms enclosures specified and tested to IP66 or 
IP67, or NEMA 4X, but EN 60950-22:2006 and EN 62368-1:2020 only required IP54 
to provide PD2 environment.

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: Douglas Nix <0bb8ff993b10-dmarc-requ...@listserv.ieee.org>
Sent: 14 February 2022 19:35
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] IP Code Question

I agree wit Ted Eckert on this. Generally for outdoor use you’d need IP65 at 
least.

Doug Nix

"The most wasted of all days is one without laughter.” — e.e. cummings.




On 14-Feb-22, at 09:23, Brian Kunde 
mailto:bkundew...@gmail.com>> wrote:

An IP code of IPx2 implies the enclosure protects against the ingress of water 
drops at 15° tilt.  Now, most PC enclosures protect the electronics from 
occasional exposure to water drops, but it is not designed to be exposed to 
water drops continuously.  So can you rate an electronic device IP22, for 
instance, but not intend it to be used outside or in an environment where it is 
exposed to water on a regular basis?

Thanks for your input.
The Other Brian
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Re: [PSES] Declarations of Conformity-Gap Analysis Reports-EMC

2022-02-12 Thread Charlie Blackham
Ryan

I don't wish to breach copyright by sharing the actual content as it's a large 
% of the actual document, but in both cases it basically says "this document 
supersedes EN 55 and EN55yyy and their later updates"

It will cost you 5.74 Euros each for the definitive text, or you can "browse" 
them for 2 Euros each:
https://www.evs.ee/en/evs-en-55032-2015-a11-2020
https://www.evs.ee/en/evs-en-55035-2017-a11-2020

There no change to any of the test methods or limits
Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: Ryan Jazz 
Sent: 11 February 2022 23:41
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Declarations of Conformity-Gap Analysis Reports-EMC

Dear Group,
I am afraid the answer to my question may rely on purchasing 'before and after' 
standards and sifting out the delta in order to prepare a Gap Report to a 
Declaration of Conformity.

  *   If there is an alternate method please advise. A recommended service 
perhaps. Decoder Ring?
At the moment I am stuck trying to come up with a source I can reference to 
explain the difference between EN 55035:2017, vs. EN 55035:2017/A11:2020, and 
EN 55032:2015, vs EN 55032:2015/A11:2020.
This forum touched on it last October by sharing a document referring to the 
Frankfort Agreement 
(https://boss.cenelec.eu/media/4dij213u/en_iecreferencing.pdf)

  *   Is there a similar explanation for the latest amendments to 55035, and 
can someone share a good source to find these difference.
Not sure why these matters have to be so cryptic in this already mazy world of 
product compliance.
I've been at this since 1999 and this is one area where I have not felt 
well-heeled.
Your help and guidance is greatly appreciated.
Ryan Jazz

Ryan Jayasinghe
Regulatory Compliance Engineer
rjayasin...@line6.com<mailto:rjayasin...@line6.com>

"After silence, that which best expresses the inexpressible, is music" - Aldous 
Huxley

LINE6
26580 Agoura Road
Calabasas CA 91302
818.575.3711
line6.com
ampeg.com

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Re: [PSES] EN 62368-1 : 2020 Ed 3

2022-02-11 Thread Charlie Blackham
Scott

There’s no better system on the way – we’re stuck with the current one!

As always, Harmonised Standards provide a “presumption of conformity”, but 
manufacturers must also document a risk assessment and determine whether the 
applied standard covers all foreseeable risks, and if not, what other measures 
have been taken as per LVD Annex III

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: scott...@gmail.com 
Sent: 11 February 2022 01:34
To: Charlie Blackham ; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] EN 62368-1 : 2020 Ed 3

Hi Charlie,

Did you mean the current system is no longer to work anymore or is any better 
system on the way?  How do the market surveillances conduct their sampling 
checks on the market?  Just discover 6 Jan 2023 of is the DOW of last version 
on the new standard.  Is it the correct way to follow if Ed 3 will not be 
listed in OJ?

Rgds,

Scott


From: Charlie Blackham 
mailto:char...@sulisconsultants.com>>
Sent: Thursday, 10 February 2022 10:04 pm
To: scott...@gmail.com<mailto:scott...@gmail.com>; 
EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: RE: [PSES] EN 62368-1 : 2020 Ed 3

Scott

It’s never going to be listed in the OJ

The EU Commission have rejected for multiple clauses not giving legal 
presumption of conformity

(As an aside, the current version would be rejected if reviewed against the 
current criteria as well)

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: scott...@gmail.com<mailto:scott...@gmail.com> 
mailto:scott...@gmail.com>>
Sent: 10 February 2022 13:13
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: [PSES] EN 62368-1 : 2020 Ed 3

I learned this standard will become in force on 6 Jan 2023.  However I could 
not find it in OJ as a harmonised standard replacing the Ed 2.  It is difficult 
in encouraging the suppliers to use this new standard without official 
confirmation.  Is anyone aware of when it will be available in OJ?

Thanks and regards,

Scott
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Re: [PSES] EN 62368-1 : 2020 Ed 3

2022-02-10 Thread Charlie Blackham
Scott

It’s never going to be listed in the OJ

The EU Commission have rejected for multiple clauses not giving legal 
presumption of conformity

(As an aside, the current version would be rejected if reviewed against the 
current criteria as well)

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: scott...@gmail.com 
Sent: 10 February 2022 13:13
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] EN 62368-1 : 2020 Ed 3

I learned this standard will become in force on 6 Jan 2023.  However I could 
not find it in OJ as a harmonised standard replacing the Ed 2.  It is difficult 
in encouraging the suppliers to use this new standard without official 
confirmation.  Is anyone aware of when it will be available in OJ?

Thanks and regards,

Scott
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Re: [PSES] Notice about LVD compliance in a DoC for machinery?

2022-01-17 Thread Charlie Blackham
Oliver

The issue is that the legal bit stating that only the MD applies and not the 
LVD is in the MD (below) and not included in the list of exemptions in Annex II 
of the LVD

1.5. RISKS DUE TO OTHER HAZARDS
1.5.1. Electricity supply
Where machinery has an electricity supply, it must be designed, constructed and 
equipped in such a way that
all hazards of an electrical nature are or can be prevented.
The safety objectives set out in Directive 73/23/EEC shall apply to machinery. 
However, the obligations
concerning conformity assessment and the placing on the market and/or putting 
into service of machinery
with regard to electrical hazards are governed solely by this Directive.

(noting that 73/23/EEC was the first iteration of the LVD)

My view is that Turkish customs are incorrect, but there’s little point in 
trying to argue with them, so I would send them a DoC that they are happy with, 
listing the relevant standard(s) you have applied.

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: Charles Grasso 
Sent: 17 January 2022 16:55
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Notice about LVD compliance in a DoC for machinery?

Other that the fact that the statement is  "the manufacturer’s EC Declaration of
conformity shall not refer to the LVD but to the MD".?

My guess is that you could invalidate the DoC if you violate that requirement.


Chas

On Mon, Jan 17, 2022 at 9:41 AM Oliver Betz 
mailto:list...@gmx.net>> wrote:
This message originated outside of DISH and was sent by: 
owner-emc-p...@listserv.ieee.org<mailto:owner-emc-p...@listserv.ieee.org>

Hi all,

the "Guide to application of the Machinery Directive 2006/42/EC",
Edition 2.2: https://ec.europa.eu/docsroom/documents/38022 states:

"...Thus, whilst machinery with an electrical supply, which is not in
any of the categories listed in Article 1(2) (k) of MD, shall fulfil the
safety objectives of the LVD, the manufacturer’s EC Declaration of
conformity shall not refer to the LVD but to the MD".

Yet, EN60204-1:2018 is listed in the LVD summary of harmonised standards.

Would it harm to state also the LVD conformity in a DoC for machinery?

The above mentioned guide writes that the DoC "shall *not* refer to the
LVD but to the MD" but I'm not sure about the intention behind.

And we have problems with Turkish customs insisting that the DoC shall
list also LVD compliance.

I wonder whether / how I can phrase an elegant note on the LVD compliance.

Any ideas?

Oliver

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[PSES] Very high temperature thermal fuse / snap switch

2022-01-06 Thread Charlie Blackham
Client is looking for a thermal fuse or similar that would operate at around 
800 C - does anyone know of such a component?

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Mead House
Longwater Road
Eversley
RG27 0NW
UK
Tel: +44 (0)7946 624317
Email: char...@sulisconsultants.com<mailto:char...@sulisconsultants.com>
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247


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Re: [PSES] FCC Part 15 - Frequency range of radiated emissions

2021-12-21 Thread Charlie Blackham
Paolo

I would recommend FCC KDB 996369 D04 Module Integration Guide V02
https://apps.fcc.gov/oetcf/kdb/forms/FTSSearchResultPage.cfm?id=44637&switch=P

§ 15.33(a) gives you an upper frequency of 12.5 GHz for part 15B “emc” emissions
§ 15.33(b) gives you an upper frequency of 25 GHz for part 15C “radio spurious” 
emissions

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: Paolo Roncone 
Sent: 21 December 2021 12:24
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] FCC Part 15 - Frequency range of radiated emissions

Hi David

Thanks for the reply
You mean both EMI and Radio must cover up to 10× BT module frequency?

Thanks again
Paolo

On Tue, Dec 21, 2021, 13:05 David Schaefer 
mailto:david.schae...@element.com>> wrote:
Paolo,

You are correct. Part 15.33 requires 10x the highest frequency, including the 
radio.

https://www.ecfr.gov/current/title-47/chapter-I/subchapter-A/part-15
§ 15.33 Frequency range of radiated measurements.
(a) For an intentional radiator, the spectrum shall be investigated from the 
lowest radio frequency signal generated in the device, without going below 9 
kHz, up to at least the frequency shown in this paragraph:
(1) If the intentional radiator operates below 10 GHz: to the tenth harmonic of 
the highest fundamental frequency or to 40 GHz, whichever is lower.

Thanks,



[cid:image485435.jpg@AB03C68D.3D324536]
David Schaefer​
Technical Manager
Element Materials Technology
9349 W Broadway Ave
Brooklyn Park
,
MN
55445
,
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O +1 612 638 5136
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www.element.com<http://www.element.com>
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From: Paolo Roncone [mailto:paoloc...@gmail.com<mailto:paoloc...@gmail.com>]
Sent: Tuesday, December 21, 2021 5:32 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: [PSES] FCC Part 15 - Frequency range of radiated emissions


CAUTION:This email originated from outside of Element Materials Technology. DO 
NOT click links or open attachments unless you recognize the sender and know 
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about this email.
Hi all,

an EUT with built-in Bluetooth 2.4 GHz module must be tested - as any 
electrical/electronic equipment sold in the USAm to FCC requirements for EMI.

Questions:
1. What is the frequency range of EMI radiated emissions for the EUT in 
question?
According to § 15.33 of Part 15:
https://www.ecfr.gov/current/title-47/chapter-I/subchapter-A/part-15#15.33

[image.png]
My understanding is that the above mentioned EUT must be tested up to at least  
10 x 2.4 GHz = 24 GHz for radiated emissions, with the limits specified in § 
15.109 (Field strength in uVolts/m).

2. Does it make any difference wrt question 1 (EMI frequency range), if the 
2.4G Bluetooth module is already covered by a Declaration of conformity or 
certified according to FCC 47 CFR Part 2 Subpart J (spurious emissions, or 
Radio tests) ?
https://www.ecfr.gov/current/title-47/part-2/subpart-J

According to a colleague of mine, if the Bluetooth module is already Radio 
tested and/or certified, we may test the subject EUT as an "unintentional 
radiator" (Subpart B), excluding the 2.4 GHz and the 10x rule, but using the 5x 
highest frequency rule for unintentional radiators as the radiated EMI range.

[image.png]
I'm not at all convinced..

I hope someone in this forum can clarify this.

Thanks a lot in advance and happy holidays!

Paolo





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Re: [PSES] RoHS III references on the DoC?

2021-12-16 Thread Charlie Blackham
Doug

It’s not required – the applicable Directive is still 2011/65/EU

2015/863 Directive amended it…….as did 60 or so Commission Delegated Directives

Whether you like it or not, declaring compliance to RoHS means that you are 
declaring compliance with RoHS, as amended, with applicable permitted 
exemptions if permitted, at the time of signing.

Lots of people like ask to see it on the DoC, so I agree that it won’t hurt, 
probably isn’t “wrong”, but also is not “required”

You do not however declare compliance to RoHS III (it doesn’t exist)

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: John Woodgate 
Sent: 16 December 2021 20:19
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] RoHS III references on the DoC?


It can't hurt to cite it. There are cases where a citation is not allowed, but 
I don't think this is one of them.
==
Best wishes John Woodgate OOO-Own Opinions Only
www.woodjohn.uk<http://www.woodjohn.uk>
Rayleigh, Essex UK
Istae nunc praetereunt nisi non ubicumque


On 2021-12-16 19:48, Douglas E Powell wrote:
All,

Given that Directive 2011/65/EU has been amended by Directive (EU) 2015/863, is 
it now necessary to reference the amendment on the Declaration of Conformity?

This is an amendment to Annex II, and "RoHS III" appears terminology used by 
the unwashed masses.

Thoughts?

-Doug


Douglas E Powell
Laporte, Colorado USA
doug...@gmail.com<mailto:doug...@gmail.com>
LinkedIn<https://www.linkedin.com/in/coloradocomplianceguy/>
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Re: [PSES] dow date for EN 62368-1:2014 ?

2021-12-13 Thread Charlie Blackham
Doug

I don't have the citation, but understand that there's a general rule that 
standards added to OJ listing provide (at least) an 18 month period before 
existing standard is superceded

That said, there are a large number of reasons why the EU Commission have 
rejected 62368-1 3rd edition as a Harmonised Standard, so I'm not expecting it 
to be listed

(EN 62368-1:2014 was listed under the previous acceptance criteria and 
published on the "C" list on Eur-Lex and my understanding is it wouldn't meet 
the more stringent requirement to provide legal conformity to be listed on the 
"L" list as is now required for all Harmonised Standards)

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: Kealey, Doug <1230523daaa3-dmarc-requ...@listserv.ieee.org>
Sent: 13 December 2021 14:29
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] dow date for EN 62368-1:2014 ?

Thank you Boštjan,

Your response is very helpful.  If EN 62368-1:2020+A11:2020 is listed in OJEU 
in December 2022, do you think they will delay the DoW date for EN 62368-1:2014 
until 12 or 24 months after Jan 06 2023?  Is there a rule or a precedent that 
the Commission will delay it?

Best regards,
Doug

From: Boštjan Glavič mailto:bostjan.gla...@siq.si>>
Sent: Sunday, December 12, 2021 11:11 PM
To: Kealey, Doug mailto:doug.kea...@garmin.com>>; 
EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: RE: dow date for EN 62368-1:2014 ?

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Hi Doug,

As there is no successor of EN 62368-1:2014 listed in OJEU, there is no DoW for 
this one. Date of Cessation in your standard is is for Cenelec 
(standardization) purpose only.

So EN 62368-1:2014 will continue to be harmonized standard after Jan 06 2023.

Best regards,
Boštjan





From: Kealey, Doug 
<1230523daaa3-dmarc-requ...@listserv.ieee.org<mailto:1230523daaa3-dmarc-requ...@listserv.ieee.org>>
Sent: Monday, December 13, 2021 5:42 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: [PSES] dow date for EN 62368-1:2014 ?

Hi All,

In my copy of EN IEC 62368-1:2020+A11:2020 (3rd edition), the dow date for the 
cessation of the 2nd edition shows as Jan. 6, 2023.  If the OJ does not list 
the 3rd edition as a harmonised standard until after Jan. 6, 2023 (let's 
pretend the OJ harmonises the 3rd edition on May 1, 2023), will 2nd edition 
remain a harmonised standard until at least May 1, 2023?  OR will there exist a 
situation for approx 4 months, during which there is no harmonised standard for 
this category of products?  We have a plan that accounts for this scenario, but 
if I get pulled into a discussion about the way this technically unfolds, I 
want to be prepared to answer.

Any precedents you can recall for safety standards?  Perhaps a past situation 
where a new revision was late in being cited in the OJ as a harmonised 
standard, did the Commission push out the dow date several additional months 
past the date of being cited in the OJ, to give manufactures more time to 
complete their technical files and update their DoC's?

Thanks so much,
Doug Kealey




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Re: [PSES] RED standard for LoRa sensor end device

2021-12-03 Thread Charlie Blackham
Amund

From a standards perspective, Lora is “just” a digitally modulated radio 
protocol

The appropriate standard* would be EN 300 220-2 V3.1.1, noting the permitted 
bands, powers and spectrum access requirements in Annexes B and C

(* Assuming the radio is not been used for an alarm application under scope of 
EN 300 220-3-1 V2.1.1 or ETSI EN 300 220-3-2 V1.1.1)

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: Amund Westin 
Sent: 03 December 2021 08:58
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] RED standard for LoRa sensor end device

Checking out the harmonized EU standards, but can’t find any specific radio 
standard for LoRa devices (operates in the 868MHz band)
Anyone who has experience about appropriate standard? The first that comes in 
my mind is EN 300 220 series.

Best regards Amund

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Re: [PSES] EU CE Marking Exemptions for Military Equipment Query

2021-10-22 Thread Charlie Blackham
Philip

> They have informed us that there is a CE Marking Exemption for Military 
> Equipment in France and Germany for these products

I suspect what they mean is “our customers in France and Germany are not asking 
for evidence of CE compliance”

That’s perfectly fine – the customer has nothing to do with it as the 
obligation to comply with EMCD and LVD is on he manufacturer and they cannot be 
exempted by a customer.

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: Matthew Wilson | GBE 
Sent: 22 October 2021 11:35
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EU CE Marking Exemptions for Military Equipment Query

It’s old now but this article, written by someone working for TUV SUD, was 
handy for me when needing to deal with the ‘military exempt argument’ a while 
ago.

https://www.newelectronics.co.uk/electronics-technology/the-military-ce-marking-conundrum/64803/

It agrees with your stance, which I personally also agree with, FWIW.

“They have informed us that there is a CE Marking Exemption for Military 
Equipment in France and Germany for these products”

Why not ask them for documentary proof or some such of the exemption?  They may 
well struggle!

Good luck.

Matthew Wilson,
GB Electronics (UK) Ltd.

[cid:image001.png@01D7C73E.196331F0]
Disclaimer:​ This email and any files transmitted with it are confidential and 
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​GB Electronics (UK) Ltd is a company registered in England and Wales under 
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​Registered office: Ascot House Mulberry Close, Woods Way, Goring By Sea, West 
Sussex, BN12 4QY.
From: Philip Stevenson mailto:pw...@hotmail.co.uk>>
Sent: 21 October 2021 11:16
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: [PSES] EU CE Marking Exemptions for Military Equipment Query

Dear All

I am contacting this forum for advice on whether there are any EU CE Marking 
Exemptions for Military Equipment in France and Germany?

My reason for asking is that the manufacturers of Military off the shelf 
equipment (MOTS) who are based in France and Germany that we incorporate into 
some of our Military CE marked products which we manufacture. They have 
informed us that there is a CE Marking Exemption for Military Equipment in 
France and Germany for these products. These products are not covered by 
Article 296 and therefore not specifically exempt CE Marking. This equipment 
also falls within the scope of the EMC Directive.

My view is that Military equipment not covered by Article 296 do not have a 
general exemption to CE marking EMC requirements and that exemptions for 
specific applications are contained within certain directives such as 
2014/53/EU Radio Equipment and 2011/65/RoHS  Directives, but other directives 
such as EMC and Low Voltage Directives do not contain any exemption.

Is my assessment correct?

If you prefer please contact me directly at my personal Email address below and 
I will not post these replies online.

Regards

Philip Stevenson

Email: pw...@hotmail.co.uk<mailto:pw...@hotmail.co.uk>

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[PSES] IEC 62368-3:2017 evaluation of USB 2.0 ports

2021-10-20 Thread Charlie Blackham
All

I realise there are now applications where 100W or more can be transferred, but 
for devices with only USB2.0 ports, that are coming from the same chip, is 
there really any need for testing and CB certification to this standard as part 
of an assessment to IEC 62368-1?

The particular products I’m looking at are powered from external 5V LPS power 
supplies that shutdown at around 4.5 A

I may just be being cynical, but I can’t see how the -3 standard makes such a 
product any safer, it just seems to make the test lab richer 😊

Is there something in the CB scheme rules that mandates using the -3 standard 
as well when seeking CB certificate?

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Mead House
Longwater Road
Eversley
RG27 0NW
UK
Tel: +44 (0)7946 624317
Email: char...@sulisconsultants.com<mailto:char...@sulisconsultants.com>
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247


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Re: [PSES] Will 5G Be Bad for Our Health?

2021-10-19 Thread Charlie Blackham
Not come across this before, but according to Press release Europeans for Safe 
Connections, September, 2021 - Stop 5G 
International<https://stop5ginternational.org/press-release-europeans-for-safe-connections-september-2021/>


What exactly is a European Citizens’ Initiative or ECI?
A European Citizens’ Initiative is a democratic way for citizens to directly 
influence the EU by proposing new laws to the European Commission. Soon after 
the registration is accepted by the EU Commission the ECI will be open for 
Europeans to sign. There is 1 year to gather the signatures for the Initiative.
When the Initiative has reached over 1 million legal signatures, the European 
Commission is obliged to consider the proposals and the ECI will also be 
discussed in the European Parliament.
It looks as though it’s a method for EU citizens to make the EU Parliament 
discuss something, though not necessarily change anything

We have Petitions - UK Government and 
Parliament<https://petition.parliament.uk/> and I guess other countries might 
have similar national petitions

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: Colin Wilson 
Sent: 19 October 2021 16:46
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Will 5G Be Bad for Our Health?

What do we think will come out of this:

COMMISSION IMPLEMENTING DECISION (EU) 2021/1828

of 7 October 2021

on the request for registration of the European citizens’ initiative entitled 
‘Stop (((5G))) – Stay Connected but Protected’ pursuant to Regulation (EU) 
2019/788 of the European Parliament and of the Council


https://eur-lex.europa.eu/eli/dec_impl/2021/1828/oj

Colin

From: John Allen 
mailto:jral...@productsafetyinc.com>>
Sent: Friday, October 15, 2021 5:00 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: Re: [PSES] Will 5G Be Bad for Our Health?

[EXTERNAL EMAIL] DO NOT CLICK links or attachments unless you recognize the 
sender and know the content is safe.
Very well put Dan.  Where in the risk assessment does it talk about “prudent 
avoidance”?  A toaster is hot and has uninsulated live parts accessible while 
energized with a known shock hazard.

Have a nice weekend!!


Best Regards and Be Safe,

John

John Allen
President & CEO
Product Safety Consulting, Inc
www.productsafetyinc.com<http://www.productsafetyinc.com>

On Oct 15, 2021, at 3:45 PM, Dan Roman 
<0d75e04ed751-dmarc-requ...@listserv.ieee.org<mailto:0d75e04ed751-dmarc-requ...@listserv.ieee.org>>
 wrote:


[EXTERNAL EMAIL] DO NOT CLICK links or attachments unless you recognize the 
sender and know the content is safe.
A Friday thought:  Where would we be if “prudent avoidance” was all we ever 
did?  Is this 5G situation overly conservative or just outright lazy because 
someone didn’t do the science to come up with a definitive result?  Do people 
protesting 5G have any basis?  Did 5G cause COVID-19?  I digress to the 
ridiculous.

My background and rambling thoughts on the topic are:

Humans have been bathed in electromagnetic fields from the earth, sun, and 
cosmos since emergence from single-celled organisms and a soup of primordial 
building blocks.  We may have introduced new frequency ranges and field 
strengths, but if life on earth was that susceptible, we would not have gotten 
beyond those first DNA and RNA strands forming.

No one has been able to convince me that non-ionizing RF within regulated power 
levels, which are based on thermal effect hazards with margin, cause harms that 
are meaningful or unacceptable.  Sure, there have been non-thermal claims over 
the years, but none has held up under scrutiny, peer-review, or attempts to 
duplicate the results.

According to the NTSB, the annual odds that a typical American will die in a 
plane crash are about 1 in 11 million.  Around 1 in 9 thousand for a car crash 
annually.  Both of these are acceptable as we still fly or ride in a car.  The 
level of risk is accepted.  It doesn’t appear RF exposure is as dangerous as a 
car ride.  Probably not as dangerous as a plane trip either.  How does prudent 
avoidance fit in?  Did the keynote speaker at one of the USA IEEE EMC Symposia 
get there by car or plane?

Based on what I personally have read, I am comfortable with 5G, the Wi-Fi in my 
house and in public, the Bluetooth and 4G in my phone, airport screening, and 
my ham radio hobby.  The risk equation includes harm and exposure.  I do not 
personally believe the harm extends beyond what we already know about and I am 
comfortable with the existing limits on exposure levels.  Low risk for me 
personally that I am more comfortable with than flying.  I also don’t believe 
that people can have a Wi-Fi allergy.  Others may have come to different 
conclusions.

We all set our own risk tolerance levels over a wide range of personal 
activities an

Re: [PSES] UL 510 Flame retardant tape

2021-10-10 Thread Charlie Blackham
Rich, Ted, All

The product has an outer enclosure that provides suitable mechanical strength 
and the battery is IEC62133 compliant charged and discharged via a suitable chip

There's a product requirement for a yellow enclosure, and we can't find a 
suitable yellow plastic with enough fire retardancy.

The issue is that Clause M.4.3 mandates a fire enclosure and it's never clear 
(to me anyway) whether some batteries actually have their own fire enclosure as 
I don't see this listed anywhere, and you might get for Conditions of 
Acceptability for a Recognised Component PSU.

If a LiIon battery really does "cook off" I'm not sure what enclosure would 
actually contain it - I guess it might be as much about whether the enclosure 
provides more fuel, but I'm not sure as to the intent of the clause in the 
standard

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: Richard Nute 
Sent: 08 October 2021 22:42
To: Charlie Blackham ; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] UL 510 Flame retardant tape


Hi Charlie:

Rather than guess:

https://www.kaptontape.com/PDF/Kapton_Films_Datasheet.pdf
https://www.dupont.com/content/dam/dupont/amer/us/en/products/ei-transformation/documents/DEC-Kapton-HN-datasheet.pdf
https://www.dupont.com/content/dam/dupont/amer/us/en/products/ei-transformation/documents/EI-10167-Kapton-General-Specifications.pdf

After looking at the above specs, I'm inclined to believe that Kapton tape will 
provide an acceptable fire enclosure (as good as any other plastic material).  
It is tough stuff!  And relatively expensive.

If you are going to test it (as suggested by Ted), I suggest a side-by-side 
test with the alternate fire enclosure plastic material.

Note that IEC 62368-1 uses IEC 60695-11-10 for flammability rating rather than 
UL 94 and UL 510.  There are no specific requirements for fire-enclosure tape.

Stay safe, and best regards,
Rich




From: Charlie Blackham 
mailto:char...@sulisconsultants.com>>
Sent: Friday, October 8, 2021 6:25 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: [EXTERNAL] [PSES] UL 510 Flame retardant tape

All

Various Kapton tapes are sold as Flame Retardant, some seem to reference UL 94 
and others UL 510.

The scenario is a product falling under EN 62368-1 and the secondary lithium 
battery needs a fire enclosure and rather than using the product enclosure, one 
could be made for the battery using a suitable plastic or manual application of 
retardant tape.

Is there any correlation between UL 510 and UL94 when considering creating a 
Fire Enclosure for a battery as per Clause M.4.3 ?



Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Mead House
Longwater Road
Eversley
RG27 0NW
UK
Tel: +44 (0)7946 624317
Email: char...@sulisconsultants.com<mailto:char...@sulisconsultants.com>
Web: 
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[PSES] UL 510 Flame retardant tape

2021-10-08 Thread Charlie Blackham
All

Various Kapton tapes are sold as Flame Retardant, some seem to reference UL 94 
and others UL 510.

The scenario is a product falling under EN 62368-1 and the secondary lithium 
battery needs a fire enclosure and rather than using the product enclosure, one 
could be made for the battery using a suitable plastic or manual application of 
retardant tape.

Is there any correlation between UL 510 and UL94 when considering creating a 
Fire Enclosure for a battery as per Clause M.4.3 ?



Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Mead House
Longwater Road
Eversley
RG27 0NW
UK
Tel: +44 (0)7946 624317
Email: char...@sulisconsultants.com<mailto:char...@sulisconsultants.com>
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247


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Re: [PSES] Climatic conditions for ESD testing

2021-07-29 Thread Charlie Blackham
EN 61000-4-2 specifies a minimum air pressure of 860 mbar but,

  *   920 mbar is the centre of a cat 5 hurricane at sea level
  *   860 mbar is about 4500m above sea level

Hardly the most rigorous set of criteria ever written into a standard 😊

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: Pete Perkins <0061f3f32d0c-dmarc-requ...@ieee.org>
Sent: 29 July 2021 17:32
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Climatic conditions for ESD testing

John, You need to address your question to the committee that is 
responsible for the standard you are questioning.

   Remember that the standards writing business is a BOGSAT process 
(Bunch Of Guys Sitting Around a Table).  Most of the participants are there 
because they know something about the subject (subject expert matter delegates) 
or they have some issue that they either want addressed or want to have it 
excluded from the standard (latter is usually not disclosed until deep into the 
discussion).  If the leader can come up with a comprehensive outline as to the 
subjects to be addressed then the process will be more comprehensive; if not it 
will be less organized.
   Specifically for this case; why did the committee write another 
standard that seems to cover the same ground as a base standard IEC 61000-4-2?  
Wot’s the rationale for this additional standard?

   Standards writing is not a scientific endeavor (even tho it uses 
scientific principles, such as you pointed out); It’s like sausage making – but 
don’t go into the kitchen if you aren’t ready to be involved in making the 
sausage…
   If you have strong feelings about the completeness of the 
product level standard perhaps you should be on the committee and straighten it 
out.  Don’t just grumble, get involved.

:>) br,  Pete

Peter E Perkins, PE
Principal Product Safety & Regulatory Affairs Consultant
PO Box 1067
Albany, ORe  97321-0413

503/452-1201

IEEE Life Fellow
IEEE PSES 2020 Distinguished Lecturer
www.researchgate.net<http://www.researchgate.net/Peter%20Perkins> search my name
p.perk...@ieee.org<mailto:p.perk...@ieee.org>


Entropy ain’t what it used to be

From: John Flavin mailto:jfla...@vermeer.com>>
Sent: Thursday, July 29, 2021 5:39 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: [PSES] Climatic conditions for ESD testing

IEC 61000-4-2 specifies climatic conditions for air discharge, including 
barometric pressure. ISO 10605 (ESD for road vehicles) is silent about 
barometric pressure.
As I remember, air pressure influences the reproducibility of air discharges, 
which I assume is why IEC 61000-4-2 specifies limit on it. (ISO 10605:2008 even 
says this in Annex E.)

So, if it’s important, why is this not specified in ISO 10605?


[cid:image001.jpg@01D784A1.D2CB5120]
John Flavin
Senior EMC Engineer
1860 Vermeer Road East | Pella, IA USA 50219
O: 641-621-8958
jfla...@vermeer.com<mailto:jfla...@vermeer.com>
vermeer.com<http://www.vermeer.com/?utm_source=email&utm_medium=email&utm_content=emailsignature&utm_campaign=mysignature.vermeer.mobi>


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Re: [PSES] CE Test Report for UK Compliance?

2021-06-19 Thread Charlie Blackham
Darren

The “Conformity Assessment Body” is the Notified Body (EU) of Competent Body 
(UK)

This advice isn’t as clearly written as it could be – that last sentence has 
nothing to do with product testing or test labs

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: Darren @ Vitesses 
Sent: 19 June 2021 13:20
To: Charlie Blackham 
Cc: EMC-PSTC@listserv.ieee.org
Subject: Re: [PSES] CE Test Report for UK Compliance?

Hi Charles
Can you explain your last sentence, “ the conformity assessment bodies that 
test them need to be different”

From my understanding a test lab can test to mutiple country standards and 
results used,  ssuming its self declaration .

Sent from my iPhone


On 19 Jun 2021, at 12:44, Charlie Blackham 
mailto:char...@sulisconsultants.com>> wrote:

Andy

> some folks are asking for a UK test report

Some folks are confused then 😊
https://www.gov.uk/guidance/placing-manufactured-goods-on-the-market-in-great-britain

Using both the CE and UKCA marking
Both the CE and UKCA mark can be placed on a product so long as neither impedes 
the visibility of the other and requirements of both the GB and EU legislation 
are met.
The essential requirements and standards that can be used to demonstrate 
conformity with them for UKCA marked goods have not changed. That means that if 
your good is currently made to the technical requirements necessary for CE 
marking then it will be made to the same technical requirements that exist for 
UKCA marking. However, the conformity assessment bodies that test them may need 
to be different.
Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: worldwideemc mailto:worldwide...@gmail.com>>
Sent: 18 June 2021 19:57
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: Re: [PSES] CE Test Report for UK Compliance?

Hi Darren,

Thank you for the information. It makes sense that the CE report should be 
sufficient but some folks are asking for a UK test report. I believe I'm not 
the only one confused on this topic.

BR,
Andy

On Fri, Jun 18, 2021 at 11:38 AM Darren @ Vitesses 
mailto:vites...@btinternet.com>> wrote:
Hi Andy

Yes
If the reports show you meet the relevant standards that would be fine
But also many international standards are the same, eg the Aus/NZS standard has 
a different name but the set up and limits are identical.
So a report to thoes standards would support a claim of compliance to the en 
standards regardless of the country.

I would recommend drawing up a document explaining the reasoning behind it.

Regards Darren
Sent from my iPhone



On 18 Jun 2021, at 18:28, worldwideemc 
mailto:worldwide...@gmail.com>> wrote:

Hello All,

Can I use my European EMC test report to claim compliance to UK regulations? I 
understand I need to generate a UKCA DoC and apply the UKCA marking.

The UK designated standards list at the link below lists EN standards without 
any reference to a British Standard...

https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/942100/ds-0007-21-emc-notice.pdf.

Any input from the list experts would be appreciated!

--
BR,
Andy Parker
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Re: [PSES] CE Test Report for UK Compliance?

2021-06-19 Thread Charlie Blackham
Andy

> some folks are asking for a UK test report

Some folks are confused then 😊
https://www.gov.uk/guidance/placing-manufactured-goods-on-the-market-in-great-britain

Using both the CE and UKCA marking
Both the CE and UKCA mark can be placed on a product so long as neither impedes 
the visibility of the other and requirements of both the GB and EU legislation 
are met.
The essential requirements and standards that can be used to demonstrate 
conformity with them for UKCA marked goods have not changed. That means that if 
your good is currently made to the technical requirements necessary for CE 
marking then it will be made to the same technical requirements that exist for 
UKCA marking. However, the conformity assessment bodies that test them may need 
to be different.
Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: worldwideemc 
Sent: 18 June 2021 19:57
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] CE Test Report for UK Compliance?

Hi Darren,

Thank you for the information. It makes sense that the CE report should be 
sufficient but some folks are asking for a UK test report. I believe I'm not 
the only one confused on this topic.

BR,
Andy

On Fri, Jun 18, 2021 at 11:38 AM Darren @ Vitesses 
mailto:vites...@btinternet.com>> wrote:
Hi Andy

Yes
If the reports show you meet the relevant standards that would be fine
But also many international standards are the same, eg the Aus/NZS standard has 
a different name but the set up and limits are identical.
So a report to thoes standards would support a claim of compliance to the en 
standards regardless of the country.

I would recommend drawing up a document explaining the reasoning behind it.

Regards Darren
Sent from my iPhone


On 18 Jun 2021, at 18:28, worldwideemc 
mailto:worldwide...@gmail.com>> wrote:

Hello All,

Can I use my European EMC test report to claim compliance to UK regulations? I 
understand I need to generate a UKCA DoC and apply the UKCA marking.

The UK designated standards list at the link below lists EN standards without 
any reference to a British Standard...

https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/942100/ds-0007-21-emc-notice.pdf.

Any input from the list experts would be appreciated!

--
BR,
Andy Parker
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--
Regards,
Andrew Parker
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Webs

Re: [PSES] Hot surface sign

2021-05-26 Thread Charlie Blackham
Scott

I’ve not read it (44 pages) but EU LVD market enforcement did a report 
“Non-functional Hot Surfaces Project”

https://ec.europa.eu/docsroom/documents/5263/attachments/1/translations

Some standards, such as EN 60335-2-9 (Household and similar electrical 
appliances - Safety - Part 2-9: Particular requirements for grills, toasters 
and similar portable cooking appliances) have different limits if equipment is 
labelled

The ISO symbol IEC 60417 - 5041, Caution, hot surface 
(iso.org)<https://www.iso.org/obp/ui#iec:grs:60417:5041>, is often referred to, 
but I’m not aware that colours or contrast is mandated

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: Brian Kunde 
Sent: 26 May 2021 18:08
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Hot surface sign

Usually, high-temperature surface warning symbols are only required if the 
hazard is not obvious.  So in ovens, stovetops, griddles, toasters, heat-sinks, 
etc. do not require them.

However, if such appliances or device have areas that are hot but it is not 
obvious it is hot, a warning symbol might be required.

At home, I have a 2-slice toaster. It is a "Cool Touch" toaster that has no hot 
exposed surfaces, except from the small surface between the two slots on the 
top.  So the manufacturer engraved the symbol on the metal surface.  Not a bad 
idea.  But back in the day, the sides of a toaster got really hot; hot enough 
to melt the Wonder Bread bag.  As a kid, I think every toaster I ever saw had a 
Wonder Bread bag melted on the side.

The Other Brian

On Wed, May 26, 2021 at 10:04 AM Scott Xe 
mailto:scott...@gmail.com>> wrote:
In some cooking appliances, there are some hot surfaces that may cause burn 
injury and safety standards suggest putting a hot surface sign to alert the 
users.

  *   Is there any specific colour requirement?  Common practice is black 
colour on yellow background or white colour on black background.
  *   Is an embossed sign black on black considered as a legible sign in EU 
criteria perspective?
  *   In case of ink-printed label, is it put on the top of the hot surface or 
next to the hot surface?  If on the top of surface, the colours are protected 
from heat degradation and specialized adhesives should be used to withstand 
higher temperatures.  Is there any test criteria for verification?
Thanks and regards,

Scott
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Attachments are

Re: [PSES] Shipping samples to UK

2021-05-26 Thread Charlie Blackham
Christopher

Nothing has changed that affects shipment of samples for test and/or evaluation
Just make it clear on the documentation as always

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: Chris <0133def26cf0-dmarc-requ...@listserv.ieee.org>
Sent: 25 May 2021 22:02
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Shipping samples to UK

Folks,
We would like to ship some non revenue samples to BT in UK.
Frequency C-band 3.8-4.2 GHz.
Does UK custom allow import of non revenue Access Point samples for evaluation.

Any info will help as UK rules are different compared to Europe.

Thanks in advance

Christopher
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Re: [PSES] Retesting needed for EN 61010-1:2010/A1:2019??

2021-05-25 Thread Charlie Blackham
https://www.evs.ee/en/evs-en-61010-1-2010-a1-2019 gives clause by clause changes

Unfortunately you will need to review it against your product with existing 
report to see which clauses are applicable and what changes any applicable 
clauses would require

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: Wiseman, Joshua 
Sent: 25 May 2021 13:06
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Retesting needed for EN 61010-1:2010/A1:2019??

When I reviewed it for our products the biggest impact for us is documentation, 
Clause 5.4.

With that said there are some changes that could impact products. For example, 
6.3.1 changed the voltages for what is deemed hazardous. I'm not sure if there 
is a list of changes anywhere, but the impact should really be based on the 
individual product.

Josh

Joshua Wiseman
Staff Engineer, Product Safety/EMC/Systems
From: Rodriguez, Daniel (ESP) 
<123de38bd494-dmarc-requ...@listserv.ieee.org<mailto:123de38bd494-dmarc-requ...@listserv.ieee.org>>
Sent: Tuesday, May 25, 2021 7:52 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: [PSES] Retesting needed for EN 61010-1:2010/A1:2019??

EXTERNAL SENDER: Verify links, attachments and sender before taking action


Good morning all

I have just reviewed the EN 61010-1:2010/A1:2019 and there a lot of changes. 
Most of them seems clarifications but I am not sure if we need to retest 
equipment checked for EN 61010-1:2010 to add A1:2029
Does anyone have a clear picture:
1.if retesting is required
2.if yes there is any cases that not (or which clauses requires testing)

Thank you for your answers!

Kind Regards / Saludos cordiales / Mit freundlichen Grüßen

Daniel Rodríguez
Sr. Equipment Compliance Specialist EMEA
T +34 673556249
E drodrig...@ecolab.com<mailto:drodrig...@ecolab.com>
ecolab.com

CONFIDENTIALITY NOTICE: This e-mail communication and any attachments may 
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Re: [PSES] South African SABS EMC Testing

2021-05-17 Thread Charlie Blackham
Carl

From what you say, the product was failing and now is passing and yet the 
hardware is identical

Unless I’ve misunderstood you, the lab may struggle to believe that the unit is 
unchanged if the emissions profile has changed – more importantly they don’t 
have anything to put on the report to explain what has happened to the device 
whilst it wasn’t at the lab.

If the fix was a firmware change that changed something of the operating mode, 
I could also see why they would want to re-test

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: Carl Newton 
Sent: 17 May 2021 23:26
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] South African SABS EMC Testing


Hi Rich,

I agree with the circumstances that you've described below.  But in this case 
there was no mod.  The hardware was returned briefly to the manufacturer for 
some verification and now the lab is telling us that they have to re-test 
simply because the hardware left their lab.  I understand that there are 
circumstances in the course of EMC testing where a modification might cause a 
problem "elsewhere" (I call it squeezing the balloon).  It's not uncommon.  But 
in this case there are no changes to hardware and we're being told that this 
re-testing is being imposed simply because it briefly left their building.

The fellow that's managing the project for this NRTL tells me that this is his 
first S.A. project and he's on a learning curve.   Lucky me.

Best regards,

Carl
On 5/17/2021 5:43 PM, Richard Nute wrote:

Hi Carl:

I cannot confirm that the SABS accreditation requires re-testing.

However, this not unusual.  I have experienced this same situation in safety 
testing.  If a failure, the complete complement of tests is repeated on the 
“fixed” unit or another unit.  The test house doesn’t know whether the fix 
affected the other test results.

Sometimes, only the fix is tested again – if the test house makes a 
determination that the fix is unlikely to affect the other test results.  They 
will consider your rationale that the fix does not affect the other test 
results, but not necessarily accept your rationale.

Stay safe, and best regards,
Rich



From: Carl Newton <mailto:emcl...@gmail.com>
Sent: Monday, May 17, 2021 11:52 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: [PSES] South African SABS EMC Testing


Group,

I'm writing to ask if anyone in the group is familiar enough with South African 
SABS EMC testing through accredited labs to answer my question regarding 
sequence of testing.  I'm trying to get an ITE setup through a major USA NRTL 
EMC lab in order to get the SABS EMC Certificate of Compliance.  We had a 
radiated emissions issue after the conducted emissions testing was completed 
upon AC mains and Ethernet port.  The hardware setup was returned to the 
manufacturer and subsequently returned to the EMC lab without change.  Now the 
EMC lab is telling me that their SABS accreditation demands that all conducted 
emissions be repeated because the hardware setup left the lab's possession (and 
adjusted their quote accordingly).

Can anyone on the list here confirm that SABS lab accreditation mandates this 
type of action?

Thanks,

Carl
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Re: [PSES] EU DoC on Thumb Drive?

2021-05-14 Thread Charlie Blackham
Carl

A number of other Directives such as RED and Machinery also require DoC to be 
provided with equipment

In the absence of Guidance that says you can provide it electronically it is 
best to work on the basis that you must not – Customs / Market enforcement will 
expect to be able to find the DoC if they inspect the product, and if it’s not 
in print format they won’t be able to as they’re not going to load up a CD or 
USB stick, and you will be considered to be shipping “non-compliant” product

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: Carl Newton 
Sent: 13 May 2021 20:36
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] EU DoC on Thumb Drive?


Group,

I've not been able to find anything that suggests that the EU DoC can be 
provided with the product electronically for a medical device.  I sent an 
inquiry to the commission and received no response.  The MDD and MDR require 
that the DoC is shipped with each product  and I have a customer that would 
like to include it on a thumb drive document package that will ship with the 
device rather than a paper hard-copy.

Do any of you have experience with this question that you can share?

Thanks in advance,

Carl
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Re: [PSES] EU Authorized Representative service for Market Surveillance Regulation (EU) 2019/1020

2021-05-06 Thread Charlie Blackham
Strictly speaking the manufacturer doesn’t need a formal agreement with the 
Importer, the importer take on that responsibility under the Directive as soon 
as they import something from manufacturer who is not in the EU

The problem is that many “companies who import” don’t know that they are 
“importers” with responsibilities as defined in the directive

The obligations on the importer are clear (in the Directive) and should be the 
responsibility of the importer alone, but experience of market enforcement is 
that these “companies who import” are doing what is required (and probably 
don’t know they need to as they may be importing products falling under 
multiple directives) and of course the “manufacturer” has their name on the 
product and packaging and is easy to identify

Reality and best practice may well dictate that a written agreement is best way 
forward.

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: Carl Newton 
Sent: 06 May 2021 20:43
To: Charlie Blackham ; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EU Authorized Representative service for Market 
Surveillance Regulation (EU) 2019/1020


Yes Charlie.  I used the AR term loosely.  There are five types of operator 
that qualify.  Manufacturers still need a formal agreement with one of them.

Best regards,

Carl
On 5/6/2021 2:33 PM, Charlie Blackham wrote:
You don’t have to have an Authorised Representative as long as you have an 
importer who is prepared to act as an importer as defined in the NLF aligned 
Directives (such as current RoHS, EMC, LVD, RED etc.)

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: Carl Newton <mailto:emcl...@gmail.com>
Sent: 06 May 2021 16:31
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: [PSES] EU Authorized Representative service for Market Surveillance 
Regulation (EU) 2019/1020


Can anyone in the group offer one or more references for an Authorized 
Representative service within the EU that will satisfy the requirements 
mandated within Market Surveillance Regulation (EU) 2019/1020?  This comes into 
effect on July 16.  Please feel free to contact me directly at the CC email 
address above if you prefer.

Thanks very much,

Carl
-


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Re: [PSES] EU Authorized Representative service for Market Surveillance Regulation (EU) 2019/1020

2021-05-06 Thread Charlie Blackham
You don’t have to have an Authorised Representative as long as you have an 
importer who is prepared to act as an importer as defined in the NLF aligned 
Directives (such as current RoHS, EMC, LVD, RED etc.)

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: Carl Newton 
Sent: 06 May 2021 16:31
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] EU Authorized Representative service for Market Surveillance 
Regulation (EU) 2019/1020


Can anyone in the group offer one or more references for an Authorized 
Representative service within the EU that will satisfy the requirements 
mandated within Market Surveillance Regulation (EU) 2019/1020?  This comes into 
effect on July 16.  Please feel free to contact me directly at the CC email 
address above if you prefer.

Thanks very much,

Carl
-


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Re: [PSES] 13.56 MHz NFC WLC ETSI Standard?

2021-04-23 Thread Charlie Blackham
Larry

RFID and EAS are forms of "radio communication" so fall within scope of the 
Radio Equipment Directive (RED), and the applicable article 3.2 Harmonised 
Standard

Wireless Power Transfer by itself does not fall within scope of the RED, it 
does not have to meet the RED article 3.2.

Any communication as part of the power transfer (such as hand-shaking) would 
fall under RED article 3.2

ETSI EN 303 446-1 V1.2.1 and EN 303 446-2 V1.2.1 provide guidance on testing 
combined radio and non-radio equipment - the radio aspects has to meet the 
radio standards and the non-radio aspect the EMC standard and EN 555032 should 
be considered if the highest frequency in the radio put the EMC upper frequency 
above upper frequency of the applicable EMC standard (not required in this case)

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: Larry K. Stillings 
Sent: 23 April 2021 16:09
To: Charlie Blackham ; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: 13.56 MHz NFC WLC ETSI Standard?

Hi Charlie,

Ok thanks.

I was under the assumption that if we are applying ETSI EN 300 330 to a product 
then the fundamental transmission would have to meet the H-Field 42 dBuA/m or 
60 dBuA/m limit spectrum mask limit in Annex I and not unlimited power despite 
being in an ISM band.

I also am assuming that any harmonics generated by the NFC WLC technology would 
only have to meet the spurious emissions limits in Table 6 from 30 to 1000 MHz 
and not have to meet the EN 55032 Class A or Class B limits for anything 
transmission related to the transmitter as explained in EN 303 446-1 and -2.



Larry K. Stillings
Compliance Worldwide, Inc.
Test Locally, Sell Globally and Launch Your Products Around the World!
FCC - Wireless - Telecom - CE Marking - International Approvals - Product Safety
357 Main Street
Sandown, NH 03873
(603) 887 3903 Fax 887-6445
complianceworldwide.com<https://complianceworldwide.com/>
Follow us on social media
 [cid:image001.png@01D7385B.D21E27D0]   
linkedin.com/company/compliance-worldwide-inc   
[cid:image002.png@01D7385B.D21E27D0]  twitter.com/complianceww
Privileged/Confidential Information may be contained in this message. If you 
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From: Charlie Blackham
Sent: Friday, April 23, 2021 10:53 AM
To: Larry K. Stillings 
mailto:la...@complianceworldwide.com>>; 
EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: RE: 13.56 MHz NFC WLC ETSI Standard?

Larry

ETSI EN 303 417 is for Wireless Power Transmission rather than low frequency 
communication and is looking at bands that aren't currently ISM or are 
restricted in some regions. It's looking at wireless charging for vehicles and 
other uses with the power transfer running up into kW.

13.56 MHz is already an ISM band with unrestricted power, so 13.56 MHz NFC WLC 
technology doesn't need a new standard to be developed
EN 300 330 V2.1.1 is the appropriate standard, and there's no power limit for 
the 13.553 - 13.567 MHz band

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: Larry K. Stillings 
mailto:la...@complianceworldwide.com>>
Sent: 23 April 2021 15:32
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: [PSES] 13.56 MHz NFC WLC ETSI Standard?

Hello All,

I was curious if anyone new of any work going on with ETSI to develop or add a 
standard specifically for 13.56 MHz NFC WLC technology?

Looks like to me right now the appropriate standard would be ETSI EN 300 330 
V2.1.1

Not sure if they are intending to add the 13.56 MHz band to the ETSI EN 303 417 
standard in a future edition, as the scope still stops with the 6.78 MHz band.

Or maybe develop a new standard all together or add a new part to EN 300 330 
for NFC WLC technology?

Larry K. Stillings
Compliance Worldwide, Inc.
Test Locally, Sell Globally and Launch Your Products Around the World!
FCC - Wireless - Telecom - CE Marking - International Approvals - Product Safety
357 Main Street
Sandown, NH 03873
(603) 887 3903 Fax 887-6445
complianceworldwide.com<https://complianceworldwide.com/>
Follow us on social media
 [cid:image001.png@01D7385B.D21E27D0]   
linkedin.com/company/compliance-worldwide-inc   
[cid:im

Re: [PSES] 13.56 MHz NFC WLC ETSI Standard?

2021-04-23 Thread Charlie Blackham
Larry

ETSI EN 303 417 is for Wireless Power Transmission rather than low frequency 
communication and is looking at bands that aren't currently ISM or are 
restricted in some regions. It's looking at wireless charging for vehicles and 
other uses with the power transfer running up into kW.

13.56 MHz is already an ISM band with unrestricted power, so 13.56 MHz NFC WLC 
technology doesn't need a new standard to be developed
EN 300 330 V2.1.1 is the appropriate standard, and there's no power limit for 
the 13.553 - 13.567 MHz band

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: Larry K. Stillings 
Sent: 23 April 2021 15:32
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] 13.56 MHz NFC WLC ETSI Standard?

Hello All,

I was curious if anyone new of any work going on with ETSI to develop or add a 
standard specifically for 13.56 MHz NFC WLC technology?

Looks like to me right now the appropriate standard would be ETSI EN 300 330 
V2.1.1

Not sure if they are intending to add the 13.56 MHz band to the ETSI EN 303 417 
standard in a future edition, as the scope still stops with the 6.78 MHz band.

Or maybe develop a new standard all together or add a new part to EN 300 330 
for NFC WLC technology?

Larry K. Stillings
Compliance Worldwide, Inc.
Test Locally, Sell Globally and Launch Your Products Around the World!
FCC - Wireless - Telecom - CE Marking - International Approvals - Product Safety
357 Main Street
Sandown, NH 03873
(603) 887 3903 Fax 887-6445
complianceworldwide.com<https://complianceworldwide.com/>
Follow us on social media
 [cid:image001.png@01D73856.F07E2220]   
linkedin.com/company/compliance-worldwide-inc   
[cid:image002.png@01D73856.F07E2220]  twitter.com/complianceww
Privileged/Confidential Information may be contained in this message. If you 
are not the addressee indicated in this message (or responsible for delivery of 
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sender by reply email. Please advise immediately if you or your employer do not 
consent to Internet email for messages of this kind. Opinions, conclusions and 
other information in this message that do not relate to the official business 
of my firm shall be understood as neither given nor endorsed by it.

-


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[PSES] test lab for 140 MPH wind testing

2021-04-20 Thread Charlie Blackham
All

I'm looking for a laboratory who can test a 1m x 1m basestation antenna for 
resilience to hurricane wind gusts

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Mead House
Longwater Road
Eversley
RG27 0NW
UK
Tel: +44 (0)7946 624317
Email: char...@sulisconsultants.com<mailto:char...@sulisconsultants.com>
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247


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