Re: [PSES] EMC requirements for developer/evaluation boards

2013-11-07 Thread John Woodgate
In message 
caey+zho7p8ud3cpwftnkrbzvembc0fgrfclkaqrcoz4pdh2...@mail.gmail.com, 
dated Thu, 24 Oct 2013, EMC Guy emc.guy@gmail.com writes:


Big chip makers like Texas Instruments and others sell Eval boards to 
let developers test out a chip before deciding if they want to include 
it in their design.  These boards are usually not encased in a metal 
box, and are meant to be used naked on a workbench with often many, 
many cables attached to them.


I would like to know the EMC requirements for, let's say the US and 
Europe (FCC and CE), on this type of equipment not intended for sale to 
the general public.


If these products (they are sold, not given away) are exempt, what is 
the method to get through customs without any EMC labeling on the 
device or packaging?


I have some new information. For Europe, the EMC Directive (or perhaps 
the RTTE Directive) does apply. (The LVD might apply to some products as 
well.) This clarification may be due to the introduction of 'bare board' 
products like Raspberry Pi and Arduino, which differ from evaluation 
boards in target market, price and volume shipped, but could be 
difficult for regulators to distinguish and there might be fears of 
abuse of any concession.


The way to cope with this seems to be to apply the Directive and use the 
EMC Assessment file to record and justify interpretations of the 
standards (the Generic EMC standards may be appropriate) necessary when 
applied to a bare board for use in a laboratory environment. For 
example, the ESD tests might be applied only to the shells of 
connectors, not everywhere, and cable lengths might be restricted to 2 
metres. These interpretations would need to be notified to users in the 
product documentation, to ensure as far as possible that they are 
observed. The ESD issue could be covered by a warning to take normal 
anti-static precautions.


There is no guarantee that this will fully resolve a challenge to the CE 
marking by a zealous regulator, but without such a comprehensive EMC 
Assessment file, the exposure is greatly increased.

--
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

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Re: [PSES] EMC requirements for developer/evaluation boards

2013-11-05 Thread ce-test, qualified testing bv - Gert Gremmen
Your philosophy is mine but for one thing:

It's not because a product cannot meet requirements as put on the market
that it should be excluded ..


It could for example be sold in an enclosure, so as to meet ESD requirements.
It's not a absolute requirement for these board to be sold
as a bare PCB. It has consequences for the prices of course but
that is valid for each device, not for development boards only.

And it is not because you can touch a chip, that it need to be
tested. Standards speak about likely to be touched in normal use.
Connector internal pins on my Ipad are accessible too, but most standards do
not include them for ESD testing. It may be wise to do so, but that is another 
story.


BTW did anyone obtain a satisfactorily answer from Farnell or any other seller ?

Your opinion about the EC in these, in casu their authors, is not mine.
EC texts do generally excel in quality, what need not be the same as
clear to us,  or in line with our needs. Note that they are
addressed to the member states and their legal advisors and not to
the end users. If unclear on a special subject, than it 
certainly is the case because the subject is not well enough defined, or
it would open a way to avoid requirements by what i call
smart naming or smart selling.

 


Regards,

Ing.  Gert Gremmen, BSc



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

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

 Before printing, think about the environment. 



-Oorspronkelijk bericht-
Van: Piotr Galka [mailto:piotr.ga...@micromade.pl] 
Verzonden: Monday, November 04, 2013 6:23 PM
Aan: EMC-PSTC; ce-test, qualified testing bv - Gert Gremmen
Onderwerp: Re: [PSES] EMC requirements for developer/evaluation boards

Hi Gert,

 To Piotr: ESD test are normally carried out on enclosure and connector 
 shielding, not to internal circuits.
 HCP and VCP discharge are designed for this.


My logic is:
The idea of ESD test is to check possible events which can happen in normal use 
of device.
The possible source of ESD are human fingers.
Human fingers touches enclosure and not internal circuits because enclosure is 
between fingers and internal circuits.
So ESD is tested on enclosure and on HCP and VCP = all expected ESD that can 
happen to and near device.
If device has plastic enclosure than in real ESD to something near device has 
higher probability than to device (which is close to 0%).

If there is no enclosure than human fingers can touch directly internal 
circuits so following the idea of testing all possible ESD events in my opinion 
ESD should be also tested to internal circuits. I think that for such device 
the ESD to internal circuits has much higher probability than to something near 
(HCP and VCP). There is no idea to testing something less probable and not 
testing something more probable.

If the prototype board is to be used only in ESD protected environment than 
testing ESD to internal circuits can have no sense but testing ESD to HCP and 
VCP also has no sense.

But generally I think that prototype board should be excluded from EMC at all 
and it should be written in the first EMC directive version long time ago.
When I first time read EMC (in 2002 - two years before we (Poland) joined
EU) the question about prototype board was my first thought.
Being not clear solved in directive that subject makes me to have clear opinion 
about its authors.

Best Regards
Piotr Galka

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Re: [PSES] EMC requirements for developer/evaluation boards

2013-11-05 Thread John Woodgate
In message FCA549BE3ECF9D4CB8CB8576837EA48920A300@ZEUS.cetest.local, 
dated Tue, 5 Nov 2013, ce-test, qualified testing bv - Gert Gremmen 
g.grem...@cetest.nl writes:


Note that they are addressed to the member states and their legal 
advisors and not to the end users.


That has been put forward by the Commission as an excuse for 
incomprehensible or unrealistic texts. Manufacturers WILL look at the 
Directives, not even their own national regulations, let alone those of 
30 other countries, because, as has been found by experience, many of 
them do not interpret the relevant Directive correctly or reasonably, 
and getting that publicly corrected is usually incredibly difficult.

--
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

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Re: [PSES] EMC requirements for developer/evaluation boards

2013-11-05 Thread EMC Guy
I've been reading through all your answers and comments like through a good
book.  I still have no idea how the story will end!

To follow-up on Gert Gremmen's comments, the kind of eval board I am
adressing here is the kind with a whole bunch of connectors and test points
installed directly on the PCB surface, to monitor clock signals or to
inject voltage biases from external sources while the IC under test is
being investigated.  Of course any eval board could be placed inside an
enclosure with shielded connectors for everything, but I've never seen
that.  And of course, doing so for an item not intended to be a finished
product would add a lot of design cost that would lead to an unaffordable
price for the eval boards, essentially killing the purpose.

The purpose of my enquiry was not to find a way to go around directives and
standards to maybe put humans or licensed communications in danger, but was
to find out what was the actual regulatory framework that adresses these
very specific kits.  And from all of your generous comments, the only
conclusion I can draw today is: there is none.  No authority (in Europe at
the least) has ever published specific guidelines on the subject.  So do
what you think is right, but be prepared (with a strong enough legal
department) to defend your decisions.  Although I'm really holding on to
Brian Kunde's interpretation of apparatus and end-user as described in the
Guide for the EMC Directive.

I am suprised at the lack of FCC-sided comments.  Is this because you think
FCC Form 740 option 3. The described equipment is being imported in
limited quantities for testing and evaluation for compliance with technical
requirements or marketing suitability. The equipment will not be offered
for sale or otherwise marketed. is sufficient to go through customs with
an untested eval board?

John B.


On Tue, Nov 5, 2013 at 9:34 AM, ce-test, qualified testing bv - Gert
Gremmen g.grem...@cetest.nl wrote:

 Your philosophy is mine but for one thing:

 It's not because a product cannot meet requirements as put on the market
 that it should be excluded ..


 It could for example be sold in an enclosure, so as to meet ESD
 requirements.
 It's not a absolute requirement for these board to be sold
 as a bare PCB. It has consequences for the prices of course but
 that is valid for each device, not for development boards only.

 And it is not because you can touch a chip, that it need to be
 tested. Standards speak about likely to be touched in normal use.
 Connector internal pins on my Ipad are accessible too, but most standards
 do
 not include them for ESD testing. It may be wise to do so, but that is
 another story.


 BTW did anyone obtain a satisfactorily answer from Farnell or any other
 seller ?

 Your opinion about the EC in these, in casu their authors, is not mine.
 EC texts do generally excel in quality, what need not be the same as
 clear to us,  or in line with our needs. Note that they are
 addressed to the member states and their legal advisors and not to
 the end users. If unclear on a special subject, than it
 certainly is the case because the subject is not well enough defined, or
 it would open a way to avoid requirements by what i call
 smart naming or smart selling.




 Regards,

 Ing.  Gert Gremmen, BSc



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

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

  Before printing, think about the environment.



 -Oorspronkelijk bericht-
 Van: Piotr Galka [mailto:piotr.ga...@micromade.pl]
 Verzonden: Monday, November 04, 2013 6:23 PM
 Aan: EMC-PSTC; ce-test, qualified testing bv - Gert Gremmen
 Onderwerp: Re: [PSES] EMC requirements for developer/evaluation boards

 Hi Gert,

  To Piotr: ESD test are normally carried out on enclosure and connector
  shielding, not to internal circuits.
  HCP and VCP discharge are designed for this.
 

 My logic is:
 The idea of ESD test is to check possible events which can happen in
 normal use of device.
 The possible source of ESD are human fingers.
 Human fingers touches enclosure and not internal circuits because
 enclosure is between fingers and internal circuits.
 So ESD is tested on enclosure and on HCP and VCP = all expected ESD that
 can happen to and near device.
 If device has plastic enclosure than in real ESD to something near device
 has higher probability than to device (which is close to 0%).

 If there is no enclosure than human fingers can touch directly internal
 circuits so following the idea of testing all possible ESD events in my
 opinion ESD should be also tested to internal circuits. I think that for
 such device the ESD to internal circuits has much higher probability than
 to something near (HCP and VCP). There is no idea to testing something less
 probable and not testing something more probable.

 If the prototype board is to be used only in ESD protected environment
 than testing ESD to internal circuits can have no sense but testing ESD to
 HCP

Re: [PSES] EMC requirements for developer/evaluation boards

2013-11-05 Thread Piotr Galka
Some 'experts' were recruited at some stage as 'advisers', but 
the selection seems to have been based on criteria other than technical 
expertise.


As always :) or rather
As always :(

Piotr Galka

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Re: [PSES] EMC requirements for developer/evaluation boards

2013-11-05 Thread John Woodgate
In message 
caey+zhpwfgbq9ctmf5rn-dp6a6sr0tauarovia5ch3sd6sx...@mail.gmail.com, 
dated Tue, 5 Nov 2013, EMC Guy emc.guy@gmail.com writes:


.  Although I'm really holding on to Brian Kunde's interpretation of 
apparatus and end-user as described in the Guide for the EMC Directive.


I wouldn't advise that: Brian's interpretation is not shared by others. 
The end-user is simply the person who does not pass the product on but 
uses it. The definition of apparatus is very broad and an evaluation 
board is undoubtedly apparatus.


In view of the fact that thousands of these boards have been supplied 
and no-one has reported here a problem with the authorities suggest (but 
does not guarantee) that you will have no problem. The Commission is 
conducting a strong drive to intensify market surveillance.

--
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

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Re: [PSES] EMC requirements for developer/evaluation boards

2013-11-05 Thread McInturff, Gary
Sorry I don’t have time to look it up, but the FCC regulations do discuss 
equipment operation at trade shows and other places while the product is still 
under the designers control. The principle restriction was labeling that was 
clearing identified that it wasn’t for sale and that no money could transfer 
until the unit was approved. Sorry this is really vague and I took a very brief 
shot at finding it in the rules but don’t have time for a real search. But you 
should be able to find it at least for the US – obviously the EU doesn’t care 
about what the FCC would allow. So depending on where this is going the 
allowance for pre-approved equipment in the us may or may not be pertinent 
anyway.

I can see the labeling in my mind and it even had to be red in color (colour 
for my EU friends) but just can’t come up with the actual clause just now.

Gary

From: EMC Guy [mailto:emc.guy@gmail.com]
Sent: Tuesday, November 05, 2013 7:44 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EMC requirements for developer/evaluation boards

I've been reading through all your answers and comments like through a good 
book.  I still have no idea how the story will end!
To follow-up on Gert Gremmen's comments, the kind of eval board I am adressing 
here is the kind with a whole bunch of connectors and test points installed 
directly on the PCB surface, to monitor clock signals or to inject voltage 
biases from external sources while the IC under test is being investigated.  Of 
course any eval board could be placed inside an enclosure with shielded 
connectors for everything, but I've never seen that.  And of course, doing so 
for an item not intended to be a finished product would add a lot of design 
cost that would lead to an unaffordable price for the eval boards, essentially 
killing the purpose.
The purpose of my enquiry was not to find a way to go around directives and 
standards to maybe put humans or licensed communications in danger, but was to 
find out what was the actual regulatory framework that adresses these very 
specific kits.  And from all of your generous comments, the only conclusion I 
can draw today is: there is none.  No authority (in Europe at the least) has 
ever published specific guidelines on the subject.  So do what you think is 
right, but be prepared (with a strong enough legal department) to defend your 
decisions.  Although I'm really holding on to Brian Kunde's interpretation of 
apparatus and end-user as described in the Guide for the EMC Directive.
I am suprised at the lack of FCC-sided comments.  Is this because you think FCC 
Form 740 option 3. The described equipment is being imported in limited 
quantities for testing and evaluation for compliance with technical 
requirements or marketing suitability. The equipment will not be offered for 
sale or otherwise marketed. is sufficient to go through customs with an 
untested eval board?
John B.

On Tue, Nov 5, 2013 at 9:34 AM, ce-test, qualified testing bv - Gert Gremmen 
g.grem...@cetest.nlmailto:g.grem...@cetest.nl wrote:
Your philosophy is mine but for one thing:

It's not because a product cannot meet requirements as put on the market
that it should be excluded ..


It could for example be sold in an enclosure, so as to meet ESD requirements.
It's not a absolute requirement for these board to be sold
as a bare PCB. It has consequences for the prices of course but
that is valid for each device, not for development boards only.

And it is not because you can touch a chip, that it need to be
tested. Standards speak about likely to be touched in normal use.
Connector internal pins on my Ipad are accessible too, but most standards do
not include them for ESD testing. It may be wise to do so, but that is another 
story.


BTW did anyone obtain a satisfactorily answer from Farnell or any other seller ?

Your opinion about the EC in these, in casu their authors, is not mine.
EC texts do generally excel in quality, what need not be the same as
clear to us,  or in line with our needs. Note that they are
addressed to the member states and their legal advisors and not to
the end users. If unclear on a special subject, than it
certainly is the case because the subject is not well enough defined, or
it would open a way to avoid requirements by what i call
smart naming or smart selling.




Regards,

Ing.  Gert Gremmen, BSc



g.grem...@cetest.nlmailto:g.grem...@cetest.nl
www.cetest.nlhttp://www.cetest.nl

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

• Before printing, think about the environment.



-Oorspronkelijk bericht-
Van: Piotr Galka 
[mailto:piotr.ga...@micromade.plmailto:piotr.ga...@micromade.pl]
Verzonden: Monday, November 04, 2013 6:23 PM
Aan: EMC-PSTC; ce-test, qualified testing bv - Gert Gremmen
Onderwerp: Re: [PSES] EMC requirements for developer/evaluation boards
Hi Gert,

 To Piotr: ESD test are normally carried out on enclosure and connector
 shielding, not to internal circuits.
 HCP

Re: [PSES] EMC requirements for developer/evaluation boards

2013-11-05 Thread EMC Guy
Gary,

You are referring to FCC CFR47 Part 2.803 (c)(2)

---

(ii) A radio frequency device that is in the conceptual, developmental,
design or pre-production stage may be offered for sale solely to business,
commercial, industrial, scientific or medical users (but not an offer for
sale to other parties or to end users located in a residential environment)
if the prospective buyer is advised in writing at the time of the offer for
sale that the equipment is subject to the FCC rules and that the equipment
will comply with the appropriate rules before delivery to the buyer or to
centers of distribution.

(iii) (A) A radio frequency device may be advertised or displayed,
(e.g.,at a trade show or exhibition) if accompanied by a conspicuous
notice
containing this language:

This device has not been authorized as required by the rules of the Federal
Communications Commission. This device is not, and may not be, offered for
sale or lease, or sold or leased, until authorization is obtained.

---

It starts out very promising, but then it says: ...and that the equipment
will comply with the appropriate rules before delivery to the buyer
The eval board will *never* comply with the appropriate rules, it's the
whole point of the board.  But I guess the first part of the sentence is
essentially the free-pass I was looking for.  I had never payed attention
to the fact that this statement actually allows the sale of a developmental
device.  Always thought that no money exhange was allowed under this
section.

Thank you!

John




On Tue, Nov 5, 2013 at 11:12 AM, McInturff, Gary 
gary.mcintu...@esterline.com wrote:

  Sorry I don’t have time to look it up, but the FCC regulations do
 discuss equipment operation at trade shows and other places while the
 product is still under the designers control. The principle restriction was
 labeling that was clearing identified that it wasn’t for sale and that no
 money could transfer until the unit was approved. Sorry this is really
 vague and I took a very brief shot at finding it in the rules but don’t
 have time for a real search. But you should be able to find it at least for
 the US – obviously the EU doesn’t care about what the FCC would allow. So
 depending on where this is going the allowance for pre-approved equipment
 in the us may or may not be pertinent anyway.



 I can see the labeling in my mind and it even had to be red in color
 (colour for my EU friends) but just can’t come up with the actual clause
 just now.



 Gary



 *From:* EMC Guy [mailto:emc.guy@gmail.com]
 *Sent:* Tuesday, November 05, 2013 7:44 AM
 *To:* EMC-PSTC@LISTSERV.IEEE.ORG
 *Subject:* Re: [PSES] EMC requirements for developer/evaluation boards



 I've been reading through all your answers and comments like through a
 good book.  I still have no idea how the story will end!

 To follow-up on Gert Gremmen's comments, the kind of eval board I am
 adressing here is the kind with a whole bunch of connectors and test points
 installed directly on the PCB surface, to monitor clock signals or to
 inject voltage biases from external sources while the IC under test is
 being investigated.  Of course any eval board could be placed inside an
 enclosure with shielded connectors for everything, but I've never seen
 that.  And of course, doing so for an item not intended to be a finished
 product would add a lot of design cost that would lead to an unaffordable
 price for the eval boards, essentially killing the purpose.

 The purpose of my enquiry was not to find a way to go around directives
 and standards to maybe put humans or licensed communications in danger, but
 was to find out what was the actual regulatory framework that adresses
 these very specific kits.  And from all of your generous comments, the only
 conclusion I can draw today is: there is none.  No authority (in Europe at
 the least) has ever published specific guidelines on the subject.  So do
 what you think is right, but be prepared (with a strong enough legal
 department) to defend your decisions.  Although I'm really holding on to
 Brian Kunde's interpretation of apparatus and end-user as described in the
 Guide for the EMC Directive.

 I am suprised at the lack of FCC-sided comments.  Is this because you
 think FCC Form 740 option 3. The described equipment is being imported in
 limited quantities for testing and evaluation for compliance with technical
 requirements or marketing suitability. The equipment will not be offered
 for sale or otherwise marketed. is sufficient to go through customs with
 an untested eval board?

 John B.



 On Tue, Nov 5, 2013 at 9:34 AM, ce-test, qualified testing bv - Gert
 Gremmen g.grem...@cetest.nl wrote:

 Your philosophy is mine but for one thing:

 It's not because a product cannot meet requirements as put on the market
 that it should be excluded ..


 It could for example be sold in an enclosure, so as to meet ESD
 requirements.
 It's not a absolute requirement for these board to be sold

Re: [PSES] EMC requirements for developer/evaluation boards

2013-11-05 Thread Piotr Galka

Hi Gert,


It's not a absolute requirement for these board to be sold
as a bare PCB. It has consequences for the prices of course but
that is valid for each device, not for development boards only.


Not agree.
I hardly can imagine not development board sold without enclosure and 
destined to normal use without enclosure so enclosures are real need in that 
case (adds something else, not only price). If you can find some such 
products it will be only few so not it is valid for each device.

For development board enclosure is really not needed.
Specially for boards with some area to assemble your own circuits working 
with circuits originally on board. Enclosure would function as just delivery 
packaging so as device should be tested in configuration as in normal use 
(it is logical) the device should be tested without such enclosure.



And it is not because you can touch a chip, that it need to be
tested. Standards speak about likely to be touched in normal use.
Connector internal pins on my Ipad are accessible too, but most standards 
do
not include them for ESD testing. It may be wise to do so, but that is 
another story.


Yes, it is another story, but touching of connector internal pins can be (up 
to some level) understood as not likely, but touching internal circuits on 
development board is likely. Each time you take such board in your hand you 
touch some conducting things connected to some elements and probably IC pins 
on it.



Your opinion about the EC in these, in casu their authors, is not mine.
EC texts do generally excel in quality, what need not be the same as
clear to us,  or in line with our needs. Note that they are
addressed to the member states and their legal advisors and not to
the end users. If unclear on a special subject, than it
certainly is the case because the subject is not well enough defined, or
it would open a way to avoid requirements by what i call
smart naming or smart selling.

When I was discovering how directives work I understood (may be wrongly) 
that directives need to be directly written into member law. It has to be so 
because if it would not be so than they would not do the main job they are 
intended to - to make the whole market the one market with the same rules.
As I remember I have read long time ago that one member was 1 year late in 
adopting one directive and (during that year) some firms did something 
according to the directive and not to the member law and later the firms won 
in court (it was something about hotels as I remember, but not sure).
So in my opinion no other law source should be so clear as directives should 
be. Any unclear point in them has the effect of many unclear in member laws 
(and long discussions here :) ).


If I during first reading of directive (not reading any other directives 
before) see some problems in it I don't believe no one noticed it. I think 
they noticed, and I don't understand why they didn't do anything with it.


Regards
Piotr Galka 


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Re: [PSES] EMC requirements for developer/evaluation boards

2013-11-05 Thread John Woodgate
In message 
CAEY+ZhP=xo6m36mu3odkkmzxq8ma0cb360wphpzsnatt9vs...@mail.gmail.com, 
dated Tue, 5 Nov 2013, EMC Guy emc.guy@gmail.com writes:


It starts out very promising, but then it says: ...and that the 
equipment will comply with the appropriate rules before delivery to the 
buyer  The eval board will *never* comply with the appropriate 
rules, it's the whole point of the board.  But I guess the first part 
of the sentence is essentially the free-pass I was looking for


It isn't really, for the reason you cite in your first sentence. The 
text says the device can be sold on the understanding that it will 
comply when delivered. This surely is intended to cover custom-made 
equipment where payment or part-payment is agreed to be made before 
delivery.

--
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

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Re: [PSES] EMC requirements for developer/evaluation boards

2013-11-05 Thread Ron Pickard
Hi there,
First, IMHO eval boards are typically end-use apparatus as they are not likely 
integrated into other equipment or even into enclosures.

I wanted to chime in on this to mention that such an allowance may be found in 
Article 4.3 of the EMC Directive. Although eval boards are not specifically 
described, there are allowances similar to the FCC Part 2.803 reference, but 
2.803 pertains to equipment prior to autorization typically pertaining to 
intentional radiators. It's not clear to me if the subject eval board is an 
intentional radiator or not.

However, please note the last sentence of the Article 4.3 paragraph, 
Demonstration may only take place provided that adquate measures are taken to 
avoid electromagnetic disturbances. This could mean that operation of these 
devices may be limited to faraday cages, screen rooms, 30 meters away from 
anything, etc (the text is not at all clear on that point). That doesn't seem 
practical as most of these eval boards will likely be operated in an 
engineering lab type of environment being used by engineers.

Well, that's my 2 cents (2 pence in EU). Comments are welcome.

Best regards,

Ron Pickard
Sent from my Android phone

 Original message 
From: EMC Guy emc.guy@gmail.com 
Date: 11/05/2013  9:37 AM  (GMT-07:00) 
To: EMC-PSTC@LISTSERV.IEEE.ORG 
Subject: Re: [PSES] EMC requirements for developer/evaluation boards 
 
Gary,

You are referring to FCC CFR47 Part 2.803 (c)(2)
---

(ii) A radio frequency device that is in the conceptual, developmental, design 
or pre-production stage may be offered for sale solely to business, commercial, 
industrial, scientific or medical users (but not an offer for sale to other 
parties or to end users located in a residential environment) if the 
prospective buyer is advised in writing at the time of the offer for sale that 
the equipment is subject to the FCC rules and that the equipment will comply 
with the appropriate rules before delivery to the buyer or to centers of 
distribution.

(iii) (A) A radio frequency device may be advertised or displayed, (e.g., at a 
trade show or exhibition) if accompanied by a conspicuous notice containing 
this language:

This device has not been authorized as required by the rules of the Federal 
Communications Commission. This device is not, and may not be, offered for sale 
or lease, or sold or leased, until authorization is obtained.

---

It starts out very promising, but then it says: ...and that the equipment will 
comply with the appropriate rules before delivery to the buyer  The eval 
board will *never* comply with the appropriate rules, it's the whole point of 
the board.  But I guess the first part of the sentence is essentially the 
free-pass I was looking for.  I had never payed attention to the fact that this 
statement actually allows the sale of a developmental device.  Always thought 
that no money exhange was allowed under this section.

Thank you!

John





On Tue, Nov 5, 2013 at 11:12 AM, McInturff, Gary gary.mcintu...@esterline.com 
wrote:
Sorry I don’t have time to look it up, but the FCC regulations do discuss 
equipment operation at trade shows and other places while the product is still 
under the designers control. The principle restriction was labeling that was 
clearing identified that it wasn’t for sale and that no money could transfer 
until the unit was approved. Sorry this is really vague and I took a very brief 
shot at finding it in the rules but don’t have time for a real search. But you 
should be able to find it at least for the US – obviously the EU doesn’t care 
about what the FCC would allow. So depending on where this is going the 
allowance for pre-approved equipment in the us may or may not be pertinent 
anyway.

 

I can see the labeling in my mind and it even had to be red in color (colour 
for my EU friends) but just can’t come up with the actual clause just now.

 

Gary

 

From: EMC Guy [mailto:emc.guy@gmail.com] 
Sent: Tuesday, November 05, 2013 7:44 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EMC requirements for developer/evaluation boards

 

I've been reading through all your answers and comments like through a good 
book.  I still have no idea how the story will end!

To follow-up on Gert Gremmen's comments, the kind of eval board I am adressing 
here is the kind with a whole bunch of connectors and test points installed 
directly on the PCB surface, to monitor clock signals or to inject voltage 
biases from external sources while the IC under test is being investigated.  Of 
course any eval board could be placed inside an enclosure with shielded 
connectors for everything, but I've never seen that.  And of course, doing so 
for an item not intended to be a finished product would add a lot of design 
cost that would lead to an unaffordable price for the eval boards, essentially 
killing the purpose.

The purpose of my enquiry was not to find a way to go around directives and 
standards

Re: [PSES] EMC requirements for developer/evaluation boards

2013-11-05 Thread McInturff, Gary
Yes - delivered is actually two parts - Financial completing and physical 
transportation. That argument has been used for Beta tests of new equipment. It 
might be a complete assembly that someone has agreed to be a beta test site - 
these are NOT production units and user is a part, a final part, or design 
process. The beta unit is sometimes sold AFTER the completion of the beta test 
but never before. Physical delivery has occurred but monetary delivery has not. 
The unit has not been full delivered. Beta customers are often compensated 
somewhat in the purchase price for their knowingly accepting, testing and 
report errors and glitches that are likely to occur in this sort of test. Beta 
test equipment is still under the control of the developing company - as is 
development equipment.


Gary


-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk] 
Sent: Tuesday, November 05, 2013 9:20 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EMC requirements for developer/evaluation boards

In message 
CAEY+ZhP=xo6m36mu3odkkmzxq8ma0cb360wphpzsnatt9vs...@mail.gmail.com, 
dated Tue, 5 Nov 2013, EMC Guy emc.guy@gmail.com writes:

It starts out very promising, but then it says: ...and that the 
equipment will comply with the appropriate rules before delivery to the 
buyer  The eval board will *never* comply with the appropriate 
rules, it's the whole point of the board.  But I guess the first part 
of the sentence is essentially the free-pass I was looking for

It isn't really, for the reason you cite in your first sentence. The 
text says the device can be sold on the understanding that it will 
comply when delivered. This surely is intended to cover custom-made 
equipment where payment or part-payment is agreed to be made before 
delivery.
-- 
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

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Re: [PSES] EMC requirements for developer/evaluation boards

2013-11-05 Thread John Woodgate
In message 7gvlanbec00i8qwsu6b4is3d.1383671852...@email.android.com, 
dated Tue, 5 Nov 2013, Ron Pickard rpick...@rpqconsulting.com writes:


However, please note the last sentence of the Article 4.3 paragraph, 
Demonstration may only take place provided that adquate measures are 
taken to avoid electromagnetic disturbances. This could mean that 
operation of these devices may be limited to faraday cages, screen 
rooms, 30 meters away from anything, etc (the text is not at all clear 
on that point). That doesn't seem practical as most of these eval 
boards will likely be operated in an engineering lab type of 
environment being used by engineers.


The text applies to equipment *demonstrated* (perhaps in exhibitions - 
this is something that the German industry has a fixation on, due to 
past experience of Clipboard Man shutting down costly exhibition 
stands).


The test is actually clear, but the clarity is in the BIG word 
'adequate'. If cage, screened room, large separation are necessary, then 
they are required, if not, not.

--
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

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Re: [PSES] EMC requirements for developer/evaluation boards

2013-11-04 Thread Piotr Galka

Hi Gert,


To Piotr: ESD test are normally carried out on enclosure
and connector shielding, not to internal circuits.
HCP and VCP discharge are designed for this.



My logic is:
The idea of ESD test is to check possible events which can happen in normal 
use of device.

The possible source of ESD are human fingers.
Human fingers touches enclosure and not internal circuits because enclosure 
is between fingers and internal circuits.
So ESD is tested on enclosure and on HCP and VCP = all expected ESD that can 
happen to and near device.
If device has plastic enclosure than in real ESD to something near device 
has higher probability than to device (which is close to 0%).


If there is no enclosure than human fingers can touch directly internal 
circuits so following the idea of testing all possible ESD events in my 
opinion ESD should be also tested to internal circuits. I think that for 
such device the ESD to internal circuits has much higher probability than to 
something near (HCP and VCP). There is no idea to testing something less 
probable and not testing something more probable.


If the prototype board is to be used only in ESD protected environment than 
testing ESD to internal circuits can have no sense but testing ESD to HCP 
and VCP also has no sense.


But generally I think that prototype board should be excluded from EMC at 
all and it should be written in the first EMC directive version long time 
ago.
When I first time read EMC (in 2002 - two years before we (Poland) joined 
EU) the question about prototype board was my first thought.
Being not clear solved in directive that subject makes me to have clear 
opinion about its authors.


Best Regards
Piotr Galka

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Re: [PSES] EMC requirements for developer/evaluation boards

2013-11-04 Thread John Woodgate
In message 0D28C9BA9E9F4B019163BCA9DE6FACE6@MmPc24, dated Mon, 4 Nov 
2013, Piotr Galka piotr.ga...@micromade.pl writes:


When I first time read EMC (in 2002 - two years before we (Poland) 
joined EU) the question about prototype board was my first thought.
Being not clear solved in directive that subject makes me to have clear 
opinion about its authors.


The responsibility is actually with the senior Commission staff, who 
entrusted the drafting of the Directive to experts in legal language who 
were quite unfamiliar with electronics and electronics terminology.


The authors would not have known of a 'prototype board' as an article of 
commerce. Some 'experts' were recruited at some stage as 'advisers', but 
the selection seems to have been based on criteria other than technical 
expertise.

--
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

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Re: [PSES] EMC requirements for developer/evaluation boards

2013-10-30 Thread ce-test, qualified testing bv - Gert Gremmen
No John, no jail for me.

Being/Owning a test house I am officially
allowed to put into service non-tested equipment,
and even non compliant equipment without any restriction



Regards,

Ing.  Gert Gremmen, BSc



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

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

 Before printing, think about the environment. 



-Oorspronkelijk bericht-
Van: John Woodgate [mailto:j...@jmwa.demon.co.uk] 
Verzonden: Tuesday, October 29, 2013 2:49 PM
Aan: EMC-PSTC@LISTSERV.IEEE.ORG
Onderwerp: Re: [PSES] EMC requirements for developer/evaluation boards

In message FCA549BE3ECF9D4CB8CB8576837EA48920A2C6@ZEUS.cetest.local,
dated Tue, 29 Oct 2013, ce-test, qualified testing bv - Gert Gremmen 
g.grem...@cetest.nl writes:

I think the real reason for this exception going unnoticed is simply 
because they are shipped in small quantities (1 at a time). I now and 
then buy Ebay stuff from the far-east without any ce marking and it 
arrives always, in spite of clearly not being tested/ce marked or 
compliant.

Go directly to jail. Do not collect 200 Euros.(;-)

I have taken steps to try to get the matter properly resolved, by adopting in 
the EMCD the words from RoHS II quoted  here, but I am not in a position to 
give details.
--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk If 
dictionaries were correct, we would only need one, because they would all give 
the same information.
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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Re: [PSES] EMC requirements for developer/evaluation boards

2013-10-30 Thread John Woodgate
In message FCA549BE3ECF9D4CB8CB8576837EA48920A2D2@ZEUS.cetest.local, 
dated Wed, 30 Oct 2013, ce-test, qualified testing bv - Gert Gremmen 
g.grem...@cetest.nl writes:



Being/Owning a test house I am officially
allowed to put into service non-tested equipment, and even non 
compliant equipment without any restriction


When I wanted to test some equipment on an OATS, the British regulator 
restricted me to 1 dB less than the then current emission limits! Things 
have moved on a bit since then but not far enough.

--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk
If dictionaries were correct, we would only need one, because they would all
give the same information.
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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Re: [PSES] EMC requirements for developer/evaluation boards

2013-10-30 Thread Ed Price
How about that; our Congress works that way too.

 

Ed Price
WB6WSN
Chula Vista, CA USA

 

-Original Message-
From: ce-test, qualified testing bv - Gert Gremmen [mailto:g.grem...@cetest.nl] 
Sent: Wednesday, October 30, 2013 8:08 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EMC requirements for developer/evaluation boards

 

No John, no jail for me.

 

Being/Owning a test house I am officially allowed to put into service 
non-tested equipment, and even non compliant equipment without any 
restriction

 

Regards,

 

Ing.  Gert Gremmen, BSc

 

 

 

 mailto:g.grem...@cetest.nl g.grem...@cetest.nl

 http://www.cetest.nl www.cetest.nl

 


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Re: [PSES] EMC requirements for developer/evaluation boards

2013-10-29 Thread ce-test, qualified testing bv - Gert Gremmen
The EMC directive is not about hazardous malfunctions, but
about functional immunity only.

The END-user construction seems to me fully not applicable.
If the definition had something to do with engineers capable of
handling unwanted emissions, if would haven bee formulated like that,
in addition if there is one category of engineers that don't know
 about EMI then it is a certainly digital designer, the target audience for
this kind of device.

I think the real reason for this exception going unnoticed is simply
because they are shipped in small quantities (1 at a time).
I now and then buy Ebay stuff from the far-east without any
ce marking and it arrives always, in spite of clearly
not being tested/ce marked or compliant.

To Piotr: ESD test are normally carried out on enclosure
and connector shielding, not to internal circuits.
HCP and VCP discharge are designed for this.

If a device carries a ce mark, it is supposed to
comply with all applicable directives, for a piece
of electronics that definitely includes the EMC
directive in ALL cases (if not clearly exempted).

The Farnell answer will never come, because there is no such
answer.  It's a see, hear, and shut-up  clause.

But that works only for Farnell, Intel , Motorola
etc. If you have a small company forget it.
You will be sued and obliged to withdraw all
the stuff until you are broke. 

The best approach is like the PLT stuff. 
Start developing a standard with virtual limits
based on unsound testing techniques, and convince
the EC commission that your product will change the
way we live and open new ways of interacting
together.(Apple talk)



Regards,

Ing.  Gert Gremmen, BSc



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

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

 Before printing, think about the environment. 


-Oorspronkelijk bericht-
Van: John Woodgate [mailto:j...@jmwa.demon.co.uk] 
Verzonden: Monday, October 28, 2013 10:38 PM
Aan: EMC-PSTC@LISTSERV.IEEE.ORG
Onderwerp: Re: [PSES] EMC requirements for developer/evaluation boards

In message
caey+zhng2vxxykmy11nygckz5mgxk9jenkahdj2khnewuyn...@mail.gmail.com,
dated Mon, 28 Oct 2013, EMC Guy emc.guy@gmail.com writes:

I've looked at that Intel webpage disclaimer, and it really looks like 
something invented by their legal department to get out of EMC-testing 
their eval boards.

It isn't worded in a way I would recommend. I did tell you that getting a 
straight answer from anyone on this issue seems to be impossible: it's firmly 
in the 'too difficult' folder.

Still not sure what decision to make on this one.  Designing a board to 
pass EMC tests (yes, including ESD!) without a metal enclosure might 
not be easy or even possible in some cases, so we might just take our 
chances and do what Intel and others do: mark it CE for RoHS II, and 
include a big disclaimer that the board is intended for engineers who 
will use their own judgment to mitigate possible EMC issues

You need to be very careful with the wording. If the product is extremely 
unlikely to produce significant emissions, say so.  If it would be best to use 
shielded cables, put that in the product documents. 
It's very unlikely that regulatory authorities would be concerned about 
immunity issues UNLESS the product is something like a motor controller, where 
a lack of immunity could cause hazardous malfunction.
--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk If 
dictionaries were correct, we would only need one, because they would all give 
the same information.
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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Re: [PSES] EMC requirements for developer/evaluation boards

2013-10-29 Thread John Woodgate
In message FCA549BE3ECF9D4CB8CB8576837EA48920A2C6@ZEUS.cetest.local, 
dated Tue, 29 Oct 2013, ce-test, qualified testing bv - Gert Gremmen 
g.grem...@cetest.nl writes:


I think the real reason for this exception going unnoticed is simply 
because they are shipped in small quantities (1 at a time). I now and 
then buy Ebay stuff from the far-east without any ce marking and it 
arrives always, in spite of clearly not being tested/ce marked or 
compliant.


Go directly to jail. Do not collect 200 Euros.(;-)

I have taken steps to try to get the matter properly resolved, by 
adopting in the EMCD the words from RoHS II quoted  here, but I am not 
in a position to give details.

--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk
If dictionaries were correct, we would only need one, because they would all
give the same information.
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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Re: [PSES] EMC requirements for developer/evaluation boards

2013-10-28 Thread John Cotman
Even if the EMC Directive is not applicable by virtue of the end user
definition, the item looks as if it could well be in RoHS scope, RoHS also
now being a CE-marking directive.  If that is the case, it would at least
need CE marking under that directive.

 

John C

 

  _  

From: EMC Guy [mailto:emc.guy@gmail.com] 
Sent: 25 October 2013 16:48
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EMC requirements for developer/evaluation boards

 

Hi Brian,

Your summary is exemplary.  It points out exactly what I have also read in
the Guide, that lead me to believe that a Developer Kit might by excluded
from the EMC Directive. Particularly the End User definition.

Which brings me to the second part of the problem: entering Europe without
any marking or DoC whatsoever.  Do you know of an established method to
declare the non-applicability of CE-marking related directives, so the
customs officials do not deny entry each time one of these boards is shipped
to Europe.  Something that would resemble FCC Form 740 for example.

To John Woodgate: Thanks for the lead on Farnell, I have asked them the
question, I'll post their answer if I ever get one.

John

 

On Fri, Oct 25, 2013 at 10:25 AM, Kunde, Brian brian_ku...@lecotc.com
wrote:

The Guide for the EMC Directive may be somewhat helpful.

As it is sold, do you feel this type of product is really an Apparatus? It
has no function as sold. Don't you have to incorporate it with other
Components to make it work? Isn't it really a Component or sub-assembly
incorporated with other Components or sub-assemblies to create a Prototype
Apparatus not intended to be marketed?

Can you classify it as a Component or Sub-Assembly which is NOT Intended
for Incorporation into an Apparatus???
Referring to the Guide for the EMC Directive 2004/108/EC (8th February
2010), look at the Flow Charts starting on page 10; then go to Flow-Chart 2
on page 16.
A Component or Sub-Assembly NOT Intended for Incorporation into an
Apparatus would be Excluded from the EMC Directive.

An Apparatus must also be intended for the End User. Though in this case,
the End User would be an Engineer with knowledge of Electronics which would
most likely include at least some knowledge of EMC. On page 17 of the guide
where it describes what an End User is, see the text that says, Generally
an end-user is deemed to have no qualifications in the field of
electromagnetic compatibility.  Products not intended for the End User is
Excluded from the EMC Directive.

In the scope of the EMC Directive, it says, When compliant with the
provisions of the EMC Directive, equipment
may be placed on the market and/ or put into service in the Community
territory, freely moved and operated as designed and intended in the
expected electromagnetic environment.  So what is the expected
electromagnetic environment for a product like this? It is intended to be
used Temporarily in an engineering lab or Research and Development lab. What
is the Expected EMC Environment of such an area where prototype electronic
devices without any EMC testing is commonly operated for long periods of
time? Though I cannot find any text that specifically excludes prototype
electronic devices operating in an RD environment, it is kind of a no
brainer.

Hope this is somewhat helpful.

Brian



-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk]
Sent: Friday, October 25, 2013 6:22 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EMC requirements for developer/evaluation boards

In message
caey+zhmv+erfxd--dvutjklyva7wbr1dtjdkjxfqyj6m5lg...@mail.gmail.com
mailto:CAEY%2BZhMV%2BErfxd--dvUtjKLYva7wbr1dtjDKjxfQyj6M5LG5kA@mail.gmail.c
om ,
dated Fri, 25 Oct 2013, EMC Guy emc.guy@gmail.com writes:

.  My literature research did not come up with anything helpful,
especially for Europe

As I explained, you will not find anything explicit about this issue.
Wherever you are, you can ask Farnell, but the answers will be
Europe-oriented.
--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk If
dictionaries were correct, we would only need one, because they would all
give the same information.
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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Re: [PSES] EMC requirements for developer/evaluation boards

2013-10-28 Thread CR

On 10/28/2013 1247, John Cotman wrote:


Even if the EMC Directive is not applicable by virtue of the end 
user definition, the item looks as if it could well be in RoHS scope, 
RoHS also now being a CE-marking directive.  If that is the case, it 
would at least need CE marking under that directive.


John C




And then we use lead-bearing solder on it. Sweet!


Cortland Richmond

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Re: [PSES] EMC requirements for developer/evaluation boards

2013-10-28 Thread EMC Guy
Thanks to all for the reminder on the RoHS II part of the CE-marking.  It
is still not burned in my head that they are now combined.

I've looked at that Intel webpage disclaimer, and it really looks like
something invented by their legal department to get out of EMC-testing
their eval boards.

Still not sure what decision to make on this one.  Designing a board to
pass EMC tests (yes, including ESD!) without a metal enclosure might not be
easy or even possible in some cases, so we might just take our chances and
do what Intel and others do: mark it CE for RoHS II, and include a big
disclaimer that the board is intended for engineers who will use their own
judgment to mitigate possible EMC issues.

With my background, I'm not proud of that choice, but it's starting to look
like the only realistic approach.

Thanks for your help with this one, it is really appreciated.

John B.


On Mon, Oct 28, 2013 at 1:07 PM, CR k...@earthlink.net wrote:

  On 10/28/2013 1247, John Cotman wrote:

  Even if the EMC Directive is not applicable by virtue of the “end user”
 definition, the item looks as if it could well be in RoHS scope, RoHS also
 now being a CE-marking directive.  If that is the case, it would at least
 need CE marking under that directive.

 ** **

 John C


 And then we use lead-bearing solder on it. Sweet!


 Cortland Richmond
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Re: [PSES] EMC requirements for developer/evaluation boards

2013-10-28 Thread Ted Eckert
RoHS II (2011/65/EC) Article 2, Section 4 (j) specifically exempts equipment 
specifically designed solely for the purposes of research and development only 
made available on a business-to-business basis. Anything fitting within this 
exemption would then not fall under the RoHS Directive and would not likely 
need CE marking for RoHS purposes. Intel's development kit would appear to fit 
this clause.

I wish the other Directives has exemptions that were as clear as the RoHS 
exemption.

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.

From: EMC Guy [mailto:emc.guy@gmail.com]
Sent: Monday, October 28, 2013 2:20 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EMC requirements for developer/evaluation boards

Thanks to all for the reminder on the RoHS II part of the CE-marking.  It is 
still not burned in my head that they are now combined.
I've looked at that Intel webpage disclaimer, and it really looks like 
something invented by their legal department to get out of EMC-testing their 
eval boards.
Still not sure what decision to make on this one.  Designing a board to pass 
EMC tests (yes, including ESD!) without a metal enclosure might not be easy or 
even possible in some cases, so we might just take our chances and do what 
Intel and others do: mark it CE for RoHS II, and include a big disclaimer that 
the board is intended for engineers who will use their own judgment to mitigate 
possible EMC issues.
With my background, I'm not proud of that choice, but it's starting to look 
like the only realistic approach.
Thanks for your help with this one, it is really appreciated.
John B.

On Mon, Oct 28, 2013 at 1:07 PM, CR 
k...@earthlink.netmailto:k...@earthlink.net wrote:
On 10/28/2013 1247, John Cotman wrote:
Even if the EMC Directive is not applicable by virtue of the end user 
definition, the item looks as if it could well be in RoHS scope, RoHS also now 
being a CE-marking directive.  If that is the case, it would at least need CE 
marking under that directive.

John C


And then we use lead-bearing solder on it. Sweet!


Cortland Richmond
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Re: [PSES] EMC requirements for developer/evaluation boards

2013-10-28 Thread John Woodgate
In message 
caey+zhng2vxxykmy11nygckz5mgxk9jenkahdj2khnewuyn...@mail.gmail.com, 
dated Mon, 28 Oct 2013, EMC Guy emc.guy@gmail.com writes:


I've looked at that Intel webpage disclaimer, and it really looks like 
something invented by their legal department to get out of EMC-testing 
their eval boards.


It isn't worded in a way I would recommend. I did tell you that getting 
a straight answer from anyone on this issue seems to be impossible: it's 
firmly in the 'too difficult' folder.


Still not sure what decision to make on this one.  Designing a board to 
pass EMC tests (yes, including ESD!) without a metal enclosure might 
not be easy or even possible in some cases, so we might just take our 
chances and do what Intel and others do: mark it CE for RoHS II, and 
include a big disclaimer that the board is intended for engineers who 
will use their own judgment to mitigate possible EMC issues


You need to be very careful with the wording. If the product is 
extremely unlikely to produce significant emissions, say so.  If it 
would be best to use shielded cables, put that in the product documents. 
It's very unlikely that regulatory authorities would be concerned about 
immunity issues UNLESS the product is something like a motor controller, 
where a lack of immunity could cause hazardous malfunction.

--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk
If dictionaries were correct, we would only need one, because they would all
give the same information.
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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Re: [PSES] EMC requirements for developer/evaluation boards

2013-10-28 Thread John Woodgate
In message 
bce6e11441ea4a8bb0660c8fb12d6...@blupr03mb034.namprd03.prod.outlook.com

, dated Mon, 28 Oct 2013, Ted Eckert ted.eck...@microsoft.com writes:

RoHS II (2011/65/EC) Article 2, Section 4 (j) specifically exempts 
?equipment specifically designed solely for the purposes of research 
and development only made available on a business-to-business basis.? 
Anything fitting within this exemption would then not fall under the 
RoHS Directive and would not likely need CE marking for RoHS purposes. 
Intel?s development kit would appear to fit this clause.


I wish the other Directives has exemptions that were as clear as the 
RoHS exemption.


Indeed. It is possible that those words will be included in the next but 
one revision of the EMC Directive, but that could be 10 years away.

--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk
If dictionaries were correct, we would only need one, because they would all
give the same information.
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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Re: [PSES] EMC requirements for developer/evaluation boards

2013-10-26 Thread Piotr Galka
Hi John,

If prototype board can't get CE mark because of EMC may be it can get CE mark 
because of other directive.
I'm not on time (probably wrong English) (I have speed a year developing new 
devices and now I will spend next year on CE bureaucracy - I dream to times 
when developing/bureaucracy was 90%/10%).
I have heard that during I was busy ROHS become CE.
If the prototype board are not excluded from ROHS you have the way to put CE on 
it and avoid entering Europe without any marking or DoC.
Many prototype boards use some RF communication - than may be RTTE will help 
you to make DoC and put CE on it.

Best Regards
Piotr Galka
  - Original Message - 
  From: EMC Guy 
  To: EMC-PSTC@LISTSERV.IEEE.ORG 
  Sent: Friday, October 25, 2013 5:47 PM
  Subject: Re: [PSES] EMC requirements for developer/evaluation boards


  Hi Brian,


  Your summary is exemplary.  It points out exactly what I have also read in 
the Guide, that lead me to believe that a Developer Kit might by excluded from 
the EMC Directive. Particularly the End User definition.


  Which brings me to the second part of the problem: entering Europe without 
any marking or DoC whatsoever.  Do you know of an established method to declare 
the non-applicability of CE-marking related directives, so the customs 
officials do not deny entry each time one of these boards is shipped to Europe. 
 Something that would resemble FCC Form 740 for example.


  To John Woodgate: Thanks for the lead on Farnell, I have asked them the 
question, I'll post their answer if I ever get one.


  John




  On Fri, Oct 25, 2013 at 10:25 AM, Kunde, Brian brian_ku...@lecotc.com wrote:

The Guide for the EMC Directive may be somewhat helpful.

As it is sold, do you feel this type of product is really an Apparatus? 
It has no function as sold. Don't you have to incorporate it with other 
Components to make it work? Isn't it really a Component or sub-assembly 
incorporated with other Components or sub-assemblies to create a Prototype 
Apparatus not intended to be marketed?

Can you classify it as a Component or Sub-Assembly which is NOT 
Intended for Incorporation into an Apparatus???
Referring to the Guide for the EMC Directive 2004/108/EC (8th February 
2010), look at the Flow Charts starting on page 10; then go to Flow-Chart 2 on 
page 16.
A Component or Sub-Assembly NOT Intended for Incorporation into an 
Apparatus would be Excluded from the EMC Directive.

An Apparatus must also be intended for the End User. Though in this case, 
the End User would be an Engineer with knowledge of Electronics which would 
most likely include at least some knowledge of EMC. On page 17 of the guide 
where it describes what an End User is, see the text that says, Generally an 
end-user is deemed to have no qualifications in the field of electromagnetic 
compatibility.  Products not intended for the End User is Excluded from the 
EMC Directive.

In the scope of the EMC Directive, it says, When compliant with the 
provisions of the EMC Directive, equipment
may be placed on the market and/ or put into service in the Community 
territory, freely moved and operated as designed and intended in the expected 
electromagnetic environment.  So what is the expected electromagnetic 
environment for a product like this? It is intended to be used Temporarily in 
an engineering lab or Research and Development lab. What is the Expected EMC 
Environment of such an area where prototype electronic devices without any EMC 
testing is commonly operated for long periods of time? Though I cannot find any 
text that specifically excludes prototype electronic devices operating in an 
RD environment, it is kind of a no brainer.

Hope this is somewhat helpful.

Brian



-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk]
Sent: Friday, October 25, 2013 6:22 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EMC requirements for developer/evaluation boards

In message
caey+zhmv+erfxd--dvutjklyva7wbr1dtjdkjxfqyj6m5lg...@mail.gmail.com,
dated Fri, 25 Oct 2013, EMC Guy emc.guy@gmail.com writes:

.  My literature research did not come up with anything helpful,
especially for Europe

As I explained, you will not find anything explicit about this issue.
Wherever you are, you can ask Farnell, but the answers will be 
Europe-oriented.
--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk If 
dictionaries were correct, we would only need one, because they would all give 
the same information.
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

-

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discussion list. To post a message to the list, send your e-mail to 
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Re: [PSES] EMC requirements for developer/evaluation boards

2013-10-26 Thread Piotr Galka
Hi Gert,
  The boards you mention are supposed to comply with the requirements.
  and probably are.



How do you expect them to pass ESD test ?

The rationale (in my opinion) is to select any point where (during normal use) 
ESD can probably happen and have any effect.

If the board has not case, but is intended to be installed in some case (like 
PC extension boards) then during normal use ESD can attack only the case and 
such board should be tested installed.

If the board is expected to be used without the case then ESD can attack any 
point accessible for human fingers.



Best Regards

Piotr Galka

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Re: [PSES] EMC requirements for developer/evaluation boards

2013-10-25 Thread ce-test, qualified testing bv - Gert Gremmen
Hi John,

 

They are not exempt.

The EMC directive in the EC is valid, for each and

every single device put on the market, or put into service.

General public has nothing to do with that.

The boards you mention are supposed to comply with the requirements.

and probably are.

 

 

Someone else will possible explain the US position.

 

BTW: telling a bit more about your engagement with EMC

would give you better answers.

 

Regards,

Ing.  Gert Gremmen, BSc

 

 

 

g.grem...@cetest.nl mailto:g.grem...@cetest.nl 

www.cetest.nl


Kiotoweg 363

3047 BG Rotterdam

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

 

Before printing, think about the environment. 

 

 

Van: EMC Guy [mailto:emc.guy@gmail.com] 
Verzonden: Thursday, October 24, 2013 10:22 PM
Aan: EMC-PSTC@LISTSERV.IEEE.ORG
Onderwerp: [PSES] EMC requirements for developer/evaluation boards

 

Dear Group,

Big chip makers like Texas Instruments and others sell Eval boards to
let developers test out a chip before deciding if they want to include
it in their design.  These boards are usually not encased in a metal
box, and are meant to be used naked on a workbench with often many,
many cables attached to them.

I would like to know the EMC requirements for, let's say the US and
Europe (FCC and CE), on this type of equipment not intended for sale to
the general public.

If these products (they are sold, not given away) are exempt, what is
the method to get through customs without any EMC labeling on the device
or packaging?

Thanks for your comments and ideas.

John

-


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Re: [PSES] EMC requirements for developer/evaluation boards

2013-10-25 Thread John Woodgate
In message 
caey+zho7p8ud3cpwftnkrbzvembc0fgrfclkaqrcoz4pdh2...@mail.gmail.com, 
dated Thu, 24 Oct 2013, EMC Guy emc.guy@gmail.com writes:




I would like to know the EMC requirements for, let's say the US and 
Europe (FCC and CE), on this type of equipment not intended for sale to 
the general public.


If these products (they are sold, not given away) are exempt, what is 
the method to get through customs without any EMC labeling on the 
device or packaging?


As far as I know, this question was posed to the European authorities a 
long time ago but never answered fully. If you are in Europe, I 
recommend seeking advice from the distributor Farnell, which will not 
sell anything that does not conform, but does sell evaluation boards 
with no CE mark and no DoC.


In practice, the number of these sold is very small, they are used in a 
technical environment where there are many other sources of emission 
and, because they are low power, the chance of a strong emission is very 
small. The Guide to the EMC Directive includes:


Commercial equipment which is modified by and for the use of radio
amateurs and kits of components to be assembled by radio amateurs are
not regarded as commercially available, and are therefore outside the
scope of both the EMC and RTTE Directives.

It seems unreasonable to exempt that sort of stuff but not the same sort 
of stuff used by professionals (which may also be radio amateurs) in 
what is very likely an environment under better EMC control.

--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk
If dictionaries were correct, we would only need one, because they would all
give the same information.
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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Re: [PSES] EMC requirements for developer/evaluation boards

2013-10-25 Thread EMC Guy
Hello again Group,

To those who asked more details about me, let's just say that I've been
involved with real product testing to CE, FCC, VCCI, ACMA, KCC (MSIP) and
others for more than 15 years.  I am located neither in the US, neither in
Europe. After having seeing quite a lot of those eval boards and eval kits
being sold without any marking whatsoever, I had the opportunity to run
some of them in a test chamber and found most of them to be failing like
crazy (although one of them passed class B limits using apparent magic with
all the cables that were attached).

Now, I may have to deal with the export of a new eval board in the near
future, and want to be sure to be doing the right thing.  My literature
research did not come up with anything helpful, especially for Europe.  I
do not want to tint this conversation with my own opinion, so it's why I am
not saying much yet.

Again, your comments and input are greatly appreciated.

John

On Fri, Oct 25, 2013 at 4:21 AM, ce-test, qualified testing bv - Gert
Gremmen g.grem...@cetest.nl wrote:

 Hi John,

 ** **

 They are not exempt.

 The EMC directive in the EC is valid, for each and

 every single device put on the market, or put into service.

 General public has nothing to do with that.

 The boards you mention are supposed to comply with the requirements.

 and probably are.

 ** **

 ** **

 Someone else will possible explain the US position.

 ** **

 BTW: telling a bit more about your engagement with EMC

 would give you better answers.

 ** **

 Regards,

 Ing.  Gert Gremmen, BSc

 ** **

 ** **

 ** **

 *g.grem...@cetest.nl*

 *www.cetest.nl*


 *Kiotoweg 363***

 *3047 BG Rotterdam*

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

 * *

 * **Before printing, think about the environment.* 

 ** **

 ** **

 *Van:* EMC Guy [mailto:emc.guy@gmail.com]
 *Verzonden:* Thursday, October 24, 2013 10:22 PM
 *Aan:* EMC-PSTC@LISTSERV.IEEE.ORG
 *Onderwerp:* [PSES] EMC requirements for developer/evaluation boards

 ** **

 Dear Group,

 Big chip makers like Texas Instruments and others sell Eval boards to
 let developers test out a chip before deciding if they want to include it
 in their design.  These boards are usually not encased in a metal box, and
 are meant to be used naked on a workbench with often many, many cables
 attached to them.

 I would like to know the EMC requirements for, let's say the US and Europe
 (FCC and CE), on this type of equipment not intended for sale to the
 general public.

 If these products (they are sold, not given away) are exempt, what is
 the method to get through customs without any EMC labeling on the device or
 packaging?

 Thanks for your comments and ideas.

 John

 -
 

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Re: [PSES] EMC requirements for developer/evaluation boards

2013-10-25 Thread John Woodgate
In message 
caey+zhmv+erfxd--dvutjklyva7wbr1dtjdkjxfqyj6m5lg...@mail.gmail.com, 
dated Fri, 25 Oct 2013, EMC Guy emc.guy@gmail.com writes:


.  My literature research did not come up with anything helpful, 
especially for Europe


As I explained, you will not find anything explicit about this issue. 
Wherever you are, you can ask Farnell, but the answers will be 
Europe-oriented.

--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk
If dictionaries were correct, we would only need one, because they would all
give the same information.
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

-

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Re: [PSES] EMC requirements for developer/evaluation boards

2013-10-25 Thread Kunde, Brian
The Guide for the EMC Directive may be somewhat helpful.

As it is sold, do you feel this type of product is really an Apparatus? It 
has no function as sold. Don't you have to incorporate it with other Components 
to make it work? Isn't it really a Component or sub-assembly incorporated with 
other Components or sub-assemblies to create a Prototype Apparatus not intended 
to be marketed?

Can you classify it as a Component or Sub-Assembly which is NOT Intended 
for Incorporation into an Apparatus???
Referring to the Guide for the EMC Directive 2004/108/EC (8th February 2010), 
look at the Flow Charts starting on page 10; then go to Flow-Chart 2 on page 16.
A Component or Sub-Assembly NOT Intended for Incorporation into an Apparatus 
would be Excluded from the EMC Directive.

An Apparatus must also be intended for the End User. Though in this case, the 
End User would be an Engineer with knowledge of Electronics which would most 
likely include at least some knowledge of EMC. On page 17 of the guide where it 
describes what an End User is, see the text that says, Generally an end-user 
is deemed to have no qualifications in the field of electromagnetic 
compatibility.  Products not intended for the End User is Excluded from the 
EMC Directive.

In the scope of the EMC Directive, it says, When compliant with the provisions 
of the EMC Directive, equipment
may be placed on the market and/ or put into service in the Community 
territory, freely moved and operated as designed and intended in the expected 
electromagnetic environment.  So what is the expected electromagnetic 
environment for a product like this? It is intended to be used Temporarily in 
an engineering lab or Research and Development lab. What is the Expected EMC 
Environment of such an area where prototype electronic devices without any EMC 
testing is commonly operated for long periods of time? Though I cannot find any 
text that specifically excludes prototype electronic devices operating in an 
RD environment, it is kind of a no brainer.

Hope this is somewhat helpful.

Brian


-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk]
Sent: Friday, October 25, 2013 6:22 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EMC requirements for developer/evaluation boards

In message
caey+zhmv+erfxd--dvutjklyva7wbr1dtjdkjxfqyj6m5lg...@mail.gmail.com,
dated Fri, 25 Oct 2013, EMC Guy emc.guy@gmail.com writes:

.  My literature research did not come up with anything helpful,
especially for Europe

As I explained, you will not find anything explicit about this issue.
Wherever you are, you can ask Farnell, but the answers will be Europe-oriented.
--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk If 
dictionaries were correct, we would only need one, because they would all give 
the same information.
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

-

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mistake, please destroy it and notify us of the error. Thank you.

-

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Re: [PSES] EMC requirements for developer/evaluation boards

2013-10-25 Thread EMC Guy
Hi Brian,

Your summary is exemplary.  It points out exactly what I have also read in
the Guide, that lead me to believe that a Developer Kit might by excluded
from the EMC Directive. Particularly the End User definition.

Which brings me to the second part of the problem: entering Europe without
any marking or DoC whatsoever.  Do you know of an established method to
declare the non-applicability of CE-marking related directives, so the
customs officials do not deny entry each time one of these boards is
shipped to Europe.  Something that would resemble FCC Form 740 for example.

To John Woodgate: Thanks for the lead on Farnell, I have asked them the
question, I'll post their answer if I ever get one.

John


On Fri, Oct 25, 2013 at 10:25 AM, Kunde, Brian brian_ku...@lecotc.comwrote:

 The Guide for the EMC Directive may be somewhat helpful.

 As it is sold, do you feel this type of product is really an Apparatus?
 It has no function as sold. Don't you have to incorporate it with other
 Components to make it work? Isn't it really a Component or sub-assembly
 incorporated with other Components or sub-assemblies to create a Prototype
 Apparatus not intended to be marketed?

 Can you classify it as a Component or Sub-Assembly which is NOT
 Intended for Incorporation into an Apparatus???
 Referring to the Guide for the EMC Directive 2004/108/EC (8th February
 2010), look at the Flow Charts starting on page 10; then go to Flow-Chart 2
 on page 16.
 A Component or Sub-Assembly NOT Intended for Incorporation into an
 Apparatus would be Excluded from the EMC Directive.

 An Apparatus must also be intended for the End User. Though in this
 case, the End User would be an Engineer with knowledge of Electronics which
 would most likely include at least some knowledge of EMC. On page 17 of the
 guide where it describes what an End User is, see the text that says,
 Generally an end-user is deemed to have no qualifications in the field of
 electromagnetic compatibility.  Products not intended for the End User is
 Excluded from the EMC Directive.

 In the scope of the EMC Directive, it says, When compliant with the
 provisions of the EMC Directive, equipment
 may be placed on the market and/ or put into service in the Community
 territory, freely moved and operated as designed and intended in the
 expected electromagnetic environment.  So what is the expected
 electromagnetic environment for a product like this? It is intended to be
 used Temporarily in an engineering lab or Research and Development lab.
 What is the Expected EMC Environment of such an area where prototype
 electronic devices without any EMC testing is commonly operated for long
 periods of time? Though I cannot find any text that specifically excludes
 prototype electronic devices operating in an RD environment, it is kind of
 a no brainer.

 Hope this is somewhat helpful.

 Brian


 -Original Message-
 From: John Woodgate [mailto:j...@jmwa.demon.co.uk]
 Sent: Friday, October 25, 2013 6:22 AM
 To: EMC-PSTC@LISTSERV.IEEE.ORG
 Subject: Re: [PSES] EMC requirements for developer/evaluation boards

 In message
 caey+zhmv+erfxd--dvutjklyva7wbr1dtjdkjxfqyj6m5lg...@mail.gmail.com,
 dated Fri, 25 Oct 2013, EMC Guy emc.guy@gmail.com writes:

 .  My literature research did not come up with anything helpful,
 especially for Europe

 As I explained, you will not find anything explicit about this issue.
 Wherever you are, you can ask Farnell, but the answers will be
 Europe-oriented.
 --
 OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk If
 dictionaries were correct, we would only need one, because they would all
 give the same information.
 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
 

 LECO Corporation Notice: This communication may contain confidential
 information intended for the named recipient(s) only. If you received this
 by mistake, please destroy it and notify us of the error. Thank you

Re: [PSES] EMC requirements for developer/evaluation boards

2013-10-25 Thread Chris Anderson (cmanderson)
Read the statement at the very bottom of the linked web page.

http://www.intel.com/content/www/us/en/intelligent-systems/evaluation-platforms/core-i7-4700eq-development-kit.html

This is one approach that has been apparently successful.  I believe Intel 
ships their eval boards all over the world.

Chris


-Original Message-
From: Kunde, Brian [mailto:brian_ku...@lecotc.com] 
Sent: Friday, October 25, 2013 8:25 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EMC requirements for developer/evaluation boards

The Guide for the EMC Directive may be somewhat helpful.

As it is sold, do you feel this type of product is really an Apparatus? It 
has no function as sold. Don't you have to incorporate it with other Components 
to make it work? Isn't it really a Component or sub-assembly incorporated with 
other Components or sub-assemblies to create a Prototype Apparatus not intended 
to be marketed?

Can you classify it as a Component or Sub-Assembly which is NOT Intended 
for Incorporation into an Apparatus???
Referring to the Guide for the EMC Directive 2004/108/EC (8th February 2010), 
look at the Flow Charts starting on page 10; then go to Flow-Chart 2 on page 16.
A Component or Sub-Assembly NOT Intended for Incorporation into an Apparatus 
would be Excluded from the EMC Directive.

An Apparatus must also be intended for the End User. Though in this case, the 
End User would be an Engineer with knowledge of Electronics which would most 
likely include at least some knowledge of EMC. On page 17 of the guide where it 
describes what an End User is, see the text that says, Generally an end-user 
is deemed to have no qualifications in the field of electromagnetic 
compatibility.  Products not intended for the End User is Excluded from the 
EMC Directive.

In the scope of the EMC Directive, it says, When compliant with the provisions 
of the EMC Directive, equipment
may be placed on the market and/ or put into service in the Community 
territory, freely moved and operated as designed and intended in the expected 
electromagnetic environment.  So what is the expected electromagnetic 
environment for a product like this? It is intended to be used Temporarily in 
an engineering lab or Research and Development lab. What is the Expected EMC 
Environment of such an area where prototype electronic devices without any EMC 
testing is commonly operated for long periods of time? Though I cannot find any 
text that specifically excludes prototype electronic devices operating in an 
RD environment, it is kind of a no brainer.

Hope this is somewhat helpful.

Brian


-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk]
Sent: Friday, October 25, 2013 6:22 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EMC requirements for developer/evaluation boards

In message
caey+zhmv+erfxd--dvutjklyva7wbr1dtjdkjxfqyj6m5lg...@mail.gmail.com,
dated Fri, 25 Oct 2013, EMC Guy emc.guy@gmail.com writes:

.  My literature research did not come up with anything helpful,
especially for Europe

As I explained, you will not find anything explicit about this issue.
Wherever you are, you can ask Farnell, but the answers will be Europe-oriented.
--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk If 
dictionaries were correct, we would only need one, because they would all give 
the same information.
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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Attachments are not permitted but the IEEE PSES Online

[PSES] EMC requirements for developer/evaluation boards

2013-10-24 Thread EMC Guy
Dear Group,

Big chip makers like Texas Instruments and others sell Eval boards to let
developers test out a chip before deciding if they want to include it in
their design.  These boards are usually not encased in a metal box, and are
meant to be used naked on a workbench with often many, many cables
attached to them.

I would like to know the EMC requirements for, let's say the US and Europe
(FCC and CE), on this type of equipment not intended for sale to the
general public.

If these products (they are sold, not given away) are exempt, what is the
method to get through customs without any EMC labeling on the device or
packaging?

Thanks for your comments and ideas.

John

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RE: CE mark on development/evaluation boards ?

2003-03-14 Thread john.radom...@modicon.com


 I don't want to self-certify and so a competent body looks like the way
to go.

Dave,

As I understand the EMCD, the manufacturer is the only person responsible
for the conformity of the apparatus, so he (or his authorized
representative in the EEA) has to issues a written EC Declaration of
Conformity (and affix the CE marking). Competent bodies are to help
complete the conformity assessment.

John Radomski
Schneider Electric







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RE: CE mark on development/evaluation boards ?

2003-03-13 Thread drcuthbert

We are currently going through a similar process with a board designed for
in-house use. We are planning to go for CE certification. We designed it to
EN61010 and it passed our own safety testing and radiated/immunity and ESD.
But it seems to be a gray area as to having it certified or not. I don't want
to self-certify and so a competent body looks like the way to go. 

   Dave Cuthbert
   Micron Technology


From: John Woodgate [mailto:j...@jmwa.demon.co.uk]
Sent: Friday, March 07, 2003 2:24 PM
To: emc-p...@majordomo.ieee.org
Subject: Re: CE mark on development/evaluation boards ?



I read in !emc-pstc that Peter L. Tarver peter.tar...@sanmina-sci.com
wrote (in nebbkemlgllmjofmoplememaeeaa.peter.tar...@sanmina-sci.com)
about 'CE mark on development/evaluation boards ?' on Fri, 7 Mar 2003:

I also have a current need for this information and would
appreciate being copied on anything off the list.

Why off-list? It seems to me that a lot of people would be interested in
answers, especially if one came from one of the suppliers mentioned.

[sigsnip]

 -Original Message-
 From: owner-emc-p...@majordomo.ieee.org
 [mailto:owner-emc-p...@majordomo.ieee.org]On
 Behalf Of Anthony Moulds
 Sent: Friday, March 07, 2003 9:30 AM
 To: emc-p...@majordomo.ieee.org
 Subject: CE mark on development/evaluation boards ?

I didn't get this message, so apologies to PT for hi-jacking his
response.


 Hi,

 It's unclear (to me anyway!) if
 development/evaluation test board products
 should be tested for
 compliance with the EU EMC directive. I often see
 boards supplied without
 the CE mark,
 e.g. Xilinx, TI, Altera development boards. Are
 these type of products
 exempt from the
 European directive ?

Well, are they shipped as functioning units? If you just get a pile of
parts, and the supplier has no *detailed* idea how you are going to
build them up, nor what software and peripherals you will add, the
supplier CAN'T carry out any meaningful EMC tests, let alone safety, so
the only **sensible** solution is to regard them as outside the scopes
of the Directives.

However, having 'sensible' and 'Directives' in the same sentence is
something of an oxymoron, so if anyone who has a definitive answer would
post, it would be very helpful.
-- 
Regards, John Woodgate, OOO - Own Opinions Only. http://www.jmwa.demon.co.uk 
Interested in professional sound reinforcement and distribution? Then go to 
http://www.isce.org.uk
PLEASE do NOT copy news posts to me by E-MAIL!


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RE: CE mark on development/evaluation boards ?

2003-03-11 Thread Peter L. Tarver

 From: John Woodgate
 Sent: Friday, March 07, 2003 1:24 PM

 Peter L. Tarver peter.tar...@sanmina-sci.com wrote:

 I also have a current need for this information and would
 appreciate being copied on anything off the list.

 Why off-list? It seems to me that a lot of people
 would be interested in
 answers

Many people reply off the list, directly to a poster rather
than to the list as a whole.  Their reasons are there own,
but I wanted to be certain I received as many responses to
Anthony's question as possible, since I coincidentally need
the same information.


Regards,

Peter L. Tarver, PE
Product Safety Manager
Sanmina-SCI Homologation Services
2000 Ringwood Ave.
San Jose, CA 95131-1749
V: 408-904-2081
F: 408-904-2095
M: 408-234-3529
peter.tar...@sanmina-sci.com



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RE: CE mark on development/evaluation boards ?

2003-03-11 Thread Peter L. Tarver

I also have a current need for this information and would
appreciate being copied on anything off the list.


Regards,

Peter L. Tarver, PE
Product Safety Manager
Sanmina-SCI Homologation Services
San Jose, CA
peter.tar...@sanmina-sci.com

 -Original Message-
 From: owner-emc-p...@majordomo.ieee.org
 [mailto:owner-emc-p...@majordomo.ieee.org]On
 Behalf Of Anthony Moulds
 Sent: Friday, March 07, 2003 9:30 AM
 To: emc-p...@majordomo.ieee.org
 Subject: CE mark on development/evaluation boards ?



 Hi,

 It's unclear (to me anyway!) if
 development/evaluation test board products
 should be tested for
 compliance with the EU EMC directive. I often see
 boards supplied without
 the CE mark,
 e.g. Xilinx, TI, Altera development boards. Are
 these type of products
 exempt from the
 European directive ?


 If anyone is in a position to throw light on this
 I would appreciate an
 email.

 Thanks.


 Anthony.



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Re: CE mark on development/evaluation boards ?

2003-03-11 Thread John Woodgate

I read in !emc-pstc that Peter L. Tarver peter.tar...@sanmina-sci.com
wrote (in nebbkemlgllmjofmoplememaeeaa.peter.tar...@sanmina-sci.com)
about 'CE mark on development/evaluation boards ?' on Fri, 7 Mar 2003:

I also have a current need for this information and would
appreciate being copied on anything off the list.

Why off-list? It seems to me that a lot of people would be interested in
answers, especially if one came from one of the suppliers mentioned.

[sigsnip]

 -Original Message-
 From: owner-emc-p...@majordomo.ieee.org
 [mailto:owner-emc-p...@majordomo.ieee.org]On
 Behalf Of Anthony Moulds
 Sent: Friday, March 07, 2003 9:30 AM
 To: emc-p...@majordomo.ieee.org
 Subject: CE mark on development/evaluation boards ?

I didn't get this message, so apologies to PT for hi-jacking his
response.


 Hi,

 It's unclear (to me anyway!) if
 development/evaluation test board products
 should be tested for
 compliance with the EU EMC directive. I often see
 boards supplied without
 the CE mark,
 e.g. Xilinx, TI, Altera development boards. Are
 these type of products
 exempt from the
 European directive ?

Well, are they shipped as functioning units? If you just get a pile of
parts, and the supplier has no *detailed* idea how you are going to
build them up, nor what software and peripherals you will add, the
supplier CAN'T carry out any meaningful EMC tests, let alone safety, so
the only **sensible** solution is to regard them as outside the scopes
of the Directives.

However, having 'sensible' and 'Directives' in the same sentence is
something of an oxymoron, so if anyone who has a definitive answer would
post, it would be very helpful.
-- 
Regards, John Woodgate, OOO - Own Opinions Only. http://www.jmwa.demon.co.uk 
Interested in professional sound reinforcement and distribution? Then go to 
http://www.isce.org.uk
PLEASE do NOT copy news posts to me by E-MAIL!


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RE: CE mark on development/evaluation boards ?

2003-03-11 Thread Gibling, Vic

Hello Anthony,

I have experience of such a product (7 years ago). Compliance to the EMC
Directive was achieved through the Technical Construction File route with
guidance from a Competent Body.

Emission testing was performed with scope probes and logic analyser looms
attached as well as any interfacing cables, but no immunity testing as far
as I can remember.

The general approach was to assess the measured emissions, and there were
some howlers too, taking account of the where and how the product was used. 

Nothing was done to suppress the high emissions( 60dB at 10 metres). The
risk was considered acceptable based on the discrete frequency, likelihood
of interference and that the emission would not be on continually (!!). 

It was also necessary to inform the customer that the product:
should only be operated in an industrial test and development area;
that it could be susceptible to ESD, mobile phones etc;
if it was to cause interference then, use ferrites, move/reorientate it or
the victim;
etc etc.

Hope this helps

Vic Gibling
Compliance Engineer
Internet:  www.e2vtechnologies.com




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CE mark on development/evaluation boards ?

2003-03-07 Thread Anthony Moulds

Hi,

It's unclear (to me anyway!) if development/evaluation test board products
should be tested for
compliance with the EU EMC directive. I often see boards supplied without
the CE mark,
e.g. Xilinx, TI, Altera development boards. Are these type of products
exempt from the
European directive ?


If anyone is in a position to throw light on this I would appreciate an
email.

Thanks.


Anthony.




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RE: Evaluation Boards - again

2000-06-14 Thread David_Sterner

 Eval boards must comply with FCC requirements.  Legally this does not 
 mean they must meet Class A/B emissions levels.
 
 It is your call whether to meet Class A/B or mark the evaluation 
 boards with the disclaimer of Section 2.803, see (e)(1)(v) under 
 paragraph 2.803.
 
 From a customer's perspective your decision should be based on how 
 much assistance is needed.
 - do you know the final mechanical design (shielding)?
 - will the circuitry end up in a PC?
 - are you sharing PWBA layout files with the customer?
 - does the circuitry contain a chip that cannot easily be EMI-tamed?
 - would customers be upset if the eval board has an FCC disclaimer?
 
 David
 
 
 


__ Reply Separator
_
Subject: Evaluation Boards - again
Author:  Vic Gibling SMTP:v...@virata.com at ADEMCONET
List-Post: emc-pstc@listserv.ieee.org
Date:6/14/2000 4:04 AM


Hi,
 
Thank you for your previous comments regarding Evaluation Boards. 
Could I raise one issue for further comment.
 
It has been stated that Evaluation Boards must comply with FCC emc 
requirements CFR 47  Part 15.
 
Another view is that Evaluation Cards are exempt as defined by section 
15.103 (c) which states;
 -- A digital device used exclusively as industrial, commercial, or medical
test equipment. --
 
In Europe I know one Evaluation Board manufacturer gained CE compliance 
through the Technical Construction File route. The product exceeded 
recognised industrial emc emission levels but was 'passed' by a Competent 
Body on the proviso that it's use was restricted to industrial development 
premises. Unfortunately I don't now how he dealt with this for the US.
 
Knowing how these boards are often used - external cables to logic 
analysers, additional circuitry connected to expansion ports - the EU 
approach is reasonable
 
Has anyone any comments to offer or suggested sources of information.
 
Vic
 
v...@virata.com
 
 
 
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Evaluation Boards - again

2000-06-14 Thread Vic Gibling

Hi,

Thank you for your previous comments regarding Evaluation Boards. 
Could I raise one issue for further comment.

It has been stated that Evaluation Boards must comply with FCC emc
requirements CFR 47  Part 15.

Another view is that Evaluation Cards are exempt as defined by section
15.103 (c) which states;
 -- A digital device used exclusively as industrial, commercial, or medical
test equipment. --

In Europe I know one Evaluation Board manufacturer gained CE compliance
through the Technical Construction File route. The product exceeded
recognised industrial emc emission levels but was 'passed' by a Competent
Body on the proviso that it's use was restricted to industrial development
premises. Unfortunately I don't now how he dealt with this for the US.

Knowing how these boards are often used - external cables to logic
analysers, additional circuitry connected to expansion ports - the EU
approach is reasonable

Has anyone any comments to offer or suggested sources of information.

Vic

v...@virata.com



---
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RE: Evaluation Boards

2000-05-24 Thread David_Sterner

 
 John,
 For developmental boards the pertinent paragraphs of CFR47 immediately 
 follow the text you transcribed.  FCC clearly exempts boards used for 
 development at a customer facility under paragraphs (v) and (2),
however 
 the marking requirement applies.
 
 (iv) Evaluation of product performance and determination of customer 
 acceptability, provided such operation takes place at the
manufacturer's 
 facilities during developmental, design, or pre-production states; or
 (v) Evaluation of product performance and determination of customer 
 acceptability where customer acceptability of a radio frequency device 
 cannot be determined at the manufacturer's facilities because of size
or 
 unique capability of the device, provided the device is operated at a 
 business commercial, industrial, scientific, or medical user's site,
but 
 not at a residential site, during the development, design or
pre-production 
 stages.  A product operated under this provision shall be labeled, in a

 conspicuous location with the notice in paragraph (c) of this section.
 (2) For the purpose of paragraphs (e)(1)(v) of this section, the term 
 'manufacturer's facilities' includes the facilities of the party 
 responsible for compliance with the regulations and the manufacturer's 
 premises, as well as the facilities of other entities working under the

 authorization of the responsible party in connection with the
development 
 and manufacture, but not marketing, of the equipment.
 
 'Marketing' is subject to interpretation; many companies have technical

 marketing departments with their own development labs.  My
interpretation:  
 to demonstrate ~ in front of customers, the marketing paragraphs apply.
 
 David

__ Reply Separator
_
Subject: RE: Evaluation Boards
Author:  jestuckey SMTP:jestuc...@micron.com at ADEMCONET
List-Post: emc-pstc@listserv.ieee.org
Date:5/23/2000 10:56 AM


I had forwarded this to Vic upon receiving his request last week, but 
viewing some on the responses that I have seen, I feel it would be 
appropriate to put it out for general viewing.
 
Look at 47 CFR
 2.803 Marketing of radio frequency devices prior to equipment 
authorization.
(a) Except as provided elsewhere in this section, no person shall sell or 
lease, or offer for sale or lease (including advertising for sale or lease),

or import, ship, or distribute for the purpose of selling or leasing or 
offering for sale or lease, any radio frequency device unless:
(1) In the case of a device subject to certification, such device has been 
authorized by the Commission in accordance with the rules in this chapter 
and is properly identified and labeled as required by  2.925 and other 
relevant sections in this chapter; or
(2) In the case of a device that is not required to have a grant of 
equipment authorization issued by the Commission, but which must comply with

the specified technical standards prior to use, such device also complies 
with all applicable administrative (including verification of the equipment 
or authorization under a Declaration of Conformity, where required), 
technical, labeling and identification requirements specified in this 
chapter.
(b) The provisions of paragraph (a) of this section do not prohibit 
conditional sales contracts between manufacturers and wholesalers or 
retailers where de-livery is contingent upon compliance with the applicable 
equipment authorization and technical requirements, nor do they prohibit 
agreements between such parties to produce new products, manufactured in 
accordance with designated specifications.
(c) Notwithstanding the provisions of paragraphs (a), (b), (d) and (f) of 
this section, a radio frequency device may be advertised or displayed, e.g.,

at a trade show or exhibition, prior to equipment authorization or, for 
devices not subject to the equipment authorization requirements, prior to a 
determination of compliance with the applicable technical requirements 
provided that the advertising contains, and the display is accompanied by, a

conspicuous notice worded as follows:
 
This device has not been authorized as required by the rules of the Federal 
Communications Commission. This device is not, and may not be, offered for 
sale or lease, or sold or leased, until authorization is obtained.
 
(1) If the product being displayed is a prototype of a product that has been

properly authorized and the prototype, itself, is not authorized due to 
differences between the prototype and the authorized product, the following 
disclaimer notice may be used in lieu of the notice stated in paragraph (c) 
introductory text of this section:
 
Prototype. Not for sale.
 
(2) Except as provided elsewhere in this chapter, devices displayed under 
the provisions of paragraphs (c) introductory

RE: Evaluation Boards

2000-05-23 Thread jestuckey
 jestuc...@micron.com
 
 


-Original Message-
From: Vic Gibling [mailto:v...@virata.com]
Sent: Monday, May 22, 2000 09:35
To: emc-p...@ieee.org
Subject: Evaluation Boards



Hi All

As a chip manufacturer we provide Evaluation Boards to licencees for product
development.

I would appreciate any advice, guidance or comments regarding safety and emc
issues with regard to these boards.

Thank you.

Vic Gibling

v...@virata.com



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RE: Evaluation Boards

2000-05-23 Thread David_Sterner

 Vic,
 There is no US legal obligation for EMC/safety on development boards 
 so long as they are offered for sale.  If a system containing the 
 board is offered for sale, then the system must pass EMI requirements 
 any market-imposed safety requirements (e.g. UL1950).
 
 If the customer usually incorporates the development board circuitry 
 into a larger PWBA, app. notes will prevent frantic calls at the end 
 of the development cycle about not passing EMC and safety.
 
 EMC
 If the development board fails applicable requirements, you should 
 provide an app. note explaining how to meet the requirements.
 
 SAFETY
 Any special markings, warnings, telco restrictions, etc. should be 
 explained in an app. note.
 
 David


__ Reply Separator
_
Subject: Evaluation Boards
Author:  Vic Gibling SMTP:v...@virata.com at ADEMCONET
List-Post: emc-pstc@listserv.ieee.org
Date:5/22/2000 11:34 AM


Hi All
 
As a chip manufacturer we provide Evaluation Boards to licencees for product

development.
 
I would appreciate any advice, guidance or comments regarding safety and emc

issues with regard to these boards.
 
Thank you.
 
Vic Gibling
 
v...@virata.com
 
 
 

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RE: Evaluation Boards

2000-05-22 Thread Grant, Tania (Tania)

Vic,

I am not sure whether you are providing a product or a service.   Agencies
control products;-- I am not aware that they are controlling services in the
ITE product category.

However, assuming that you want to perform due diligence with respect to
what you are providing to your customers, I believe the question should be
asked,-- how are your customers using these Evaluation Boards ?Are
these boards just a convenient place to mount your chips?Is there any
circuitry on these boards that enables your customers to run some tests?
And if there is such circuitry, what would be the test platform?

Assuming that the test platform is either a PC or some test and measurement
equipment, and your circuitry is designed for that specific platform, and
you want to encourage your customers to buy your chips rather than someone
else's because they are so good and, most important, they meet the
applicable EMC limits and safety requirements, then-

*   you test your Evaluation Boards in that platform to the appropriate
standards.

However, I am not sure that legally you are required to do all of the above.
I hope that someone else can shed some better wisdom on this very
interesting subject.

Tania Grant, tgr...@lucent.com mailto:tgr...@lucent.com 
Lucent Technologies, Intelligent Network Unit
Messaging Solutions Group


--
From:  Vic Gibling [SMTP:v...@virata.com]
Sent:  Monday, May 22, 2000 8:35 AM
To:  emc-p...@ieee.org
Subject:  Evaluation Boards


Hi All

As a chip manufacturer we provide Evaluation Boards to licencees for product
development.

I would appreciate any advice, guidance or comments regarding safety and emc
issues with regard to these boards.

Thank you.

Vic Gibling

v...@virata.com



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Evaluation Boards

2000-05-22 Thread Vic Gibling

Hi All

As a chip manufacturer we provide Evaluation Boards to licencees for product
development.

I would appreciate any advice, guidance or comments regarding safety and emc
issues with regard to these boards.

Thank you.

Vic Gibling

v...@virata.com



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