Re: [PSES] SV: [PSES] Spare parts and EMC directive
In message 01cf3db2$6c2daf00$44890d00$@westin-emission.no, dated Wed, 12 Mar 2014, Amund Westin am...@westin-emission.no writes: I assume you have to make an evaluation that deals with the consequence of new EMC requirements and thereafter let a Notified Body make an opinion. Such an evaluation should only include the spare part. I don't see that being necessary. The apparatus itself is already on the marked and new EMC requirements do not have any impact on it. That's the point. After the repair, the product's EMC characteristics are the same as before the failure, and those characteristics are accepted even though newer equipment has to have different characteristics. No new testing is required. But, maybe the evaluation is an easier task if it includes the complete apparatus. It would be. -- OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk Nondum ex silvis sumus John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] SV: [PSES] Spare parts and EMC directive
Amund The Blue Guide cover this Products which have been repaired (for example following a defect), without changing the original performance, purpose or type, are not to be considered as new products according to New Approach directives. Thus, such products need not undergo conformity assessment, whether or not the original product was placed on the market before or after the directive entered into force. This applies even if the product has been temporarily exported to a third county for the repair operations. Such operations are often carried out by replacing a defective or worn item by a spare part, which either is identical, or at least similar, to the original spare part (for example modifications may have taken place due to technical progress, or discontinued production of the oldpart). If the repair activity involved export/import activity, make sure the paperwork is clear. Regards Charlie From: Amund Westin [mailto:am...@westin-emission.no] Sent: 12 March 2014 05:18 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] SV: [PSES] Spare parts and EMC directive Thanks to all who replied. Just want to add a comment ... Let's say that an apparatus is not in production anymore. The spare part could be the apparatus main board. If is identical with the original main board, we should expect that the EMC performance of the apparatus is still unchanged after the spare part has been installed. But what if the EMC requirements have been changed (more severe) since the apparatus originally was EMC tested. It's not possible to re-test the apparatus because it's not in production anymore and it's impossible to test the main board as a standalone unit. I assume you have to make an evaluation that deals with the consequence of new EMC requirements and thereafter let a Notified Body make an opinion. Such an evaluation should only include the spare part. The apparatus itself is already on the marked and new EMC requirements do not have any impact on it. But, maybe the evaluation is an easier task if it includes the complete apparatus. Does it sound as a reasonable route to follow? Best regards Amund Fra: Ted Eckert [mailto:ted.eck...@microsoft.com] Sendt: 11. mars 2014 17:48 Til: EMC-PSTC@LISTSERV.IEEE.ORGmailto:EMC-PSTC@LISTSERV.IEEE.ORG Emne: Re: [PSES] Spare parts and EMC directive The EMC Working Party issued a guidance document regarding aftermarket parts and spare parts in relation to the EMC and EMC Vehicle Directives. This document gives a clearer statement on the applicability of 2004/108/EC to spare parts. The document is written in regards to automotive parts, but it gives a better idea of how the EMC Directive should be interpreted. http://ec.europa.eu/DocsRoom/documents/4543/attachments/1/translations/en/renditions/native I realized that this does not directly answer the question since it is automotive related. I am only offering it as evidence that the current interpretations regarding spare parts continue to be similar to the previous interpretations. Ted Eckert Compliance Engineer Microsoft Corporation ted.eck...@microsoft.commailto:ted.eck...@microsoft.com The opinions expressed are my own and do not necessarily reflect those of my employer. -Original Message- From: John Woodgate [mailto:j...@jmwa.demon.co.uk] Sent: Tuesday, March 11, 2014 9:07 AM To: EMC-PSTC@LISTSERV.IEEE.ORGmailto:EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Spare parts and EMC directive In message 000601cf3d01$5dfc2120$19f46360$@westin-emission.nomailto:000601cf3d01$5dfc2120$19f46360$@westin-emission.no, dated Tue, 11 Mar 2014, Amund Westin am...@westin-emission.nomailto:am...@westin-emission.no writes: Can?t find any spare part discussion in latest EMC guideline (2010), but I find some text in the old 89/336/EC guideline. A strange omission. However, at the practical level, if you are supplying spare parts, make that clear on the invoice: These goods are spare parts for our product model XYZ. -- OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.ukhttp://www.jmwa.demon.co.uk Nondum ex silvis sumus John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.orgmailto:emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas
[PSES] Spare parts and EMC directive
I'm looking for some guidance regarding spare parts and CE marking / EMC directive. Can't find any spare part discussion in latest EMC guideline (2010), but I find some text in the old 89/336/EC guideline. Anyone who have seen such an updated guideline for how to handle spare parts? Thanks! #Amund - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] Spare parts and EMC directive
Amund, I think the key to the spare parts issue for the EMC directive is in the definition of apparatus. Flowchart 2 in the guidance document does a good job of helping with classification of items as apparatus or not. The answer depends partially on what *you* mean by spare part, and particularly who is intended to do the replacing. Regards, Lauren Crane KLA-Tencor From: Amund Westin [mailto:am...@westin-emission.no] Sent: Tuesday, March 11, 2014 3:10 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] Spare parts and EMC directive I'm looking for some guidance regarding spare parts and CE marking / EMC directive. Can't find any spare part discussion in latest EMC guideline (2010), but I find some text in the old 89/336/EC guideline. Anyone who have seen such an updated guideline for how to handle spare parts? Thanks! #Amund - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.orgmailto:emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe)http://www.ieee-pses.org/list.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.netmailto:emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.orgmailto:mcantw...@ieee.org For policy questions, send mail to: Jim Bacher j.bac...@ieee.orgmailto:j.bac...@ieee.org David Heald dhe...@gmail.commailto:dhe...@gmail.com - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] Spare parts and EMC directive
Amund, The Blue Guide (circa 2000) says: Products which have been repaired (for example following a defect), without changing the original performance, purpose or type, are not to be considered as new products according to New Approach directives. Thus, such products need not undergo conformity assessment, whether or not the original product was placed on the market before or after the directive entered into force. This applies even if the product has been temporarily exported to a third county for the repair operations. Such operations are often carried out by replacing a defective or worn item by a spare part, which either is identical, or at least similar, to the original spare part (for example modifications may have taken place due to technical progress, or discontinued production of the old part). Thus, maintenance operations are basically excluded from the scope of the directives. However, at the design stage of the product the intended use and maintenance must be taken into account (23). Jim __ James L. Knighten, Ph.D. EMC Engineer Teradata Corporation 17095 Via Del Campo San Diego, CA 92127 858-485-2537 - phone 858-485-3788 - fax (unattended) From: Amund Westin [mailto:am...@westin-emission.no] Sent: Tuesday, March 11, 2014 1:10 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] Spare parts and EMC directive I'm looking for some guidance regarding spare parts and CE marking / EMC directive. Can't find any spare part discussion in latest EMC guideline (2010), but I find some text in the old 89/336/EC guideline. Anyone who have seen such an updated guideline for how to handle spare parts? Thanks! #Amund - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.orgmailto:emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe)http://www.ieee-pses.org/list.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.netmailto:emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.orgmailto:mcantw...@ieee.org For policy questions, send mail to: Jim Bacher j.bac...@ieee.orgmailto:j.bac...@ieee.org David Heald dhe...@gmail.commailto:dhe...@gmail.com - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] Spare parts and EMC directive
In message 000601cf3d01$5dfc2120$19f46360$@westin-emission.no, dated Tue, 11 Mar 2014, Amund Westin am...@westin-emission.no writes: Can?t find any spare part discussion in latest EMC guideline (2010), but I find some text in the old 89/336/EC guideline. A strange omission. However, at the practical level, if you are supplying spare parts, make that clear on the invoice: These goods are spare parts for our product model XYZ. -- OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk Nondum ex silvis sumus John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] Spare parts and EMC directive
The EMC Working Party issued a guidance document regarding aftermarket parts and spare parts in relation to the EMC and EMC Vehicle Directives. This document gives a clearer statement on the applicability of 2004/108/EC to spare parts. The document is written in regards to automotive parts, but it gives a better idea of how the EMC Directive should be interpreted. http://ec.europa.eu/DocsRoom/documents/4543/attachments/1/translations/en/renditions/native I realized that this does not directly answer the question since it is automotive related. I am only offering it as evidence that the current interpretations regarding spare parts continue to be similar to the previous interpretations. Ted Eckert Compliance Engineer Microsoft Corporation ted.eck...@microsoft.commailto:ted.eck...@microsoft.com The opinions expressed are my own and do not necessarily reflect those of my employer. -Original Message- From: John Woodgate [mailto:j...@jmwa.demon.co.uk] Sent: Tuesday, March 11, 2014 9:07 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Spare parts and EMC directive In message 000601cf3d01$5dfc2120$19f46360$@westin-emission.nomailto:000601cf3d01$5dfc2120$19f46360$@westin-emission.no, dated Tue, 11 Mar 2014, Amund Westin am...@westin-emission.nomailto:am...@westin-emission.no writes: Can?t find any spare part discussion in latest EMC guideline (2010), but I find some text in the old 89/336/EC guideline. A strange omission. However, at the practical level, if you are supplying spare parts, make that clear on the invoice: These goods are spare parts for our product model XYZ. -- OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.ukhttp://www.jmwa.demon.co.uk Nondum ex silvis sumus John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.orgmailto:emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.netmailto:emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.orgmailto:mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.orgmailto:j.bac...@ieee.org David Heald: dhe...@gmail.commailto:dhe...@gmail.com - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
[PSES] SV: [PSES] Spare parts and EMC directive
Thanks to all who replied. Just want to add a comment . Let's say that an apparatus is not in production anymore. The spare part could be the apparatus main board. If is identical with the original main board, we should expect that the EMC performance of the apparatus is still unchanged after the spare part has been installed. But what if the EMC requirements have been changed (more severe) since the apparatus originally was EMC tested. It's not possible to re-test the apparatus because it's not in production anymore and it's impossible to test the main board as a standalone unit. I assume you have to make an evaluation that deals with the consequence of new EMC requirements and thereafter let a Notified Body make an opinion. Such an evaluation should only include the spare part. The apparatus itself is already on the marked and new EMC requirements do not have any impact on it. But, maybe the evaluation is an easier task if it includes the complete apparatus. Does it sound as a reasonable route to follow? Best regards Amund Fra: Ted Eckert [mailto:ted.eck...@microsoft.com] Sendt: 11. mars 2014 17:48 Til: EMC-PSTC@LISTSERV.IEEE.ORG Emne: Re: [PSES] Spare parts and EMC directive The EMC Working Party issued a guidance document regarding aftermarket parts and spare parts in relation to the EMC and EMC Vehicle Directives. This document gives a clearer statement on the applicability of 2004/108/EC to spare parts. The document is written in regards to automotive parts, but it gives a better idea of how the EMC Directive should be interpreted. http://ec.europa.eu/DocsRoom/documents/4543/attachments/1/translations/en/r enditions/native http://ec.europa.eu/DocsRoom/documents/4543/attachments/1/translations/en/re nditions/native I realized that this does not directly answer the question since it is automotive related. I am only offering it as evidence that the current interpretations regarding spare parts continue to be similar to the previous interpretations. Ted Eckert Compliance Engineer Microsoft Corporation mailto:ted.eck...@microsoft.com ted.eck...@microsoft.com The opinions expressed are my own and do not necessarily reflect those of my employer. -Original Message- From: John Woodgate [ mailto:j...@jmwa.demon.co.uk mailto:j...@jmwa.demon.co.uk] Sent: Tuesday, March 11, 2014 9:07 AM To: mailto:EMC-PSTC@LISTSERV.IEEE.ORG EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Spare parts and EMC directive In message mailto:000601cf3d01$5dfc2120$19f46360$@westin-emission.no 000601cf3d01$5dfc2120$19f46360$@westin-emission.no, dated Tue, 11 Mar 2014, Amund Westin mailto:am...@westin-emission.no am...@westin-emission.no writes: Can?t find any spare part discussion in latest EMC guideline (2010), but I find some text in the old 89/336/EC guideline. A strange omission. However, at the practical level, if you are supplying spare parts, make that clear on the invoice: These goods are spare parts for our product model XYZ. -- OOO - Own Opinions Only. With best wishes. See http://www.jmwa.demon.co.uk www.jmwa.demon.co.uk Nondum ex silvis sumus John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to mailto:emc-p...@ieee.org emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html http://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas mailto:emcp...@radiusnorth.net emcp...@radiusnorth.net Mike Cantwell mailto:mcantw...@ieee.org mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: mailto:j.bac...@ieee.org j.bac...@ieee.org David Heald: mailto:dhe...@gmail.com dhe...@gmail.com - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org mailto:emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats
