Re: TCF for EMC directive

2001-08-16 Thread Dan Kwok

Thanks Barbara for the detailed text. It would seem Article 10.5 of the
EMC Directive is no longer relevant when one is applying the RTTE
Directive. That is implied in the wording of Article 20 of the RTTE
Directive. Even though Article 10.5 remains in the text of the EMC
Directive, I anticipate the clause will be removed for the next
revision. 

Best Regards,

-- 

Daniel Kwok, P.Eng.
Principal EMC Engineer 
Intetron Consulting, Inc.  
Vancouver, Canada
Phone (604) 432-9874
Email dk...@intetron.com
Web http://www.intetron.com

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RE: TCF for EMC directive

2001-08-15 Thread Barbara Judge

Dan,

There are several US CABs designated by NIST and confirmed by the EU.  The
RTTE CABs hold the same status as an EU Notified Body under the RTTE
Directive.

Best Regards,
Barbara
___
Barbara L. Judge
Vice President 
Compliance Certification Services
Designated TCB and CAB
561F Monterey Road
Morgan Hill, CA 95037
408-463-0885 ext.104   
Fax:  408-463-0888
e-mail:  bju...@ccsemc.com
http://www.ccsemc.com


-Original Message-
From: Dan Kwok [mailto:dk...@intetron.com]
Sent: Tuesday, August 14, 2001 7:09 PM
To: Barbara Judge
Cc: emc-p...@majordomo.ieee.org
Subject: Re: TCF for EMC directive



Barbara Judge wrote:
 
 Notified Bodies have no part in assessing TCFs under Article 10.2 of the
EMC
 Directive.  Notified Bodies dealt with radio transmitting devices under
 Article 10.5 but the overwhelming majority of those devices now fall under
 the RTTE Directive.
 

What happens if a type-examination certificate is required under
Article 10.5 of the EMC Directive? Can a U.S. CAB also issue this
certificate or would one need to obtain it from a Notified Body located
in the EU?

Just curious.

Dan Kwok

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RE: TCF for EMC directive

2001-08-15 Thread Barbara Judge

Dan,

Please note excerpts from RTTE Directive:

Article 20
Repeal
1. Directive 98/13/EC is hereby repealed as from 8 April 2000.
2. This Directive is not a specific directive within the meaning of Article
2(2) of Directive 89/336/EEC. The provisions of Directive 89/336/EEC shall
not apply to apparatus falling within the scope of this Directive, with the
exception of the protection requirements in Article 4 and Annex III and the
conformity assessment procedure in Article 10(1) and (2) of, and Annex I to,
Directive 89/336/EEC, as from 8 April 2000.
3. The provisions of Directive 73/23/EEC shall not apply to apparatus
falling within the scope of this Directive, with the exceptions of the
objectives with respect to safety requirements in Article 2 and Annex I and
the conformity assessment procedure in Annex III, Section B, and Annex IV to
Directive 73/23/EEC, as from 8 April 2000.


the above pulls telecom equipment out from coverage by the EMC Directive and
the following requires compliance, under the RTTE Directive, with both the
EMC  LV Directives.


Article 3
Essential requirements
1. The following essential requirements are applicable to all apparatus:
(a) the protection of the health and the safety of the user and any other
person, including the objectives with respect to safety requirements
contained in Directive 73/23/EEC, but with no voltage limit applying;
(b) the protection requirements with respect to electromagnetic
compatibility contained in Directive 89/336/EEC.
2. In addition, radio equipment shall be so constructed that it effectively
uses the spectrum allocated to terrestrial/space radio communication and
orbital resources so as to avoid harmful interference.
3. In accordance with the procedure laid down in Article 15, the Commission
may decide that apparatus within certain equipment classes or apparatus of
particular types shall be so constructed that:
(a) it interworks via networks with other apparatus and that it can be
connected to interfaces of the appropriate type throughout the Community;
and/or that
(b) it does not harm the network or its functioning nor misuse network
resources, thereby causing an unacceptable degradation of service; and/or
that
(c) it incorporates safeguards to ensure that the personal data and privacy
of the user and of the subscriber are protected; and/or that
(d) it supports certain features ensuring avoidance of fraud; and/or that
(e) it supports certain features ensuring access to emergency services;
and/or that
(f) it supports certain features in order to facilitate its use by users
with a disability.


I hope that you find this helpful.  

Best Regards,
Barbara
___
Barbara L. Judge
Vice President 
Compliance Certification Services
Designated TCB and CAB
561F Monterey Road
Morgan Hill, CA 95037
408-463-0885 ext.104   
Fax:  408-463-0888
e-mail:  bju...@ccsemc.com
http://www.ccsemc.com



-Original Message-
From: Dan Kwok [mailto:dk...@intetron.com]
Sent: Wednesday, August 15, 2001 11:03 AM
To: emc-p...@majordomo.ieee.org
Subject: Re: TCF for EMC directive



John Woodgate wrote:

 10.5 is deleted in 'favour' of the RTTE Directive, isn't it?


Article 10.5 is still in the current version of the EMC Directive. 


Dan Kwok

-- 

Daniel Kwok, P.Eng.
Principal EMC Engineer 
Intetron Consulting, Inc.  
Vancouver, Canada
Phone (604) 432-9874
Email dk...@intetron.com
Web http://www.intetron.com

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Re: TCF for EMC directive

2001-08-15 Thread Dan Kwok

John Woodgate wrote:

 10.5 is deleted in 'favour' of the RTTE Directive, isn't it?


Article 10.5 is still in the current version of the EMC Directive. 


Dan Kwok

-- 

Daniel Kwok, P.Eng.
Principal EMC Engineer 
Intetron Consulting, Inc.  
Vancouver, Canada
Phone (604) 432-9874
Email dk...@intetron.com
Web http://www.intetron.com

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RE: TCF for EMC directive

2001-08-15 Thread Allen, John

Hi Folks

This topic has rather drifted and I cannot remember what the original
point was. 

But, as a reminder, the following document on the UK Department of Trade and
Industry  might be of some use:
http://www.dti.gov.uk/strd/emcps00.pdf

This is the DTI guidance note on compliance with the EMC Directive. 

Page 7 gives basic guidance about TCF's and ANNEX B gives guidance on the
content thereof - although you might find that Competent Bodies might
require more (e.g. your ISO 9000 accreditations for the design and
manufacturing operations to ensure that there is some liklihood that shipped
products resemble the ones described in the file!).

John Allen


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Re: TCF for EMC directive

2001-08-15 Thread John Woodgate

I read in !emc-pstc that Dan Kwok dk...@intetron.com wrote (in
3b79d9c1.159c7...@intetron.com) about 'TCF for EMC directive', on Tue,
14 Aug 2001:
What happens if a type-examination certificate is required under
Article 10.5 of the EMC Directive? Can a U.S. CAB also issue this
certificate or would one need to obtain it from a Notified Body located
in the EU?

10.5 is deleted in 'favour' of the RTTE Directive, isn't it?
-- 
Regards, John Woodgate, OOO - Own Opinions Only. http://www.jmwa.demon.co.uk 
Eat mink and be dreary!

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Re: TCF for EMC directive

2001-08-15 Thread Dan Kwok

Barbara Judge wrote:
 
 Notified Bodies have no part in assessing TCFs under Article 10.2 of the EMC
 Directive.  Notified Bodies dealt with radio transmitting devices under
 Article 10.5 but the overwhelming majority of those devices now fall under
 the RTTE Directive.
 

What happens if a type-examination certificate is required under
Article 10.5 of the EMC Directive? Can a U.S. CAB also issue this
certificate or would one need to obtain it from a Notified Body located
in the EU?

Just curious.

Dan Kwok

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RE: TCF for EMC directive

2001-08-15 Thread Barbara Judge

John,

I would agree that the ability to have face to face meetings with the
Competent Body is of key importance.  There are a number of bodies
designated in the United States at this time, called Conformity Assessment
Bodies, which hold equal status in the EU to any Competent Body in the EU.
Bottom line:  You no longer have to go to the EU to find a designated body
to review and approve your TCFs.  

Notified Bodies have no part in assessing TCFs under Article 10.2 of the EMC
Directive.  Notified Bodies dealt with radio transmitting devices under
Article 10.5 but the overwhelming majority of those devices now fall under
the RTTE Directive.

Best Regards,
Barbara
___
Barbara L. Judge
Vice President 
Compliance Certification Services
Designated TCB and CAB
561F Monterey Road
Morgan Hill, CA 95037
408-463-0885 ext.104   
Fax:  408-463-0888
e-mail:  bju...@ccsemc.com
http://www.ccsemc.com


-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk]
Sent: Tuesday, August 14, 2001 1:04 PM
To: emc-p...@majordomo.ieee.org
Subject: Re: TCF for EMC directive



I read in !emc-pstc that Stuart Lopata stu...@timcoengr.com wrote (in
002e01c124e5$aadceac0$1301a8c0@newberry) about 'TCF for EMC
directive', on Tue, 14 Aug 2001:
Does anyone know of any good information on how to make a technical 
construction file (TCF) for the EMC directive?  My company is working
on 
obtaining its CAB certification neccessary to provide our customers
with a 
CE mark.
 
If at all possible, DON'T use the TCF route. It can be practicable if
you are in Europe and can have face-to-face meetings with your Notified
Body. 

You can almost certainly use the standards route now, which has far
fewer uncertainties. What sort of product is involved?
-- 
Regards, John Woodgate, OOO - Own Opinions Only. http://www.jmwa.demon.co..uk

Eat mink and be dreary!

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Re: TCF for EMC directive

2001-08-14 Thread John Woodgate

I read in !emc-pstc that Stuart Lopata stu...@timcoengr.com wrote (in
002e01c124e5$aadceac0$1301a8c0@newberry) about 'TCF for EMC
directive', on Tue, 14 Aug 2001:
Does anyone know of any good information on how to make a technical 
construction file (TCF) for the EMC directive?  My company is working on 
obtaining its CAB certification neccessary to provide our customers with a 
CE mark.
 
If at all possible, DON'T use the TCF route. It can be practicable if
you are in Europe and can have face-to-face meetings with your Notified
Body. 

You can almost certainly use the standards route now, which has far
fewer uncertainties. What sort of product is involved?
-- 
Regards, John Woodgate, OOO - Own Opinions Only. http://www.jmwa.demon.co..uk 
Eat mink and be dreary!

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RE: TCF for EMC directive

2001-08-14 Thread Barbara Judge
Stuart,
 
The Directive itself stipulates what must be contained in the TCF and the
Guidance notes go into greater detail.  Attached please find website for
Guidance Notes.
http://europa.eu.int/comm/enterprise/electr_equipment/emc/guides/english.pdf
http://europa.eu.int/comm/enterprise/electr_equipment/emc/guides/english.pd
f 
 
Good Luck.
Best Regards, 
Barbara 
___ 
Barbara L. Judge 
Vice President 
Compliance Certification Services 
Designated TCB and CAB 
561F Monterey Road 
Morgan Hill, CA 95037 
408-463-0885 ext.104   
Fax:  408-463-0888 
e-mail:  bju...@ccsemc.com 
http://www.ccsemc.com http://www.ccsemc.com/  

-Original Message-
From: Stuart Lopata [mailto:stu...@timcoengr.com]
Sent: Tuesday, August 14, 2001 10:22 AM
To: emc
Subject: TCF for EMC directive


Does anyone know of any good information on how to make a technical
construction file (TCF) for the EMC directive?  My company is working on
obtaining its CAB certification neccessary to provide our customers with a
CE mark.
 
Stuart Lopata
 
Compliance Engineer
Timco Engineering



RE: TCF for EMC directive

2001-08-14 Thread WOODS

You can find the information at 
http://europa.eu.int/comm/enterprise/electr_equipment/emc/index.htm
http://europa.eu.int/comm/enterprise/electr_equipment/emc/index.htm 

Look in the guidelines.

--
From:  Stuart Lopata [SMTP:stu...@timcoengr.com]
Sent:  Tuesday, August 14, 2001 1:22 PM
To:  emc
Subject:  TCF for EMC directive

Does anyone know of any good information on how to make a technical
construction file (TCF) for the EMC directive?  My company is working on
obtaining its CAB certification neccessary to provide our customers with a
CE mark.
 
Stuart Lopata
 
Compliance Engineer
Timco Engineering

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Re: TCF for EMC Directive

2000-03-01 Thread Jerry Roberton

Sam,

You  have a choice of 3 basic routes to satisfy the  EMC Directive.

1.  The standards  route.   You had the product tested  to  the appropriate
harmonised  Standards.   So you have  evidence you pass.  You can self declare.

2.  You use the Technical Construction File Route.  This mandates  production
and retention of the TCF  document.  Then you self declare.

3.  The EC Type examination route.  Getting a  Notified Body involved.
 They will get all the documents out of you, their checks  reduce your risk
considerably.  You get a certificate  instead of a self declaration.  This route
is a bit old.


For your  own peace of mind  the minimum  material I would  store  to back up D
of C would be the test reports + BOM and schematics  of the product  to prove
identification at any later  challenge.

Only  route 2.  requires  production of a formal TCF  but  actions you took to
comply with routes 1 and 3  would create a  document trail anyway.

My option has  been to use  route 1 wherever possible  and keep  supporting
evidence  with the product file.

Jerry Roberton
International Compliance Manager
NET Europe Ltd.
www.net.com


Wismer, Sam wrote:

 Bob et. al,
 Thanks for your comments.  I use the term TCF only because we include all
 the same materials as would be required if we did submit it to a competent
 body.   Perhaps Technical file is more appropriate.  We do not submit it
 because we do not deviate from the Directive.  However some feel that it is
 a document that, according to the directive, must be created to back up your
 declaration.  My question is, does the directive really require such a
 document be created?

 Sam Wismer
 RF Approvals Engineer
 LXE, Inc.
 (770) 447-4224 Ext. 3654

 Visit Our Website at:
 http://www.lxe.com

 -Original Message-
 From: Chaplis, Bob [mailto:chapl...@genrad.com]
 Sent: Tuesday, February 29, 2000 3:14 PM
 To: 'John Juhasz'
 Cc: Wismer, Sam
 Subject: RE: TCF for EMC Directive

 John,
 I think what Sams question relates to is a TCF required to show
 compliance with the EMC Directive, and to that the answer is no, The TCF is
 but one avenue that a manufacturer can use to show conpliance to the
 Directive. I wonder if Sam did not mean Techical File: instead of TCF. Is
 that correct Sam? The TCF must be under control of a Competant Body.

Bob Chaplis
  Genrad.
  -Original Message-
  From: John Juhasz [SMTP:jjuh...@fiberoptions.com]
  Sent: Tuesday, February 29, 2000 12:38 PM
  To:   'Wismer, Sam'; EMC Forum (E-mail)
  Subject:  RE: TCF for EMC Directive
 
  Sam,
 
  Regarding TCFs, it really depends on your product/product's configuration
  management.
 
  If you have a product (with a specific model name/munber) that will only
  be used 'as is'
  (no variations) then a TCF is required.
  However, if you have a product which is a base model for which there may
  be numerous
  variations, then the TCF is the way to go.
 
  John Juhasz
  Fiber Options
  Bohemia, NY
 
 
  -Original Message-
  From: Wismer, Sam [ mailto:wisme...@lxe.com]
  Sent: Tuesday, February 29, 2000 10:34 AM
  To: EMC Forum (E-mail)
  Subject: TCF for EMC Directive
 
 
 
  All,
  Thank you for your replies to my VCCI question.  The point came through
  loud
  and clear that VCCI certification is only voluntary, however maybe
  mandated
  by the market.  In short, if your customer doesn't care, then why bother.
 
  New question:
 
  There is some debate whether or not it is mandatory for a manufacturer to
  create and maintain a TCF to show compliance to the EMC Directive(ITE
  Equipment only).  We currently do create a TCF for every product when we
  apply the EMC directive.  Some here think it is necessary, and some think
  not, however in any case it happens to be a great place to keep test
  reports, schematics, drawings and the like so it is not really an issue
  until we contract a vendor to produce a product for us.  Usually we
  require
  them to obtain all the necessary approvals so that we don't have to.
 
  With this scenario, and the difference of opinion in the necessity for a
  TCF, should we require our vendor to create a TCF?  If they choose not to,
 
  are we liable since we will private label it and place it on the market?
  Should we create the TCF with their reports?
 
  Thanks in advance
 
 
 
  Sam Wismer
  RF Approvals Engineer
  LXE, Inc.
  (770) 447-4224 Ext. 3654
 
  Visit Our Website at:
  http://www.lxe.com
 
 
 
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   Jim Bacher:  jim_bac...@mail.monarch.com, or
   Michael Garretson:pstc_ad...@garretson.org
  For policy questions, send mail to:
   Richard Nute:   ri...@ieee.org