RE: CE and/or e-mark for products operated in vehicles

1998-03-20 Thread Frazee Doug
As an EMC/safety third party test agency, I have performed both CE-Mark 
certifications and e-mark type testing of electronic devices.  95/54/EC type 
testing may be performed by third party test agencies, or by the manufacturer, 
but must be witnessed by a Notified Body.  Paragraph 15.3 of the "Guidelines on 
the Application of Council Directive 89/336/EEC" discusses EMC for motor 
vehicles and devices intended for fitment into motor vehicles.  Since the 
laptop computer, with car power supply may be operated by a passenger, while 
the car is being driven, 95/54/EC is mandatory.  CE marking is mandatory for 
usage outside the automobile.  Although not mandatory, I suggest testing to ISO 
7627-0 to verify immunity to automotive powerline transients.

Doug Frazee
EMC Compliance Engineer
Windermere Information Technology Systems
MILCOM Compliance Laboratories (MCL) division
401 Defense Highway
Annapolis, MD  21401
USA
(410) 266-1793
(410) 266-1751 FAX
dfra...@windermeregroup.com


-Original Message-
From:   andreas.tho...@toshiba-teg.com [SMTP:andreas.tho...@toshiba-teg.com]
Sent:   Thursday, March 19, 1998 3:38 AM
To: emc-p...@majordomo.ieee.org
Subject:CE and/or e-mark for products operated in vehicles


Dear compliance colleagues,

I like to hear you opinion about the question, which directive a product
should observe which can be operated in a vehicle (e.g. car), but also in
other environments. For products which are designed to be operated
exclusively in vehicles like car audio equipment or car power supplies it
seems to be clear that this euipment falls under the EC-Directive 95/54 and
must carry the e-mark. Products which can be used in different
environments, e.g. a laptop computer equipped with GPS-system, have to
carry therefore the CE-mark and the e-mark and must comply to both
directives (95/54 and 89/336) ?? Please give me your comment.

Kind regards

Andreas Thomas
Product Safety
Toshiba Europe








RE: CE and/or e-mark for products operated in vehicles

1998-03-19 Thread Arthur Poolton (MEPCD)
Andeas,
I believe that we have to consider the two scenarios :-
a) when the vehicle is parked and 
b) when it is moving.

If the vehicle is parked then there should be few safety issues.

If the vehicle is moving then there are an additional two scenarios :-
a) the PC is operated by the driver and 
b) the PC operated by a passenger

If the driver was operating the laptop then surely the driver would be
breaking law by taking their eyes from off the road.
If a passenger was operating the laptop then I reckon that the laptop
should also comply with 95/54. 

Because it is impossible to guarantee where, when, how and by whom the
laptop is likely to be used then it would seem prudent to err on the
side of caution and include 95/54 but I too would be interested in any
comments from the group.


Arthur Poolton
(Approvals Manager)
Mitsubishi Electric - PC Division

> --
> From:
> andreas.tho...@toshiba-teg.com[SMTP:andreas.tho...@toshiba-teg.com]
> Sent: 19 March 1998 09:38
> To:   emc-p...@majordomo.ieee.org
> Subject:  CE and/or e-mark for products operated in vehicles
> 
> 
> Dear compliance colleagues,
> 
> I like to hear you opinion about the question, which directive a
> product
> should observe which can be operated in a vehicle (e.g. car), but also
> in
> other environments. For products which are designed to be operated
> exclusively in vehicles like car audio equipment or car power supplies
> it
> seems to be clear that this euipment falls under the EC-Directive
> 95/54 and
> must carry the e-mark. Products which can be used in different
> environments, e.g. a laptop computer equipped with GPS-system, have to
> carry therefore the CE-mark and the e-mark and must comply to both
> directives (95/54 and 89/336) ?? Please give me your comment.
> 
> Kind regards
> 
> Andreas Thomas
> Product Safety
> Toshiba Europe
> 
> 
> 
> 
> 
> 
> 


RE: CE and/or e-mark for products operated in vehicles (2)

1998-03-25 Thread Frazee Doug
My first response on EMC-PSTC was a bit misleading!  For ITE and other portable 
devices with cigarette lighter power adapters, 95/54/EC testing is required.  
However, 95/54/EC should not be listed as a directive on the Declaration of 
Conformity.  It should be listed as a technical standard under the EMC 
Directive.  Since 95/54/EC is not a "new approach directive" it may not be used 
directly for CE marking.  

For CE marking, the EMC Directive guidelines, para. 15.3 allows the use of 
95/54/EC to demonstrate conformity with the EMC Directive.  The technical 
requirements are within 95/54/EC, and no harmonized test specs. are listed nor 
required.  95/54/EC covers both vehicle EMC testing and EMC of electronic 
sub-assemblies (ESA).  ESAs are defined as electrical or electronic devices 
intended to be "part of a vehicle."  Therefore, portable devices with cigarette 
lighter power adapters are not ESAs and will not require e-marking.  Therefore, 
for ITE with power adapters that may be used in an automobile, the declaration 
of conformity should list the Low Voltage and EMC Directives.  Specific 
standards under the EMC Directive would typically be EN 55022, EN 50081-2 and 
95/54/EC.  Under 95/54/EC, immunity testing is not required for "ESAs whose 
functions are not involved in the direct control of the vehicle."  Therefore, 
additional testing under 95/54/EC will involve only NB and BB radiated!
 emissions tests that may be performed either on an OATS or in an anechoic 
chamber.  These tests may be performed in conjunction with the EN 55022 tests, 
limiting the additional cost impact.  1m antenna spacing is used, quasi-peak 
detection for the BB test, peak or average for NB.  ISO 7637-1 automotive 
powerline transient immunity tests are recommended, but not specifically called 
out under the EMC Directive framework.

If e-marking is required, the device is by definition either a motor vehicle or 
an ESA that becomes part of a motor vehicle.  Conformity must be demonstrated 
by type testing, witnessed by a Notified Body under 95/54/EC.  The Notified 
Body may impose other requirements such as ISO 7637-1 powerline transient 
testing.  ESD testing is discussed in paragraph 8.4 of 95/54/EC and should not 
be required for either ESAs or for motor vehicles.

Doug Frazee
EMC Compliance Engineer
Windermere Information Technology Systems
MILCOM Compliance Laboratories (MCL) division
401 Defense Highway
Annapolis, MD  21401
USA
(410) 266-1793
(410) 266-1751 FAX
dfra...@windermeregroup.com
-Original Message-
From:   andreas.tho...@toshiba-teg.com [SMTP:andreas.tho...@toshiba-teg.com]
Sent:   Tuesday, March 24, 1998 8:54 AM
To: emc-p...@majordomo.ieee.org
Subject:CE and/or e-mark for products operated in vehicles (2)


Dear compliance colleagues,

thank you for your comments which I have received until now.
The problem is the appliance of the e-mark directive on products which are
not intended to be fitted (permanently installed) into a car, like a laptop
computer or handy. This seems to be once more a "grey area" which is not
clearly defined by the people creating those directives.
Have anyone of you seen comments listed up in the operating instructions of
a vehicle which do not allow to operate electronic products in the car
environment without observing e-mark or other specified requirements  ??

Kind regards

Andreas Thomas
Toshiba Europe